Callide Legal Action and Regulatory Challenges

Safety worker in hard hat pointing at electrical transmission towers under a colorful sunset sky, highlighting energy infrastructure.

Callide is facing increased scrutiny as the Australian Energy Regulator (AER) is taking legal proceedings against Callide Power Trading due to an explosion at Callide C. In May 2021, an explosion at Callide C4 led to the tripping of multiple generators and high-voltage lines in Queensland, leaving nearly half a million homes to lose power.

The AER alleges that Callide Power Trading broke the National Electricity Rules (NER) by not adhering to its own performance standards for Callide C4. According to the allegations, the C4 unit lacked a protection system in place or having sufficient energy supply to suddenly disconnect the unit when the explosion occurred.

Justin Oliver, an AER board member stated that “Failure to comply with these standards can risk power system security, see consumers disconnected from power supply and cause wholesale energy prices to increase during and beyond these events”.

Callide C3 is expected to fully return on March 31st, with C4 following on July 31st. These are revised dates following various delays affecting both units.

In a separate incident, the Federal Court ordered IG Power, who owns 50% of Callide to appoint special administrators with powers to complete a new investigator into the incidents at the power station.

There is currently no date set for the AER’s matter to be heard at Federal Court.

This highlights the immense pressure on the energy industry and regulation to suppress spot prices in the NEM. This pressure has come in various forms including market directions, price caps on underlying fuel sources such as coal and gas, and retailer reliability obligation (RRO) being enacted in SA this summer.

This pressure has been evident in the spot price, as the spot price over the summer has been very soft, particularly in South Australia and Victoria, with prices being far below forecasted and previously traded levels.

This has caused issues for generators leading Engie to announce the early closure of two units in SA, removing 138MW of capacity from July 1, brought forward from an initial closure scheduled for 2028. This is due to financial reasons as losses have been mounting at the plants, unable to make a profit in the spot market.

There is currently a T-3 forecasted in South Australia from December 2025 to February 2026. Following the recent RRO witnessed over the summer in South Australia where spot prices have been low, volatility has been minimal, and there have been few system security issues in the state. Will we see any revisions or changes to RRO in the future?

Potential for Below Baseline REGOs

Two silhouetted figures stand on a platform at sea, observing a vast offshore wind farm against a dramatic sunset sky.

LGCs are now in an interesting position. With the REGO scheme all but fully legislated to start in 2025, there may be opportunity to meet voluntary requirements from this secondary market before it becomes the likely primary market at the end of 2030 until 2050.

The REGO scheme looks likely to exist in parallel to the LGC scheme until the expiry of the RET, with generators able to decide which products they would like to produce in any given period.

However, the REGO scheme will open previously un-tapped generation, such as below baseline generation, generation from outside of the Australian economic waters area and exported generation i.e. Sun Cable, which the LGC cannot. Further (although unlikely before 2030), STCs can be pooled to create 1 MWh, i.e. 1 REGO certificate at the point the 1MWh limit is reached.

This market is currently untapped, but with a REGO holding the same credentials as an LGC, the voluntary surrender optionality (RET Liability must still be met with LGCs until 2030) can be achieved through the REGO scheme.

With voluntary surrenders increasing, the CER estimated in 2022 a total of 7.4million LGCs were surrendered voluntarily. This increased the demand for LGCs by 1.6million in comparison to 2021 and created a demand 23% above the legislated requirements for LGCs (33m).

Prior to a REGO scheme, the increasing demand for these LGCs has come from growing corporate targets either directly into the LGC market or through its secondary market, such as GreenPower schemes.

Without increasing the availability of alternative generation sources, this growth could lead to a tightening of the supply-demand balance of the LGC and an increase in price. As such the introduction of a REGO from 2025 could be the pressure release valve the industry requires.

The growing non-RET requirements are significant, and therefore, the introduction of secondary sources of power through the REGO scheme is the only way the market will be able to meet the increasing demand.

The ACCC investigation into Momentum in 2016, where Momentum was handed a $54,000 fine for falsely advertising their green credentials, as they are backed by Hydro Tas whose generation was below baseline, has brought to the fore the requirement for accreditation of these below baseline assets (outside of the i-REC scheme).

Below baseline is renewable generation assets created before 1997 – mainly hydro assets. The baseline is set on production between 1994 – 1996, and therefore, generators coming on from 1997 have a baseline of zero and can produce LGCs, unlike those online prior to 1997. Indications are these facilities generate 12-13TWh of electricity each, that is, 12-13 million REGOs, which could come into the Australian voluntary market (pre-2030 RET end). However, the below baseline generation is eligible for an i-REC certification and many assets pursued this option prior to the REGO /GO scheme announcements. As such, this 12-13 million may be as low as 2 million in the initial years, given existing PPAs and voluntary i-REC surrender deals in place.

It is worth noting, if Hydro Tas had created the REGO and these were surrendered against the Momentum portfolio, the renewable claim would have been upheld, and the REGO would have never hit the market. This example shows that even if produced, companies may utilise the additional certification without giving others the opportunity to trade them in the open market.

A concern does sit around the inclusion of small-scale renewable REGOs, although unlikely to be in large quantities prior to 2030, the concern holds that the measurement of the “hour” the REGO is produced, when the cumulative units have reached 1MWh of generation, is currently untested and there are a significantly larger number of these units than there are utility scale solar. The cost and oversight required could add cost to the certificate, which we currently have no view of as to the uptake or requirements.

End of 2023 Energy and Climate News Wrap

There was lots of news that came out during the Christmas break, so please see our wrap of the end of 2023.

European Grid Resilience: Denmark-UK Link Operational

Further underpinning the resilience of the European grid, the 1,400MW DC link from Denmark to the UK came online on 29th December. However the capacity has been restricted to 800MW in the first instance as the electrification of the grid and hunger for power in the Danish region is not high with strong wind output (54% of the Danish grid) and the link into the power hungry Germany is not yet in place.

NSW’s Energy Manoeuvre: Orderly Exit Mechanism

The NSW minister for Energy and Climate Change, Penny Sharpe, gave herself and anyone in her seat the power other states have in their pocket; at the end of last year, she granted the “Orderly Exit Mechanism” power. Which means that with or without the consent of Origin in negotiations she now has the power to order Eraring to stay on as she backdated the powers to 2021. With the deadline to keep Eraring on or not this could shift the scales of negotiations and may be an indication of the noose Origin held around the NSW government loosing.

Queensland’s Ambitious Climate Target

QLD government strengthened its climate targets with a new target of 75% below to the 2005 baseline by 2035. This is due to be legislated in the new year.

Record Power Demand and Prices in December

Friday, 29th December, was indeed a scorcher, with demand topping over 9,750MW over the evening peak and pricing topping out around the $15,000/MWh price over the evening peak and prices averaging $448.97/MWh for the day. Showing how solar penetration can create huge volatility in prices on high demand days.

Coal Seam Gas Regulation: Draft Framework

The Department of Resources released a paper looking into a risk framework for regulation around Coal Seam Gas subsidence. Feedback has closed but the draft proposed legislation is due early 2024.

Queensland Revives Polluter Pays Legislation

Polluter pays legislation is back in the spotlight, with the Queensland government releasing a consultation paper on “Improving the powers and penalties provisions of the Environmental Protection Act 1994”

ARENA’s Industrial Emission Reduction Initiative

ARENA has launched a $40m fund called the “National Industrial Transformation (NIT) program” assisting existing plant and industrial facilities to reduce their scope 1 and scope 2 emissions.

COP28 More of a Fizz Rather than a Bang

Logo for COP 28 UAE event featuring a circular design with intricate yellow patterns on a green background, symbolizing sustainability and environmental themes, displayed over a dark brick wall texture.

With just 2 days of negotiations left at the COP28 summit, it is clear that world leaders are not entering into the summit with the same sweeping mandated as seen in Paris in 2015. In fact, it is becoming increasingly clearer that the Paris 1.5-degree target is unlikely, never mind strengthening the resolve on these targets.

Despite this year, 2023, already being declared the warmest on record by November, and having six record breaking months and two record breaking seasons, world leaders as squabbling over texts which will have little to no impact on emissions or targets.

With the head of this year’s COP, Sultan Al Jaber, the head of the Abu Dhabi National Oil Company (ADNOC) in the position many thought would create a conflict of interest, he is indeed between a rock and a hard place. With over 80 countries, many at the forefront of climate change pushing for an end to the use of fossil fuels, a topic every previous COP has been careful to avoid, the Sultan is now being lobbied from both sides, with OPEC now pressuring members and the chair to reject any deal which targets fossil fuels directly.

Reuters, who broke the news shared a letter from December 6th sent by OPEC Secretary-General Haitham al-Ghais “It seems that the undue and disproportionate pressure against fossil fuels may reach a tipping point with irreversible consequences, as the draft decision still contains options on fossil fuels phase out … I avail of this opportunity to respectfully urge all esteemed OPEC Member Countries and Non-OPEC Countries participating in the CoC and their distinguished delegations in the COP 28 negotiations to proactively reject any text or formula that targets energy i.e. fossil fuels rather than emissions”.

The Sultan is therefore walking a very fine line, as evident by his calling of the majlis, elders conference, on Sunday. In there, the main focus was two pronged, one the aforementioned fossil fuels phase out or abatement, and the second on financing.

Climate adaptation funds is not a new concept, it was raised pre-the-Paris agreement, and every year since. However, despite UN reports released in November, Adaptation Gap Report 2023, showing 2021 funding fell 15% year on year to a cumulative $24.6bn, but more than $200 – 350bn is needed, and 2023 is likely to only be around the $100bn mark. The idea of now increasing the burden on fossil fuels emissions to be phased out and not abated will leave many countries, especially in the African continent behind. As emerging and expensive technologies, which will allow other countries to continue producing, will not be available to them.

I once again argue, with politicians and special interests lobbying, the value of the COP is diminishing. Energy policy should not be in the hands of those who are worrying about re-election in 1, 2 or 4 years but those who understand the science, industries and financing of the projects required to make the change. We cannot just turn off coal, the Eraring “closure” has shown us that in bright bold lights (or blackouts), so there has to be balance. But that cannot be done by those who are not in that world or influenced by only one side of an argument.

However, with Azerbaijan the COP29 hosts, a country with at least 7bn barrels of commercial oil, and 1.3 trillion cubic meters of natural gas and one of the world’s largest gas fields I am sure will fly the flag for phase out of fossil fuels and strong targets for all nations attending.

With Statements due in the next 48 hours, I may be proven incorrect, and the Sultan is absolutely making the right noises, “I want everyone to come prepared with solutions … I want everyone to come ready to be flexible and to accept compromise. I told everyone not to come with any prepared statements, and no prescribed positions. I really want everyone to rise above self-interests and to start thinking of the common good.” But as always, the proof is in the packages which come out of the talks and with only two days to go and no consensus the clock is absolutely counting down.

Domestic Demand Management: Lessons to be Learned?

Smart energy monitor displaying real-time electricity usage in kilowatts and cost per hour in pounds on a desk with a coffee cup, smartphone, and money.

As the artic blast moves down throughout northern Europe and negative overnight temperatures are expected throughout the UK, including London. The UK’s National Grid, our AEMO, has activated the Energy Blackout scheme.

This was introduced in 2022 during the height of the Russia / Ukraine conflict and the idea was to allow demand side response from domestic participants who have smart meters installed in their properties. Once you have signed up, and 1.6 million households were in the first wave of signups, you receive a notification that states a date and time for the event which will be under the scheme – currently this tends to be around the peak of 17:00 – 18:30 on evenings. Participation provides a buffer for the grid in terms of capacity.

This doesn’t mean those household have to return to the dark ages with candles, you can keep lighting on, but you are encouraged to reduce high demand intensive loads such as washing machines which use high quantities of energy.

In the northern winter 2022 / 2023 period the scheme was so successful it was estimated by the Centre for Net Zero and the National Grid that 3.3GWh of power and 681 tonnes of CO2 were avoided over the 22 activations. Your retailer assesses your average use and the use over the “blackout period” and you are rewarded with a reduction in your bills for the energy not consumed.

Payments totalled £11m, or $21mAUD with one SME business saving $1,726 or $3,298AUD in one event and the average household will save around £100, $191AUD in total.

So, can the Australian grid benefit from these types of events? The answer is an an-doubtable yes, however with reports stating that outside of Victoria uptake of smart meters is at the 30-35% level, which is significantly below the AEMCs target for 100% upgrade by 2030 and a compulsory roll out to begin in 2025 being pushed at the moment, the likely introduction of these schemes is significantly behind those of the UK.

However, with increasing UFE charges, increasing home regulation systems, solar and batteries, and smart appliances the change could come from within consumers rather than via regulation. This would present challenges for retailers though, the traditional view of peak, off-peak and shoulder would need to have a dynamic element to allow these homes and businesses to take advantage of their flexibility and Time Of Use tariffs will need significant refinement.

From a regulatory point of view, ensuring customer protections over those periods are kept, that the metering is fair and that they are fully aware of their responsibilities will no doubt cause some further concerns and delays, yet with numbers like 3.3GWh, $21mAUD and customer engagement on the table this can’t be an idea only for long.

AEMO’s Summer Readiness Briefing

Close-up of a document with the term 'El Niño' highlighted in pink.

On Monday the 13th, AEMO held their annual Summer Readiness briefing. The purpose of this report is to highlight risks and address how they will be combatted in the upcoming summer. The report highlights the well-known risks of El Niño, such as extreme peak demand due to heat (potential for POE10), and the potential for reduced wind generation. In addition to the following covered within the briefing:

  • Weather & Climate outlook
  • Electricity & Gas System Readiness
  • Network Readiness
  • Victorian Bushfire Readiness

The briefing also noted that scheduled generation availability is up across all states compared to last summer, it also points out the risk that several generators are on longer-term outages in the November–December period. Specifically, in coal generation, the following outages were highlighted:

  • QLD: Callide B1/B2, C3/C4, Gladstone 1/2, and Tarong 4
  • NSW: Bayswater 1, Eraring 2
  • VIC: Loy Yang A2, Newport, Yallourn 2

The report highlighted the effects of the positive El Niño, combined with a positive Indian Ocean Dipole (IOD) which would amplify the effects of the El Niño. The El Niño is currently expected to persist into Autumn with the positive IOD forecasted to last into at least early summer.

Additionally, there is also a number of planned high-impact network outages scheduled for the summer. However, AEMO highlights that these outages are only allowed to proceed if they do not pose any system security issues.

TransGrid presented a Bushfire Risk Management Plan which outlined the proactively management and mitigation of our exposure to bushfires. This includes risk of bushfires affecting transmission lines. Proactive management and mitigation involved vegetation management and identifying any high priority defects prior to the start of the season. Ultimately, TransGrid’s assessment indicated strong organisational preparedness for the 2023/24 bushfire season.

The report also notes needed increases in Reliability Emergency Reserve Trader (RERT) participants, specifically to the reliability gap outlined in the latest ESOO (118MW and 120MW in SA and Vic respectively).

Transmission Requires Community Engagement Realisation

Back view of two children and an adult walking towards wind turbines, the adult holding a colourful pinwheel up in the air

With the government ploughing ahead with the re-wiring the nation rhetoric and discussions about $10,000/km costs for land the attention of the AEMC and others have naturally been drawn to the requirement for community engagement.

Many panels and speakers at this years’ All Energy conference in Victoria honed in on the requirements for the local communities to be brought into the fold regarding Renewable Energy Zones, Transmission and the benefit this could bring to those communities.

The AEMC have taken this a step further and on Thursday released the final requirements which are required for any transmission projects to get through the regulatory investment test (RIT-T). They are expecting for this engagement to be across all affected parties from councils to local landowners and will ensure they not only have clear information about the proposals but they are aware of the rights they hold.

Taking directly from the AEMC announcement the main changes being made include:

  • Stakeholders are to receive information that is clear, accessible, accurate, relevant and timely and explains the rationale for the proposed project.
  • Engagement consultation materials, methods of communication and participatory processes must be tailored to the needs of different stakeholders.
  • The stakeholders’ role in the engagement process must be clearly explained to them, including how their input will be taken into account.
  • Stakeholders are provided with a range of opportunities to be regularly involved throughout the planning of ‘actionable’ or ‘future’ Integrated System Plan (ISP) projects and Renewable Energy Zones (REZs).

This is timely given the announcement from Chris Bowen who was speaking at the Future Energy conference in Adelaide this week who amongst his optimistic speech stated that “a properly constructed renewable grid is a reliable grid… is one that we can count on in difficult times,” and that access to transmission or delays in building new infrastructure would be the main contributor to Australia not meeting its targets.

These targets are now set to 82% of Australia’s energy coming from renewable sources by the end of the decade, and GHG emissions cut by 45% (in comparison to 2005 levels) by the same time.

However, with the focus of the government squaring in on transmission as the key messaging to Australia missing its targets and not the lack of cohesive renewable energy strategy for the past 10 years or the governments approvals of new gas fields, you do wonder if that is part of the reason our Minister for Climate Change and Energy is ducking the hard questions at this years COP28 in Dubai which starts at the end of the month.

The announcement that he is dispatching his Assistant Minister, Jenny McAllister has not gone unnoticed, especially by the pacific islands our Prime Minister is trying to woo this week. With those nations key to Australia being announced as the COP31 hosts, Turkey is stating they would also be interested, they intend to firmly hold Australia to its climate promises and pointing the finger will not wash with their nations at the forefront of recent climate disasters.

 

Australia’s Safeguard Reforms: New Amendments and the Path Forward for Emission Regulations

Interlocking metal gears with words such as 'RULES', 'REGULATIONS', 'COMPLIANCE', 'STANDARDS', and 'POLICIES'

On Friday the Department of Climate Change, Energy the Environment and Water released the amendment to the Safeguard rule which was largely expected, but still another blow to large emitters. This came into force as of the 7th October 2023 which was the day after it was registered.  

In the latest update to the regulation default emission intensity numbers have been updated and new production variables established. This will be another blow to those Safeguard entities who will now be set to international best practice standards for the default emission intensities.  

Further to the above and also on Friday, the Climate Active certification process had a paper released, following its roundtable and workshop earlier this year. In this consultation paper they are looking to strengthen the certification process which has slipped against industry standards since its inception in 2010.  

One key concept the reforms are looking to address is that currently there is no mandatory gross emission reductions (i.e. reduction of emissions prior to offsetting) required under the legislation.  

The proposals are looking to enforce that “meaningful direct emissions reductions” are undertaken and strategised before offsetting occurs. It would also look to ensure they are tracking their performance against meaningful targets to assist them in this. This requirement will form part of the audit and will be required for them to meet and maintain their Climate Active certification.  

Interestingly they are including all scopes (1, 2, and 3) within their boundary and emission reductions although the “boundary” for this will surely be amended to allow for those outside of their direct control, especially for those within the Scope 3 targets.  

The second part of the consultation paper is looking to tighten the availability of international credits as per the Chubb review paper in late 2022. The proposal will be met by the green lobby as a half measure I am sure as they are stating that vintage requirements on international certification is put in as 5-Years which is loose to say the least. But let’s see if that has any impact at all on price or requirements before we make that call.  

The other interesting proposal is that any ACCUs used as a voluntary requirement will count towards Australia’s national emissions reduction target under the Paris Agreement. It does make you wonder how we will meet these targets at all if this is a scramble for a few voluntary certificates.  

What will be a real key item to watch is if this could this be the first step towards vintage limits on all Carbon Credits, and if so, what will that do to an already tightening supply market. With Safeguard reforms coming in and baselines declining the market is anticipating strength and vintage limits may be the catalyst to the government $75/tonne cap.  

Consultations close on this paper on the 15th December with implementation of changes from 2024 expected.  

AER’s State of the Energy Market in 2023

The AER released their annual ‘State of the Energy Market’ report last Thursday for 2023 for Australia’s electricity and gas markets. This included some relatively good news as the energy system in 2023 has “experienced fewer shocks and better outcomes than in 2022”. The 2023 wholesale electricity market prices have declined from the record prices in 2022, largely due to the government interventions in the coal and gas markets. Despite the decline, prices remain high by historical standards.

A media release by the AER accompanying the report stated, “Increases in wholesale energy prices were evident in retail prices, with estimated electricity bills rising between 9% and 20% in all NEM jurisdictions in 2022-23, impacting households already experiencing broader cost-of-living pressures. “

The report highlighted the pressures for investment in renewables to permit the retirement of coal generation. The report also commented on Liddell’s retirement in April 2023 going smoothly due to the new renewable generation and recent favourable market conditions.

The transition to new energy infrastructure faces several challenges:

  • The vast scale and required coordination of investments.
  • Rising costs in the infrastructure sector.
  • The need for community engagement in infrastructure planning and development.

The report highlighted the government involvement and support in investments including joint initiatives between Australia Government and state and territory governments.

The dynamic between electricity and gas markets is increasingly interconnected. As regions shift from gas demand to electricity demand (like replacing gas heating with electric air conditioning), it’s anticipated that pressure on gas markets will decrease, while electricity demand will surge. Factors like electric vehicle adoption will further influence electricity demand and the necessity for new infrastructure.

Furthermore, planning will now also factor in emissions reduction to serve the long-term interests of energy consumers, integrating it with other goals such as price, reliability, and supply security.

An interesting comment was made in the report executive summary highlighting concerns in the industry surrounding issues of competition in the market and market power outlined below.

“Our concerns are around the reduced liquidity of exchange-traded hedging products, the declining number of clearing service providers for electricity derivatives, and the levels of concentration of ownership of flexible generation capacity, particularly in NSW and Victoria. The AER’s anticipated new powers in relation to contract market monitoring will allow us to better monitor participant behaviour and gain sharper insights on issues of competition and market power.”

Powering Up: How Australia Is Revolutionising Its Electricity Grid

The launch of the Very Fast FCAS markets on 9 October 2023, 1300 (market time) will add two new FCAS markets, “very fast” Raise Contingency FCAS, and “very fast” Lower Contingency FCAS. These markets will enable frequency control by providing full active power response within 2 seconds, as opposed to the existing 6 seconds with the “fast” services. With the ability to respond to changes in power supply and demand within a second, these markets will provide a much-needed boost to the resilience of the National Electricity Market (NEM). As we move towards a future increasingly powered by renewable energy sources, the importance of maintaining a stable and secure power supply becomes even greater.

However, not everyone is convinced that the introduction of Very Fast FCAS markets is a positive development. Some critics argue that the increased competition created by these markets could drive down prices, potentially leading to lower revenues for generators and less investment in new capacity. There are also fears that the faster response times required by Very Fast FCAS markets may introduce technical challenges and increase the risk of errors or failures in the system. Furthermore, some stakeholders worry that the introduction of Very Fast FCAS markets represents a case of “scope creep,” where changes to the Market Ancillary Services System (MASS) exceed the original intent of the review and encroach on other areas of the NEM.

Despite these concerns, many see the benefits of Very Fast FCAS markets outweighing the drawbacks. By preparing for these changes now, businesses can take advantage of the opportunities presented by a more responsive and agile power grid.

In addition, the Department of Climate Change, Energy, the Environment, and Water is currently seeking feedback on its proposed Renewable Electricity Guarantee of Origin (REGO) scheme, which was originally proposed in Q4 2022, and aims to provide a stable framework for investors in the renewable energy sector.

The REGO scheme builds upon the existing Large-scale Generation Certificate (LGC) model but includes several key improvements. Firstly, it allows for greater transparency in reporting Scope 2 electricity emissions, making it easier for companies to demonstrate their commitment to sustainability. Secondly, it provides a long-term vision for the integration of offshore energy generation, improved electricity storage solutions, and distributed energy resources. Finally, it enables policymakers to adapt to changing market conditions and implement new policies as needed.

Another important development in the NEM is the Australian Energy Market Commission’s (AEMC) draft report on the Retailer Reliability Obligation (RRO). The RRO was introduced in 2019 to address concerns about the reliability of the power grid as the NEM transitions away from traditional fossil fuel-based generation towards cleaner, more intermittent sources of energy. Under the RRO, retailers must hold sufficient supplies of reliable generation and demand management resources, such as battery storage, pumped hydro storage, and demand response mechanisms, to meet customer demand during periods of peak usage.

While the RRO has been successful in encouraging retailers to invest in reliable resources, certain issues remain that need to be addressed. For instance, the current triggers for the RRO can create perverse incentives for retailers to over-invest in expensive peaking generators rather than cheaper, more efficient alternatives. Additionally, there are concerns that the RRO does not adequately account for the variability of renewable energy sources, leading to unnecessary expenditure on backup generation.

To address these problems, the AEMC’s draft report proposes several changes to the RRO. One suggestion is to replace the existing T-1 trigger, which is based solely on forecast demand, with a hybrid trigger that takes into consideration both forecast demand and actual supply. This change should help prevent situations where retailers are incentivised to overspend on backup generation due to overly conservative demand forecasts. Other recommended adjustments include allowing retailers to use non-generation sources of supply, such as demand response, to meet their obligations, and introducing an explicit mechanism for determining the reliability standard. Feedback on the draft is due by 2 November 2023, with the final report expected to be released in February 2024.

Overall, the launch of the Very Fast FCAS markets, the development of the REGO scheme, and the proposed modifications to the RRO form part of a broader effort to create a more reliable, resilient, and sustainable power grid for all Australians. While there may be disagreement around the specifics of each proposal, few dispute the urgent need for reform if we are to achieve our climate goals while keeping the lights on and the economy humming.