The Justice and Equity Centre made a submission to the Australian Energy Market Operator’s (AEMO) Draft 2025 ISP Methodology.
While approving of AEMO’s expansion of the list of elements in the energy system included in the analysis, we noted that the ISP still falls well short of co-optimising investment in all aspects of the electricity system. It is no longer appropriate for planning to be focused exclusively on network augmentation, and we argued that this must be ameliorated for the 2028 ISP.
We argued that hydrogen assumptions and treatment should be further reined in for the 2026 ISP, and that no scenario should rest on the assumption that hydrogen rollout will vastly exceed current expectations and overcome the established limitations of the technology.
We also supported AEMO’s ambition to introduce assumptions about imperfect foresight, but again argued that doing this via add-ons, such as the proxy of storage ‘footroom’, is not adequate. This may be the only viable alternative for the 2026 iteration of the ISP, but for the 2028 iteration, the assumption will need to be added in a more fundamental way. This will require the upgrading, or even replacement, of the modeling platform, PLEXOS, which AEMO uses for ISP and other work.
