The JEC made a submission to the Australian Energy Market Commission’s (AEMC) consultation on three rule changes: Better integrating gas into the Integrated System Plan (ISP), Improving consideration of demand-side factors in the ISP, and Better integrating community sentient into the ISP.
We noted the absence of emissions reduction as an assessment criteria, and recommending adding this to bring the process into conformity with the National Gas and Electricity Objectives.
In relation to the first proposed rule change, we support the proposal to enhance the consideration of gas in the ISP, but only on the proviso that this is done in a balanced way. This means first, that the direct competitors to gas – storage and energy response – are also included, and in such a way that comparison between alternative solutions to a given identified need is meaningful and robust. Secondly, the cost estimates of gas (and the direct competitors) must be realistic.
In relation to the second rule, we support the intent to improve the quality of the data relating to demand side activity in the ISP, but note that the real value of the exercise lies in arriving at a point where demand-side investments can be considered alongside and co-optimised (or ‘orchestrated’) with supply side investments. We urged AEMO (via the AEMC) to reconsider the decision not to commence orchestration until the 2028 ISP.
Finally, in relation to the third rule, while we support the aim of more accurate cost assessment or transmission and other projects, we are weary of the risk of incentivising bad faith behaviour within the energy sector. In order to avoid this, we supported bespoke analysis of social licence costs for prospective projects, but limit the inputs to this to ‘real’ variables.
