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Submission: AEMO Draft 2026 ISP Consultation

February 16, 2026
Johanna Bowyer, Jay Gordon
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12 February 2026

To: Australian Energy Market Operator
Re: Draft 2026 ISP Consultation
 

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input to the Australian Energy Market Operator (AEMO)’s Draft 2026 Integrated System Plan (ISP) consultation.

IEEFA is an independent energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

IEEFA’s key comments on AEMO’s draft ISP are outlined below. Further detail can be found in the following pages.

  • The draft ISP’s household battery assumptions are already materially outdated. IEEFA strongly recommends that AEMO revise its residential battery forecasts for the final core 2026 ISP scenarios.
  • IEEFA recommends that AEMO expand its explanation of flexible coal plant operations.
  • IEEFA recommends that AEMO undertake further analysis of data centre loads and the potential for flexibility.
  • IEEFA recommends that AEMO expand its discussion of gas generation outcomes.
  • AEMO’s demand-side factors statement is a welcome addition but the modelling undertaken relies on limited data – further data and transparency would be of benefit.
  • IEEFA recommends that AEMO consider modelling consumer energy resources (CER) coordinated via better tariff signals.

Please do not hesitate to get in touch with any questions on any part of this submission at [email protected].

Kind regards,

Johanna Bowyer – Lead Analyst, Australian Electricity
Jay Gordon – Energy Finance Analyst, Australian Electricity

Johanna Bowyer

Johanna Bowyer is the Lead Analyst for Australian Electricity at IEEFA. Her research is focused on trends in the National Electricity Market, energy policy and decarbonisation.

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Jay Gordon

Jay Gordon is an Energy Finance Analyst at IEEFA, focusing on the Australian electricity sector. He brings experience in modeling Australia’s energy system transition, including investigating the role of the electricity sector in helping the broader economy transition towards a net-zero future.

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