This led to fears expressed at the CoAG energy ministers meeting last Friday that a reliability gap could emerge at any time across the 10 year forecast period.

So now the ESB is putting together a new options paper that will look at changes, including replacing the 3-year notice (T-3) for triggering the reliability obligation with a 5-year notice (T-5). This is likely to result in increased contracting requirements by retailers with providers of “firm” capacity.

The ESB is also looking at options that may allow AEMO – the market operator – to invoke a T-1 trigger at any time without having to go through the T-3. This will give it the flexibility to respond to any major changes.

Further, the ESB will consult on two additional options: the inclusion of an additional trigger at T-5, and the removal of the T-3 trigger.

As an alternative to the second option (the removal of the T-3 trigger) the ESB is also interested in stakeholder views on a proposed ability for a jurisdiction to trigger the reliability obligation as a transitional arrangement. Consultation on these options will be supported by a policy paper to be released before the close of trade tomorrow.

Further concerns are expressed about the proposed “ability for a jurisdiction (i.e. individual state ministers) to trigger the reliability obligation as a transitional arrangement”, suggesting that individual states could impose the mechanism.

All of which appears to attack the long standing “reliability” standard of 0.002% “unserved” energy, or 99.998% reliability.

just as we’ve put a lid on gold-plating the “poles and wires”, @JoshFrydenberg is doing his damnedest to gold-plate the generation sector — driving up prices. the truth is our generation system is > 99.999% reliable — we simply *don’t* have a reliability problem. #auspol pic.twitter.com/IHi5d9CZnn — simon holmes à court (@simonahac) August 16, 2018

This has led to some major gold plating of the network, but critics say that energy minister Josh Frydenberg has been systematically undermining it for 2 years, ever since the South Australia blackout and that this, in turn, could lead to major gold plating of the generation fleet too.

The new position will be open to submissions for another three weeks, with submissions due by September 12. The overall legislation is now in an exposure period, lasting four weeks, with CoAG then expected to have two weeks to finalise their positions before Victoria goes into caretaker period.

Quite what impact such changes would have is not clear. Under the current arrangements, the ESB has forecast no reliability concerns over the next decade, based around AEMO 10-year forecasts. But it is known that AEMO is concerned about unexpected events, such as the failure of removal of a major generator without notice.