The JEC made a submission to the Australian Energy Market Operator’s (AEMO) consultation process on the Integrated System Plan (ISP) methodology.
The key changes proposed by AEMO from the last ISP were to upgrade the treatment of both gas and consumer energy resources (CER) as inputs into the ISP and make a small change to how actionable projects get assessed and processed within the ISP.
In relation to the former two changes, the JEC supported the changes with some qualifications. We noted that the improvements in the treatment of these elements as inputs was a stopping point before more substantive co-optimisation of all aspects of the energy system, and proposed ways this partial optimisation could occur in the 2026 ISP.
In relation to the treatment of actionable projects, we re-framed the proposed change as a move from optimising the delivery times of transmission projects from the perspective of the consumer to merely confirming that the projects provide positive net benefits to consumers at the delivery times nominated by proponents. While acknowledging that AEMO does not ultimately have any powers to force a proponent to deliver (or even try to deliver) a given project at the time that optimises consumer benefit, we argued that there was a value in defining a baseline defined by maximising consumer interest, and that the move away from optimisation should only occur if the costs for AEMO were prohibitively high. Given that AEMO has defined optimal delivery times for actionable projects in the four ISPs produced so far, this seems unlikely.
We also took the opportunity to reiterate our existing position that the ‘Progressive Change’ scenario does not conform to Australia’s commitments under the Paris Agreement, and should be removed from the ISP entirely.
