On 9 October 2025, the Australian Energy Market Commission (AEMC) published a consultation paper on a rule change request from The Centre for Independent Studies. The Centre for Independent Studies has proposed changes to the way jurisdictional policies are incorporated into the Integrated System Plan (ISP), the categories of costs considered in the analysis, and the information published regarding costs.

Submissions are due on 6 November 2025.  

We are initiating this rule change in parallel with a broader review of the ISP framework. We are required to review the ISP framework by 1 July 2027 under clause 11.126.10 of the NER.

The Commission considers that this approach will enable us to consider issues holistically and to identify and explore the relationships between issues. We published a Terms of Reference for the ISP review on 9 October 2025.

Background

The Centre for Independent Studies submitted a rule change request on 31 October 2024 to amend the National Electricity Rules. The issues raised by the proponent are:

• Treatment of jurisdictional policies: The proponent suggests the ISP does not adequately account for uncertainty as to when emissions reduction and renewable energy targets will be met or whether they may change in the future.  
• Whole of system costs: The proponent considers that the ISP analysis should include a broader range of costs in determining 'whole of system' costs and identifying the optimal development path.  
• Publication of information: The proponent is seeking additional information to be published as part of the ISP relating to system costs and the cost implications of individual jurisdictional policies.