PIAC made a submission to the Draft 2024 Integrated System Plan (ISP).
The ISP is a biennial planning document in which the Australian Energy Market Operator (AEMO) amalgamates the intended actions and targets of the jurisdictional governments in the National Energy Market, as well as the transmission and distribution service providers, as well as the plans of various private providers of services like generation and storage. It also outlines an ‘optimal’ development path for the development of transmission infrastructure in the national energy market.
PIAC argued that the planning needs of the national energy market have evolved since the first ISPs were created in 2018 and 2020. Transmission is no longer thew ‘low hanging fruit’ of the energy transition, and there is a need to coordinate action in a broader set of areas, including consumer energy resources, demand response, and the roll-out of energy efficiency technologies.
We objected to the claim in the document that all the scenarios chosen for analysis match current government emissions commitments, on the grounds that the slowest energy transition scenario examined matches a 2.6°C temperature increase, which is well above the Paris Agreement targets Australia is party to.
We also criticised the paucity of contingency planning and the management of planning risks in the document. These offer some of the most material risks to consumers in terms of increased costs. We provided practical measures where this could be improved in time for incorporation into the final 2024 ISP.
Reducing unfair fines and over-policing from alcohol-free zones