We thank the Australian Energy Market Operator (AEMO) for the opportunity to comment on the Draft 2023 Inputs, Assumptions and Scenarios Report (the IASR). The IASR includes key information and context for the inputs and assumptions used in AEMO’s Forecasting and Planning publications for the National Electricity Market.
We have three overarching concerns and some follow-on comments.
1. Ambition of scenarios with relation to climate change
Of the four scenarios developed by AEMO in the Draft IASR, only the first is compatible with limiting global warming to 1.5°C compared to pre-industrial levels – a commitment that Australia has made as a party to the Paris Agreement. Given that every fraction of a degree of avoided warming matters, and will be measured in lives, species and ecosystems saved, RE-Alliance considers that all the scenarios should be aligned with 1.5°C warming as a maximum, and that the scenarios can then model several alternative ways of transforming our energy sector and limiting our emissions to these levels.
2. Unclear rationale for decision-making around policy settings
RE-Alliance agrees with other organisations in the climate movement that the IASR has not provided a strong rationale for excluding a number of legislated and/or funded state policies in its base-case policy assumptions. All scenarios seem to be predicated on the current national 43% emissions reduction target. Given the IASR’s stated goal of “covering the breadth of potential and plausible futures impacting the energy sector,” at least some of these scenarios should be testing a higher target.
3. Social Licence Actions in the Draft IASR
The IASR seems to propose new Renewable Energy Zones (REZs), and it's not clear what level of consultation has occurred on these new REZs with State Governments and local communities. We recommend that consultation with State and local Governments and affected communities occurs before the identification of new REZs. RE-Alliance also notes that strategic land use mapping is not mentioned in the section considering social licence.