Energy Consumers Australia appreciates the opportunity to provide feedback on ‘Enhancing the
Integrated System Plan to Support the Energy Transition,’ particularly improving consideration of demand-side factors in the Integrated System Plan (ISP).

We welcome this rule change from the Commonwealth, as we see value in the Australian Energy Market Operator (AEMO) giving greater consideration to the network and non-network factors needed to enable the levels of consumer energy resources (CER) and their coordination forecast by the Integrated System Plan (ISP). However, we emphasise that this rule change should mark the beginning of a more fulsome review of the regulations governing the planning of the distribution system.

Broadly, we provide the following feedback:

• We support this proposal, as for the ISP to accurately represent future scenarios for CER, it must appropriately identify distribution system constraints that will impact the ability of CER to effectively serve load “in front of the meter.” Today, the ISP assumes this happens without constraint, which the sector knows is incorrect.
• DNSPs have the greatest insight today of the data required for identifying constraints and would receive the most long-term value from understanding changes in CER and load over time. As such, DNSPs are the appropriate entity for determining low-level CER and load projections.
• In the short-term, effective collaboration is needed between AEMO and the DNSPs to gauge the long-term constraints, calculated only at the zone substation level for the next ISP.
• In the future (ideally by 2028), there is value in the ISP using accurate low-voltage CER, load, and constraints forecasts. DNSPs are the most appropriate entity for determining these projections, but we recognise that this would still require oversight by, and collaboration with, AEMO.