19 February 2026

Submission to the AEMC on the Integrated System Plan (ISP) Framework Review Consultation Paper

We make several practical recommendations to the Australian Energy Market Commission (AEMC) to improve the Integrated System Plan and strengthen its focus on consumers.

Energy Consumers Australia makes several practical recommendations to the Australian Energy Market Commission (AEMC) to improve the Integrated System Plan (ISP) and strengthen its focus on consumers.

We recommend:

  1. The National Electricity Rules (NER) should be explicit about which elements of the National Energy Objective (NEO) operate as constraints, and which are components of the objective function
  2. The Australian Energy Market Operator (AEMO) states the relative likelihood of policy assumptions used in its scenarios
  3. AEMO establishes an independent technical panel to assist the ISP Consumer Panel
  4. Demand-side resources are considered as an equal alternative to supply-side resources in scenario modelling
  5. Each ISP should include a retrospective analysis comparing equivalent scenarios across consecutive ISPs
  6. The modelling framework must follow academic standards of replicability and use open-source tools

Download our submission to find out more.

Page last updated: 26 February 2026