Published name
Policy position proposal 2: The Product GOs will cover the well-to-user system boundary. This proposal relates to pages 14-15 of the GO paper.
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. This proposal relates to page 15 of the GO paper.
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. This proposal relates to page 16 of the GO paper.
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. This proposal relates to page 17 of the GO paper.
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. This proposal relates to pages 17-18 of the GO paper.
Policy position proposal 8: An upfront data reporting model will be implemented to provide a practical reporting process. This proposal relates to pages 19-20 of the GO paper.
Policy position proposal 9: There will be four scheme participant roles with differing responsibilities and permissions. This proposal relates to pages 20-21 of the GO paper.
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. This proposal relates to page 21 of the GO paper.
Policy position proposal 11: Product GOs are proposed to require creation and transport and storage information to be complete. Product GOs can then be surrendered and report consumption information. This proposal relates to page 22 of the GO paper.
Policy position proposal 12: REGOs are proposed to be available to be traded or surrendered after being validly created. This proposal relates to page 22 of the GO paper.
Policy position proposal 13: The CER will undertake compliance monitoring and will have regulatory powers to address non-compliance. This proposal relates to page 22 of the GO paper.
Policy position proposal 14: LSTRs will provide third-party assurance of the information reported under the GO scheme. The need for LSTRs will be front-loaded requiring less as time goes on and participants demonstrate compliance with the requirements of the scheme. This proposal relates to pages 23-24 of the GO paper.
Policy position proposal 15: Where Product GOs have incorrect information, they will be updated to reflect the most up to date information. After the ARC process, Product GOs will be finalised and not subject to further amendments. This proposal relates to page 25 of the GO paper.
Policy position proposal 16: Where REGOs have incorrect information, they will not be updated and instead will follow an ‘unders’ and ‘overs’ reconciliation process to minimise impacts on the renewable electricity certificate market. This proposal relates to page 26 of the GO paper.
Policy position proposal 17: The Department proposes the GO scheme methodologies will align where possible with the NGER and the Safeguard mechanism. This proposal relates to page 28 of the GO paper.
Policy position proposal 18: The CER will be able to establish formal data sharing arrangements with the administrators of these schemes to streamline the creation process. This proposal relates to page 28 of the GO paper.
Policy position proposal 19: Material emissions sources that must be measured for each product and production pathway will be specified in the methodologies. The sources will be selected based on materiality threshold of 2.5% of total emissions per source. This proposal relates to page 33 of the GO paper.
Policy position proposal 20: ACCUs issued from within the system boundary will need to be surrendered for the emissions reductions to be recognised under the GO scheme. ACCUs or other carbon offsets cannot be used to reduce the emissions intensity of products listed on GO certificates. This proposal relates to pages 34-35 of the GO paper.
Policy position proposal 21: LGCs and REGOs will be used to demonstrate renewable electricity use. Behind the meter or directly supplied renewable electricity will not require certificate surrender if none were created. This proposal relates to pages 35-36 of the GO paper.
Policy position proposal 22: A new RMF will be calculated for use within the GO scheme that is updated frequently and can be accessed by other market-based frameworks. This proposal relates to pages 36-37 of the GO paper.
Policy position proposal 23: RECs used to demonstrate renewable electricity usage in production of a GO product must have been issued within the previous 12 months. Additional information will be captured on REGOs to allow for voluntary time matching at a more granular level. This proposal relates to pages 37-38 of the GO paper.
Policy position proposal 24: The GO scheme will expand over time by incorporating new product-specific methodologies. A prioritisation, development and review process with industry input and international engagement will be established to ensure domestic applicability, international alignment, and continued suitability of legislation. This proposal relates to pages 38-39 of the GO paper.
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ORICA AUSTRALIA’S GUARANTEE OF ORIGIN SCHEME & RENEWABLE
ELECTRICITY CERTIFICATION 1
AUSTRALIA’S GUARANTEE
OF ORIGIN SCHEME &
RENEWABLE ELECTRICITY
CERTIFICATION
ORICA SUBMISSION – FOR PUBLIC RELEASE
3 FEBRUARY 2023
Public
General
ORICA AUSTRALIA’S GUARANTEE OF ORIGIN SCHEME & RENEWABLE
ELECTRICITY CERTIFICATION 2
INTRODUCTION
Orica, headquartered in Australia and ASX100 listed, is one of the world’s leading mining and infrastructure solutions providers, operating in 100 markets. From the production and supply of explosives, blasting systems, mining chemicals and geotechnical monitoring, to our cutting-edge digital solutions and comprehensive range of services, we sustainably mobilise the earth’s resources.
Orica supports the Federal Government’s legislated 43% emissions reduction target and suite of
Powering Australia policies, including Safeguard Mechanism reforms presently underway. Orica is committed to achieving net zero emissions by 2050, with an interim operational emissions reduction target of at least 40% by 2030 based on 2019 levels.
At the end of the 2022 reporting period, global Scope 1 and 2 net emissions were 14% below our 2019 baseline. In 2022, Orica set a renewable electricity target committing to sourcing 100% renewable electricity by 2040, with an interim step of 60% by 2030.
ORICA AND ENVIRONMENTAL MARKETS
Orica led the chemical industry in Australia in setting voluntary corporate emissions reduction targets; to reduce operational Scope 1 and Scope 2 emissions by at least 40% compared to 2019 levels. At the end of FY2022 our Scope 1 and 2 net emissions totalled 1,883 ktCO2-e, which represents a 14% reduction compared to 2019 levels. In 2022, Orica also set a target to source 100% renewable electricity by 2040 with an interim step of 60% by 2030.
Orica has secured future renewable electricity supply in New South Wales through a power purchase agreement. We are also investing in capital-intensive abatement projects. This includes deploying tertiary catalyst abatement technology to Australia for the first time at our Newcastle nitric acid plants on Kooragang Island. Both of Orica’s Australian continuous manufacturing facilities (Kooragang Island,
Yarwun) have registered projects under the Emissions Reduction Fund (ERF), which gives Orica the ability to generate Australian Carbon Credit Units (ACCUs).
Efforts to accelerate Orica’s decarbonisation have relied on environmental markets and the financial and product development incentives they provide. This is leading to new opportunities to develop renewable energy and lower carbon products to meet growing customer interest. Together with growing regulatory focus on environmental claims, these conditions present a need for transparent, consistent, and trusted emissions accounting approaches to underpin renewable energy and lower carbon products.
GUARANTEE OF ORIGIN SCHEME & RENEWABLE ELECTRICITY CERTIFICATION
Orica understands that a key driver for the creation of a Guarantee of Origin scheme (GO scheme) is to offer information to verify claims made in relation to low carbon or green products. Orica strongly supports this primary objective and welcomes the opportunity to submit feedback on the scheme.
Public
General
ORICA AUSTRALIA’S GUARANTEE OF ORIGIN SCHEME 3
In this submission we have focussed at a high-level on the areas of principle interest rather than detailed responses to each proposed policy position.
In summary, Orica supports:
• The primary objectives of the proposed GO scheme and continued Renewable Electricity
Certification, voluntary participation in the GO scheme, and encourages policy design with a strong
focus on design principles of traceability and transparency.
• A GO scheme designed to align internationally and integrate with existing and emerging domestic
frameworks (e.g. NGER, Safeguard Mechanism, Renewable Energy Certificates, others). This
approach avoids legislative duplication, reduces administrative and reporting burden, and delivers
efficient policy outcomes.
• The creation of Renewable Electricity GOs (associated with tracking renewable electricity
generation) to give industry certainty for the market transition from existing tradable Renewable
Energy Certificates. Orica welcomes this development as it gives investment and reputational
confidence that renewable electricity claims can be made post-2030 to meet our corporate target.
• The proposal for Product GOs to initially cover hydrogen and hydrogen energy carriers (in Orica’s
case ammonia) is strongly supported. As the green hydrogen and ammonia industry emerges, we
are observing commercial arrangements are already exploring product traceability considerations
and the role of Product GOs.
• The proposed policy position pertaining to treatment of Australian Carbon Credit Units (ACCUs).
Where ACCUs are originated by a facility we support the requirement that surrender of those units
is necessary to lower product emissions intensity. This avoids double-counting and prioritises efforts
to reduce the emissions from production processes. Companies should not secure “greener”
certifications through the purchase and use of offsets under the Product GO scheme. There are
existing schemes (e.g. Climate Active) that facilitate other types of environmental claims from
carbon offsets such as carbon neutral products.
Industry trials for Australia’s GO Scheme are underway and Orica is pleased to be participating in phase
2 – hydrogen carriers. The results of the trials, along with future work by the government, will be important for the final design of the GO Scheme.
Questions about this submission, can in the first instance be directed to Mel Cheesman, Head of Government and Regulation via email – mel.cheesman@orica.com.
Your Sincerely,
Paul Evans – Global Vice President, Corporate Affairs
Public
General