Amongst the many emails that hit my inbox recently was an email from the AEMC that spoke to the ‘Package of ISP reform underway’ – and specifically these two arms:
Rule Change Request (from CIS):
Clarifying the treatment of jurisdictional policies and system costs in the ISP |
Statutory Requirement:
Review of the ISP |
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Almost exactly a year ago (on 31st October 2024), Aidan Morrison of the Center for Independent Studies submitted this rule change request about ‘Making the ISP robust to policy change and clear on costs’:
Since that time, the wheels have been turning within the AEMC, and it was with interest that we saw the AEMC initiate a process to consider the application above. For those still on Twitter, you might have noticed Aidan’s (sometimes very) lengthy dissertations about his thoughts on the whole ISP process. So:
You can find more information from the AEMC:
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In parallel with the CIS-initiated Rule Change proposal, the email from the AEMC also communicated these Terms of Reference for the review of the ISP:
Within that document, it’s worth highlighting three extracts. 1) Firstly, with respect to the AEMC role, it says (p2/4): ‘The Australian Energy Market Commission (the AEMC or Commission) is required to complete a review (the Review) of the Integrated System Plan (ISP) framework by 1 July 2027 …’ 2) With respect to the AEMO role, it says (p2/4): ‘The Australian Energy Market Operator (AEMO) has been required by the Rules to produce the biennial ISP since 2018. The purpose of the ISP is: (quoting from Clause 5.22.2 of the NER) “To establish a whole of system plan for the efficient development of the power system that achieves power system needs for a planning horizon of at least 20 years to contribute to achieving the national electricity objective. “ The ISP is a key planning document for electricity transmission businesses, including for actionable ISP projects triggering regulatory processes, such as the RIT-T. It is also a central reference point for jurisdictions and the energy sector more broadly.’ 3) And then it notes the plan as follows: ‘The Commission intends to publish the following papers: • consultation paper … though no sub-timing (other than the deadline above) is given. You’ll be able to track more via the AEMC sub-site (ERC0092) under its own project reference
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Both developments are topical, given the increasing number (and volume) of people voicing various concerns about the Integrated System Plan. These include:
1) At the start of September 2025 at the 2025 QCES there were a number of speakers call into question the credibility of the 2024 ISP:
(a) Amongst them, Oliver Nunn called out how ‘the ISP Step Change Scenario is divorced from reality’; and
(b) David Dixon also spoke about how ‘we’re moving fast, but not fast enough’;
(c) And there were other comments from others as well.
2) At NEMdev 2025 it was no different, with other speakers also asking real questions about the ISP:
(a) There was Sarah Lawley speaking about ‘circular reasoning’; and
(b) Bruce Mountain, raising a number of objections – and suggesting these steps;
(c) And there were other comments from others as well.
So maybe these AEMC processes will provide a forum for improvements?
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