The Integrated System Plan can guide the future of the power system providing it is robust to change and factors-in all relevant policy not just the development of Renewable Energy Zones.

Energy Consumers Australia is the national voice for residential and small business energy consumers. Established by the Council of Australian Governments (COAG) in 2015, our objective is to promote the long-term interests of consumers with respect to price, quality, reliability, safety and security of supply.

The nature of the national electricity system is changing as large fossil fuel generators are replaced by more, smaller renewable energy generation and storage including those owned and operated by household and small business energy consumers. This emerging, more decentralised energy system has implications for the role of transmission infrastructure and where it will need to be built. This transitioning energy system is changing the nature of the risks in the system that needs to be managed.

This submission comments on AEMO’s response to this recommendation its proposal for an Integrated System Plan (ISP) as outlined in the Integrated System Plan Consultation (the Paper) in December 2017.

Energy Consumers Australia (ECA) is pleased to respond to the Paper.

In summary:

• ECA considers the ISP to be an important mechanism to promote optimised, whole of system planning, investment and operation. We welcome the emphasis on system rather than grid in the name of the plan to consider a wide spectrum of interconnected infrastructure and energy developments including transmission, generation, gas pipelines, and distributed energy resources.
• The modelling underpinning the ISP must be open and transparent it is important to understand what modelling does, and what the results can and cannot tell us. The current version of the Paper treats the underlying modelling as something of a black box. We recommend that more emphasis be placed on explaining the inner workings of the model, and what this means for the results.
• The ISP needs to consider how Renewable Energy Zones (REZ) interact with other policy decisions the use and selection of REZs is only one of the policy levers available to influence transmission and power system investment. As part of its analysis, AEMO needs to consider how REZs might interact with other policies, such as the design and application of the Regulatory Investment Test for Transmission (RIT-T).
• The ISP should make extensive use of sensitivity analysis the principal purpose of sensitivity analysis is to identify which variables are of greatest significance to the results. ECA considers that there is greater scope for AEMO to undertake sensitivity analysis as part of its modelling to shed light on the factors that are likely to drive costs and around which there are greater risks.

ECA understands that the ISP is currently an indicative study and welcomes future development of the ISP and the analysis that underpins it.

The full submission can be read here.