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02 February 2023
Department of Climate Change, Energy, the Environment and Water
Response to Australia’s Guarantee of Origin scheme Consultation Paper
Thank you for the opportunity to comment on the Department of Climate Change, Energy, the
Environment and Water’s Australia’s Guarantee of Origin scheme consultation paper (Paper).
Thank you for the opportunity to comment on the Department of Climate Change, Energy, the
Environment and Water’s Renewable Electricity Certification Consultation Paper (Paper).
Quinbrook Infrastructure Partners (www.quinbrook.com) is a private equity business that invests in clean energy in the UK, the US and Australia. Our portfolio companies include:
• a NEM connected baseload renewable energy generator, Cape Byron Power
(www.capebyronpower.com), consisting of two 30 MW biomass fired power stations that
generate both renewable electricity and steam for local sugar milling operations;
• an electricity retailer that prides itself on not gouging customers and who won the 2021 Finder
Award for green energy retailer of the year in Australia, Energy Locals
(www.energylocals.com.au);
• an embedded network business that prides itself on helping customers save costs by taking
control of their energy needs, Energy Trade (www.energytrade.com.au);
• Lockyer Energy Management Pty Ltd (https://lockyerenergy.com.au/) which is developing a
hybrid peaking and utility battery project in Queensland, and
• Supernode (https://supernode.com.au/) which is developing industrial scale data centre sites
across Australia, including the flagship Brendale site (https://www.quinbrook.com/news-
insights/quinbrook-launches-2-5-billion-supernode-data-storage-project-in-brisbane-to-be-
powered-by-renewables-and-battery-storage/).
Our multiples channels of involvement in Australia, across different levels of the industry, allows us to provide balanced “whole of industry” opinion and set of potential refinements to the Guarantee of Origin scheme. Additionally, our portfolio companies in UK and US markets (which include utility wind, solar and batteries, distributed peaking generation and demand response) give us an operating knowledge of the current schemes and proposals for tracing renewable energy certificates. Both UK and US markets are currently experiencing comparable issues to Australia in regard to credibility, transparency, and confidence of emission reduction claims.
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Quinbrook is a supporter of the TCFD and publicly documents1 how we meet the TCFD reporting framework. Quinbrook also engages in policy advocacy to further our decarbonisation objectives, including: Signatory to the UN 24/7 Carbon Free Energy Compact; Signatory to the Principles for
Responsible Investing (and recipient of a 100% PRI score in 20212); Signatory of the Net Zero Asset
Managers Initiative; Member of the EnergyTag Working Group; ; Member of the Energy Web Foundation;
Member of the Long Duration Energy Storage Council.
We have provided feedback on the Department’s policy positions in the table below.
Yours Sincerely,
James Allan
Senior Director
Quinbrook Infrastructure Partners
1 See: https://www.quinbrook.com/wp-content/uploads/2022/04/Governance-Strategy-Risk-Management-and-
Process-Framework.pdf
2 See: https://www.quinbrook.com/wp-content/uploads/2022/09/2021-Assessment-Report-for-Quinbrook-
Infrastructure-Partners.pdf
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RESPONSES TO THE DEPARTMENT’S SPECIFIC POLICY POSITION PROPOSALS
Below we respond to the Department’s specific proposals in the consultation paper. We have only responded on questions where we have a specific comment, not on every question.
Policy position proposals Quinbrook Response
Proposal number
P1. The scheme will be covered under new legislation We support this position.
administered by the CER.
P2. The Product GOs will cover the well-to-user system We support this position.
boundary.
P3. There will be no minimum emissions intensity We support this position.
requirements for Product GOs and participation will be
voluntary for both Product GOs and REGOs.
P4. The GO scheme will be cost recovered in line with We support this position.
Australian Government policy.
P5. The scheme will be reviewed in 2025 and every five We support this position.
years thereafter to ensure it is fit for purpose and able to
support the industry.
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P6. Product GOs and REGOs will be housed on a We support this position.
publicly visible register with general information and the Please see our submission on the Department’s REGO framework. In summary, ability to share specific information with other scheme REGOs should record additional information on a voluntary basis. The participants. Feedback is sought on the information that additional information should include timestamping (ideally via should be publicly visible on REGOs (e.g. time of starttime/endtime to allow for hourly and sub-hourly timestamping) and location generation, grid location, commissioning date, end user, via latitude/longitude co-ordinates). This information should be public.
etc) and the information that should be publicly visible on
Product GOs? (emissions intensity, volume, relevant With regard to Product GOs, we support transparency. Ultimately, participants inputs, etc). need to be able to verify information that allows for scope 1/2/3 carbon
accounting consistent with the TCFD reporting framework and GHG Protocol.
This requires public information on Product GOs that allows the carbon intensity
of the downstream product to be calculated to an auditable standard.
P7. Product GOs will use a provenance approach, while We do not have a final position on a provenance versus tradable approach for
REGOs are able to be traded independently of the Product GOs.
electricity they were created alongside.
We strongly support REGOs being able to be traded independently of the
electricity they were created alongside.
P8. An upfront data reporting model will be implemented We note that upfront data reporting is a practical approach in the beginning to provide a practical reporting process. stage of Product GO. However, it is important to put in place strong audit and
monitoring to ensure that participants update the data as soon as possible when
the details are changed. This is important to protect the credibility of the scheme
and avoid greenwashing claims.
P9. There will be four scheme participant roles with differing responsibilities and permissions.
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P10. The creation process will be implemented which We support the creation period for GOs should not be greater than one year to combines batch data with the upfront profiles to create be aligned with other international standards such as EU’s CertifHy. We certificates. The creation period for GOs can range from recommend making the creation period flexible to accommodate hourly and a single hour to a year. sub-hourly (e.g. 5-minute intervals) to align Product Go with REGO and give
competitive edge to the facilities that can provide granular creation periods.
Feedback is sought on whether the certificate creation period range is suitably practical for businesses.
P11. 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.
P12. REGOs are proposed to be available to be traded We support this position.
or surrendered after being validly created.
P13. The CER will undertake compliance monitoring and We support this position.
will have regulatory powers to address non-compliance.
P14. 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.
P15. Where Product GOs have incorrect information, The proposed method imposes risks on the downstream users of the Product they will be updated to reflect the most up to date GO. We support a similar reconciliation to REGO in which the entity that information. After the ARC process, Product GOs will be reported incorrect information is accountable for creating or surrendering the finalised and not subject to further amendments. time-matched certificates to reconciliate the discrepancy.
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P16. Where REGOs have incorrect information, they will We support the ‘unders’ and ‘overs’ reconciliation process for REGO, provided not be updated and instead will follow an ‘unders’ and that the created certificates for under reporting and the surrendered certificates
‘overs’ reconciliation process to minimise impacts on the for over reporting are time-matched.
renewable electricity certificate market.
P17. The Department proposes the GO scheme We support this position.
methodologies will align where possible with the NGER We would recommend that, wherever possible, the methodologies align with the and the Safeguard mechanism. Energy Tag standard, the TCFD reporting framework and the GHG Protocol.
P18. The CER will be able to establish formal data We support this position.
sharing arrangements with the administrators of these schemes to streamline the creation process.
P19. Material emissions sources that must be measured We support this position.
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.
P20. ACCUs issued from within the system boundary will We support this position.
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.
P21. LGCs and REGOs will be used to demonstrate We support this position.
renewable electricity use. Behind the meter or directly supplied renewable electricity will not require certificate surrender if none were created.
P22. A new RMF will be calculated for use within the GO We support this position.
scheme that is updated frequently and can be accessed by other market-based frameworks.
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P23. RECs used to demonstrate renewable electricity We do not see a rationale for enforcing a 12-month limit on RECs or REGOs.
usage in production of a GO product must have been Instead we would recommend that consumers be given the information to drive issued within the previous 12 months. Additional their consumption preferences. It is likely that consumers will expressed information will be captured on REGOs to allow for different preferences for products: matched with legacy RECs (produced >12 voluntary time matching at a more granular level. months old); matched with annual RECs (produced within 12 months); or,
matched hourly (time-stamped REGOs). GO products should provide
consumers with the ability to differentiate these cases and allow preferences to
be exercised.
We support including granular time and locational attributes to REGO to allow
24/7 matching.
P24. The GO scheme will expand over time by We support this position.
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.
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