**Published name**
Do you agree with the way the production boundary is defined?
Please provide additional information if you disagree with the definition
Do you agree with the way the production boundary is defined?
Response: In the short term, yes; in the longer term, no.
There are strong arguments for simplicity and transparency in the early stages. It is crucial to recognize that the production boundary might necessitate periodic updates, aligning with the evolution of the hydrogen supply industry. These adjustments would aim to more accurately mirror the inherent emission intensity of the particular production process.
The prospect of locally manufacturing system components, potentially yielding lower embodied emissions compared to Asian manufacturing, warrants exploration. This exploration should include a thorough evaluation of supply chain provenance, providing insights into the environmental footprint and facilitating informed decisions on supporting local production initiatives.
Do you agree with the post-production boundary definition?
Please provide additional information if you disagree with the definition
Do you agree with the post-production boundary definition?
Response: In the short term, yes; in the longer term, possibly.
As highlighted earlier, the current post-production boundary adopted serves as a good initial benchmark. While substantial alterations may not be immediately necessary, the dynamic nature of hydrogen production and supply chains will require ongoing monitoring.
What (if any) additional emissions estimation approaches should be considered?
The emissions accounting framework within the GO system strives to strike a balance among competing considerations. Currently, the emphasis is on simplicity and transparency rather than precision and accuracy. This strategic choice aligns with the early stages of development, mirroring similar pragmatic compromises seen in other hydrogen certification initiatives.
Given the nascent state of the hydrogen industry and the uneven availability of robust data, the existing structure of the GO scheme seems appropriate. The scheme’s boundaries, confined to ‘well-to-delivery gate,’ are sensible in light of the industry’s nascent phase. While there are initial explorations into incorporating upstream Scope 3 emissions, as exemplified by Yara’s Green Ammonia plant pre-certification, which considered the impact of certain chemicals [1] , the broader inclusion of such emissions is still in its early stages.
Despite these efforts, the accompanying submission highlights a potential shortfall in the GO emissions accounting framework, suggesting a likelihood of understating life cycle emissions. It is critical to gauge the significance of this underestimation, particularly concerning its potential impact on broader decarbonization initiatives. For example, an oversight of this nature could inadvertently inflate the perceived benefits of hydrogen-enabled end-uses compared to the direct utilisation of electricity.
Another important consideration revolves around the substantial uncertainty regarding fugitive emissions and emission capture rates associated with blue hydrogen production. Consequently, it is imperative that there is a robust system for monitoring, accounting, and reporting emissions. Establishing a comprehensive and accurate framework for tracking these emissions is essential to ensuring the integrity and credibility of the GO scheme.
[1] https://www.pv-magazine-australia.com/2022/10/31/world-first-certification-of-green-ammonia-plant-in-australia/
See also Jinko Solar’s recent announcement of certification for its solar wafer production plant, which evaluated emissions categorised as Scope 3.
https://www.nasdaq.com/press-release/jinkosolars-wafer-factory-in-sichuan-leshan-is-first-wafer-factory-to-receive-zero
Are the approaches to allocating emissions to co-products appropriate?
Yes
How practical will it be to report the quantities of each input and output for every creation claim?
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Should some inputs or outputs be estimated in the reporting profile up front to reduce reporting burden, and if so, which?
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What additions or amendments should be made to the proposed measurement guidance, default emissions factors and upstream emissions factor sources?
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What additional data sources could be leveraged for additional factors?
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How should the co-product allocation values be sourced?
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