Energy Consumers Australia (ECA) broadly supports the draft determination on improving consideration of demand-side factors in the Integrated System Plan (ISP). While it is a move in the right direction, we think that it does not go far enough to improve the ISP as a whole-of-system analysis.

The draft determination will not result in a more comprehensive analysis of the trade-offs between investment at the distribution and the transmission level (e.g., through co-optimisation), and it therefore won’t completely represent the most comprehensive planning outcome.

The draft determination states that the Australian Energy Market Operator (AEMO) may undertake a more comprehensive analysis in the future when data collection and modelling capabilities allow.

More should be done in the near future to enable the ISP and Distribution Network Service Providers (DNSPs) to undertake more comprehensive data collection, analysis and planning in the longer term, such as requiring AEMO to develop a prospective roadmap for how it will achieve the data collection and modelling capabilities required.

Read our full submission for the recommendations and further detail.