03 September 2026

Submission to the Australian Energy Market Commission (AEMC) on its Review of the Integrated System Plan (ISP) Framework Discussion Paper

Our submission to the Australian Energy Market Commission (AEMC) makes three central recommendations that will strengthen the Integrated System Plan (ISP) and its focus on consumers.

Our submission (PDF, 368.90KB) to the Australian Energy Market Commission (AEMC)'s Review of the Integrated System Plan (ISP) makes three recommendations aimed at strengthening the ISP and its focus on consumers.

Our recommendations:

  1. The ISP should be a whole-of-system plan. It should consider all electricity resources and capabilities that can contribute to meeting consumers’ electricity needs, regardless of whether they are traditionally classified and supply-side or demand-side.
  2. The ISP should co-optimise supply-side resources with demand-side resources. Both sides can transform the system, and both should be treated symmetrically in an unbiased modelling framework.
  3. The ISP should be robust and transparent. Stakeholders need to be able to understand the inputs, assumptions, methods and constraints used. ECA supports greater replicability of the modelling and stronger independent technical scrutiny through the creation of a Technical Panel.
Page last updated: 17 September 2026