PIAC responded to the Energy Security Board’s (ESB) draft Integrated System Plan (ISP) rules. These draft rules would formally embed the ISP in the regulatory framework and create obligations for network businesses to plan and make investments based on the ISP.
PIAC strongly supports the 2020 ISP and future ISPs including a managed trajectory of accelerated emissions reductions as a factor in its consideration of optimal development paths. PIAC highlights that consumers will be vulnerable to avoidable cost increases if the ISP does not economically optimise growth in renewable generation with firming and balancing sources and demand response.
We stress the goal of the Integrated System Plan (ISP) should be to optimise whole-of-system outcomes and guide market development in the long-term interests of energy users, with respect to the trilemma: price, reliability/security and emissions reduction.
As such, we do not agree with the proposed drafting of NER 5.22.2(b)(1) that a purpose of the ISP is to “trigger the regulatory investment test for transmission process for actionable ISP projects.” We consider this wording unnecessarily output-focussed and process-driven rather than being outcome-focussed.
We provide our views on the timing and inputs of ISP development, dispute resolution relating to elements of the ISP, and implementation of projects.