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Submission to the Draft Guidelines to make the Integrated System Plan actionable

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Energy Consumers Australia

Energy Consumers Australia broadly supports the Guidelines which will provide a clear framework for the Australian Energy Market Operator (AEMO) to undertake its role as the author of the Integrated System Plan (ISP).

Importantly, the Guidelines require transparency and rigour around the way AEMO develops the ISP – including the assumptions and engagement – which will help assure consumers that their interests are being served.

We also support the role for the Australian Energy Regulator (AER) envisaged in the Guidelines which is not to mirror or duplicate AEMO’s role in developing the ISP, but to provide strong and independent oversight.

The Guidelines and the AER have a critical role to play given the priority that must be placed on energy affordability due to the extraordinary pressure households and small businesses are under because of COVID19. The recent history of overinvestment in network assets at a distribution level contributing to higher energy prices must also remain front of mind in the development of the ISP.

In this submission we also make suggestions about improving the Guidelines which are largely focussed on the forecasting, scenario planning and transparency aspects of the package, that go to:

  • clarifying the drafting about how parties representing consumers register to participate in the development of the ISP.
  • clarifying the drafting about the procedures relating to the staging of consultation processes and when reports will be made following meetings and consultation processes;
  • adopting a consistent and transparent naming convention for projects to make it easier for stakeholders to tack their progress through the ISP process and into subsequent construction and operational phases; and
  • requiring that scenario planning work undertaken under the Cost Benefit Analysis Guideline (CBAG) explore a range of plausible futures to ensure the authors of the ISP are thinking expansively about what the future holds for consumers and communities.

The full submission can be read here.

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