Business Council for Sustainable Development Australia

Published name

Business Council for Sustainable Development Australia

Policy position proposal 1: The scheme will be covered under new legislation administered by the CER. This proposal relates to pages 13-14 of the GO paper.

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

Policy position proposal 4: The GO scheme will be cost recovered in line with Australian Government policy. This proposal relates to page 15 of the GO paper.

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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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.

Response breakdown
100%
Broadly agree
Do you agree with the proposed position:
Broadly agree

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