Nexa Advisory welcomes the opportunity to provide input on AEMO’s Draft 2026 Integrated System Plan (Draft ISP).
The Draft ISP reinforces that a least‑cost transition relies on a large build of renewable generation, storage, and transmission and distribution investment.
Nexa supports the ISP’s role as the NEM’s principal whole‑of‑system planning framework. However, a recurring challenge across successive ISP cycles is the widening gap between what is planned and what is delivered on time and on budget. A least‑cost plan on paper will not translate into least‑cost outcomes for consumers if delivery falters, sequencing slips or substitute pathways are not developed early.
Additionally, we recognise that it is not AEMO’s role to inform government policy or implement the ISP. However, given the scale of the delivery challenge and its first‑order impact on consumer outcomes, Nexa recommends governments and market bodies progress a National Implementation Plan that complements the ISP and aligns targets with actionable, accountable steps.
Nexa broadly supports the Draft ISP direction of travel, but recommends AEMO should strengthen four areas to improve the credibility and deliverability of the ODP, namely:
- Transmission deliverability and genuine non-network options (NNOs) – including explicit delivery pathways for actionable projects and earlier/stronger integration of credible, market-led alternatives (including “virtual transmission” and other NNOs).
- Coal reliability and end‑of‑life outage modelling – ensuring the ISP’s modelled scenarios reflect increasing unplanned outages of ageing coal assets.
- Distribution and demand-side factors – further progressing the methodological updates already undertaken toward integrated distribution system planning and deeper co‑optimisation of distribution/CER and transmission within the ISP.
- The cost of gas as reliability ‘insurance’ – transparently test non-gas alternatives for rare-event reliability, and more clearly outline the cost of additional gas build required as a result of delays to renewable generation, storage and transmission.
Read our submission here: Nexa Advisory submission – Draft 2026 ISP