Australia’s Guarantee of Origin Scheme: consultation papers

3 February 2023

The Department of Climate Change,
Energy, the Environment and Water
GPO Box 3090,
Canberra ACT 2601, Australia

Email: GuaranteeofOrigin@industry.gov.au

RE: Australia’s Guarantee of Origin Scheme

Equinor ASA welcomes the opportunity to respond to this consultation which addresses Australia’s need for a transparent, consistent, and trusted emissions accounting framework to underpin the creation, use and export of renewable energy and clean products. This document covers Equinor’s response to Australia’s Guarantee of Origin Scheme policy paper.

Executive Summary
Equinor is keenly aware that strong policy is paramount to achieving a thriving green products and green fuel economy. We welcome the adoption of a new system that allows for a transparent, consistent, and trusted framework for Guarantees of Origin certificates (henceforth GOs) in Australia.

Equinor is supportive of the GO scheme’s intentions, and we believe the benefits will be multifaceted.
We support the design provided in the policy paper and that the framework allows for additional products to be added. The desire for the scheme to be aligned with international mechanisms is also prescient. If properly aligned with international mechanisms, we believe a book-and-claim method for suitable products over the provenance approach detailed in this paper could increase voluntary adoption.

The scheme’s success will likely rest on ease of application since participation is voluntary. We believe that it is important to ensure broad adoption from both small and large producers of certificates and to have measures in place to reduce risk of double counting and further harmonization with other markets.
We remain at your disposal for further engagement.

Yours sincerely

___________________________________
Thomas Hansen
Country Representative
Equinor Australia
2

About Equinor
Equinor is an international energy company committed to long-term value creation in a low-carbon future.
We are 21,000 colleagues developing oil, gas, wind, and solar energy in around 30 countries worldwide.
We’re the largest oil and gas operator in Norway, one of the world’s largest offshore operators, and a
growing force in renewables.

Equinor provides more than one million European homes with renewable power from offshore wind farms
in the United Kingdom and Germany. We are the operator of the Sheringham Shoal, Dudgeon and Hywind
Scotland offshore wind farms. Projects currently under development include Empire Wind and Beacon
Wind (US), and Dogger Bank (UK), which will be the world’s largest offshore wind farm. Equinor is also
a partner in solar energy plants in Brazil and Argentina. By 2030, we plan to have grown our installed net
renewables capacity to 12-16 GW. Two-thirds of this capacity will be within offshore wind.

Equinor is committed to long-term value creation in support of the Paris Agreement’s goals. Our ambition
is to become a net-zero energy company by 2050, including emissions from the use of sold products. Our
strategy is to combine carbon-efficient oil and gas production with expansion in renewables and
leadership in new low-carbon technologies and value chains.

To realise our transition strategy, our ambitions towards 2030 include:
• Halving our greenhouse gas emissions, with 90% of the cuts coming from absolute reductions.
• Allocating 50% of our annual gross capital expenditure to renewables and low carbon solutions.
• Reducing our net carbon intensity, including emissions from the use of sold products by 20%,
addressing the systemic challenge of delivering energy that has lower – and eventually net-zero
– emissions to end users.

Equinor in Australia

Equinor is currently pursuing multiple offshore wind opportunities in Australia with strong local partners.
Equinor sees offshore wind as an important part of Australia’s future energy mix to deliver sustainable,
affordable, reliable, and secure electricity and we are encouraged by recent regulation enabling
offshore wind development.

Offshore wind’s ability to be deployed at scale and close to existing infrastructure allows it to be an
important enabler of green products. As in other markets, Equinor believes that offshore wind has
synergies with wider value chain propositions such as green hydrogen and fuels. Equinor is assessing
green fuels globally and in Australia.

Besides offshore wind, Equinor holds interests in energy and technology companies in Australia via our
in-house venture capital fund Equinor Ventures and in 2019, Equinor acquired Danske Commodities
who have a presence in Australia.

2
Response - Australia’s Guarantee of Origin
Policy position proposal 1: The scheme will be covered under new legislation administered by the
CER

Policy position proposal 2: The Product GOs will cover the well-to-user system boundary

Policy position proposal 3: There will be no minimum emissions intensity requirements for Product
GOs and participation will be voluntary for both Product GOs and REGOs.

Policy position proposal 4: The GO scheme will be cost recovered in line with Australian Government policy.
• Equinor Response to Policy Position Proposal 1-4:
Supported. We note that well-to-user system boundary is appropriate and in line with other
methodologies.

Policy position proposal 5: The scheme will be reviewed in 2025 and every five years thereafter to ensure it is fit for purpose and able to support the industry.
• Equinor supports the need to review the scheme to ensure it satisfies its intentions, especially since
the industry is nascent and may change in a variety of ways as regulations and needs change
domestically and internationally. A process of incremental reviews and rule-changes more frequently
than every five years could allow for less policy uncertainty for projects, as the reviews and changes
would be more incremental, and the information flow between policy makers and participants would
be more frequent.

Policy position proposal 6: Product GOs and REGOs will be housed on a publicly visible register with general information and the ability to share specific information with other scheme participants.
Feedback is sought on the information that should be publicly visible on REGOs (e.g., time of generation, grid location, commissioning date, end user, etc) and the information that should be publicly visible on Product GOs? (emissions intensity, volume, relevant inputs, etc).
• Equinor would encourage the Department to ensure public information is in line with other
international schemes as different public disclosure requirements could lead to misalignment
between Australia and other jurisdictions (and therefore create jurisdictional market preferences).

Page 3 of 4
4

Policy position proposal 7: Product GOs will use a provenance approach, while REGOs are able to
be traded independently of the electricity they were created alongside.
• Tying the certificate to the product may leave “money on the table” as the availability of the
certificates is restricted only to those who can access the physical product. Instead of a provenance
approach, applying a book-and-claim method for relevant products in the future would decouple the
certificate from its physical delivery. This would create a marketplace where two customers who
demand the same product but have different sustainability targets and supply chains could trade
certificates without swapping the underlying product. This may result in increased demand for GO
certificates, as it would allow those not able to physically access the lower emissions product to
participate in the GO certificate marketplace.

Policy position proposal 8: An upfront data reporting model will be implemented to provide a practical
reporting process.

Policy position proposal 9: There will be four scheme participant roles with differing responsibilities
and permissions.

Policy position proposal 10: The creation process will be implemented which combines batch data
with the upfront profiles to create certificates. The creation period for GOs can range from a single hour
to a year. Feedback is sought on whether the certificate creation period range is suitably practical for
businesses.
• Equinor Response to Policy Position Proposal 8-10:
Equinor supports the above policy positions.
We note the importance of flexibility in the creation period to service a variety of business models.
We also foresee that ensuring that adequate incentives exist for all four scheme participants will be
important for the scheme’s adoption.

4