**Published name**
Do you agree with the way the production boundary is defined?
Please provide additional information if you disagree with the definition
However, we note that the emissions accounting paper/calculator currently only consider the production of compressed hydrogen, which would likely only suit small scale producers with local use cases.
In contrast we observe that, in practice, a system is more likely to encompass the production of a suite of hydrogen products and co-products and not just a singular product and co-products e.g., compressed hydrogen for domestic use, liquified hydrogen for domestic use/export, ammonia for domestic use/export. As such, consideration needs to be given to expanding the emissions accounting approach to allow a suite of products to be certified in the same calculator.
Do you agree with the post-production boundary definition?
Please provide additional information if you disagree with the definition
We note the need to define a homogenous product(s) (temperature, pressure, purity), across all facilities producing the same product, for the purpose of consistently designating the end of the production boundary and commencement of post-production emissions.
What additional summary values would be useful on GO Certificates beyond the overall emissions, production emissions and post-production emissions?
Uncertainty in the calculated emission intensity should be disclosed. The use of defaults (e.g., for feedstock emission factors) may result in a higher uncertainty in the emission intensity for the product, and this should be transparently disclosed to GO consumers.
We also reinforce feedback we provided on the Scheme Design Paper:
• We believe that as a minimum Product GOs should compulsorily disclose whether spatial and temporal conditions of the REGO to the producer’s consumption from the grid have been matched, and whether additionality has been met for that generation to a specified date (e.g., REGO Scheme commencement).
• In the context of Safeguard Mechanism Reforms, we believe it is important for Product GO certificates to state both a gross emission intensity as well as a net emission intensity, providing transparency to the user.
• Electricity consumption and Scope 2 emissions should be recorded using both approaches: a gross (location-based) and net (market-based) approach. We note that the calculator is already calculating scope 2 emissions under both market and location-based approaches, however the location-based Scope 2 and resulting emission intensity is not disclosed on the Certificate tab.
• Capacity factors, annual operating hours and times of operations should be submitted in the calculator inputs - this will allow a greater level of data transparency for auditing purposes and provide an indication of how much grid power is being consumed during periods with low renewable generation (e.g., electrolysers operating at night / during renewable droughts, etc.). The GO Certificate should subsequently disclose a high-level summary of whether additionality, spatial connection, and time-matching has been met.
What (if any) additional emissions estimation approaches should be considered?
No response
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?
Provided the producer can nominate batch sizes and product certificates can be aligned to batch sizes, the approach should be appropriate.
Should some inputs or outputs be estimated in the reporting profile up front to reduce reporting burden, and if so, which?
No response
What additions or amendments should be made to the proposed measurement guidance, default emissions factors and upstream emissions factor sources?
The use of default emissions factors should be minimised, particularly for inputs that have a wide emission factor range e.g., for coal gasification, the use of NGER-defaults should be avoided and instead, feedstock-specific elemental analysis should be used to inform emission factors.
When using the GO emissions calculator to estimate emissions for our feasibility-level Surat Hydrogen project, we observed a material difference between our internal estimate of emissions intensity (which is calculated using a bottom-up feedstock-specific approach) in comparison to the default-driven approach in the Product GO calculator.
What additional data sources could be leveraged for additional factors?
As per above, the use of defaults should be avoided for inputs that have a wide emission factor range.
How should the co-product allocation values be sourced?
Upload a submission
