16 February 2024

The only way to break this cycle is for AEMO to either include in the ISP’s total system costs the full suite of costs listed above and therefore properly test the full range of options available to policymakers, or else make clear that its role is to only look at transmission, not the whole system, and let the government create or appoint another body to determine whole-of-system costs. [...] The Feedback Loop Notices for HumeLink and VNI west, and the Update Notice to the 2022 ISP should be recalled and proper consultation concluded on the draft, so that the public scrutiny of the Draft ISP can be used and the final 2024 ISP suitably amended before significant costs are passed on to consumers. [...] For example, the NSW Government’s new Transmission Efficiency Test allows transmission projects to proceed without going through the RIT-T,13 instead being subjected by the AER to the much weaker test of whether the operator’s proposed capital costs for development and construction are “prudent, efficient and reasonable”.14 Similarly, the amendment made in 2020 to the National Electricity (Victori. [...] In the words of Engineers Australia, the exclusion of CER in the NPV analysis is a “limitation” which means that “while the NPV costing of Scenarios provided in the ISP is useful for comparing variations in transmission development pathways, it does not convey the total impact on future delivered electricity costs.”49 If the ISP is truly “a plan that’s meant to be for consumers to adapt the power. [...] Percent of EV charging over time by charging types under Step Change in 2023 IASR.104 The Draft 2024 ISP specifically mentions consumers’ ability to reduce peak demand on the grid by charging EVs “outside the morning and evening peaks, preferably through the peak solar daylight” and discharging back to the home or the grid “when needed”,105 with a vague mention of the “right incentives and systems.