Despite stretching out between now and late 2009, Penny Wong’s timeline for “the most significant economic and structural reform undertaken in Australia since the trade liberalisation of the 1980s” won’t be easy.

Forget about all the emphasis on consultation. The Government will make sure that key industry stakeholders are closely involved in all stages of the development of the scheme – it can’t afford not to. But the formal consultation process is window dressing designed to combat future scare campaigns by the Coalition about the impact of emissions trading.

There are two pressure points in Wong’s timeline, both of which have potential to delay the introduction of an emissions trading scheme in 2010.

The commitment to release the legislation establishing the scheme for industry comment in December is broadly consistent with Wong’s previous commitment that it would be unveiled before the end of the year.

But even a minor delay could see that slip into 2009. The draft legislation will presumably go to Cabinet in November. If ministers baulk at the political implications of the approach proposed by Wong, there may need to be some urgent reworking. The bureaucrats will have fallback options ready to go, but politicians have a remarkable capacity to impose stupid and unworkable demands on efficient regulatory frameworks for political advantage.

Even so, the timetable leaves some wiggle room over next summer to ensure the Bill goes back to Cabinet in February 2009 and is ready for introduction in the Autumn 2009 session, with passage – presumably following the inevitable Senate inquiry – during the Winter session.

Problem is, that only leaves 5-6 months for the emissions trading regulator to be established. This may seem an eternity, but establishing a new agency from scratch is not simple. If the labor market remains as tight as it currently is, recruiting staff for the new regulator will be very difficult, especially given the financial and legal skills that will be required.

And finding the right executives to lead it will also prove tough, although head-hunting firms can be engaged in advance to start looking for the right people. But the Government may find that, as the deadlines for commencement of emissions trading approaches, it hasn’t got the people in place to oversee it.

Perhaps that’s why Wong’s timetable is noticeably unclear on just when in 2010 the trading scheme will begin. Put your money on 1 July, not 1 January.