17 November 2025

Submission to the AEMC on clarifying the treatment of jurisdictional policies and system costs in the Integrated System Plan

We support any effort to improve the ISP, particularly those that make it more robust, transparent and increase stakeholder confidence in the process.

Energy Consumers Australia supports any effort to make the Integrated System Plan (ISP) more robust and transparent to increase stakeholder confidence in the process.

The ISP’s primary role should be to provide a least-cost pathway to meet consumer and system needs, including emissions reduction targets. 

To achieve this, the ISP must:
1. Model demand-side resources robustly, allowing them to compete against supply-side resources.
2. Better integrate distribution and transmission planning, recognising the role of CER.
3. Continually assess the optimality of the current development path as technology, policy and consumer behaviour evolve.

However, we do not support the proponent’s proposed solutions

We understand the concerns around how the ISP incorporates jurisdictional policies. We believe more analysis would be valuable to inform stakeholders on the implications of these policies. 

Doing so would ensure the ISP delivers its intended purpose to establish a whole of system plan for the efficient development of the power system.

Download submission (PDF, 374.32KB)

Page last updated: 20 November 2025