**Published name**
Do you agree with the way the production boundary is defined?
Please provide additional information if you disagree with the definition
The scheme cannot work unless the accounting framework applies market wide. Due to DCCEEW still permitting location based claims in Climate Active and the Corporate Emissions Reduction Transparency Report, plus the fact that default electricity emissions are displayed using state location based grid factors on customer bills across Australia by default, this scheme will continue systemic double counting. For any scheme to be applied it must have both legitimacy and integrity.
LEGITIMACY
Legitimacy will be created when the attributes of renewable electricity ('renewables use' at 'zero scope 2 emissions' are defined in a legislative instrument.
INTEGRITY
Integrity will be achieved when when location based accounting for electricity permitted for context and for dual reporting only (not for customer billing, beliefs and claims), and when systemic double counting is stopped across the market.
DCCEEW continues to provide every support to industry to provide schemes and assurance frameworks but does nothing for ordinary Australian household consumers to have consistent, complete and legally underpinned emissions allocation and disclosure for their electricity, renewable electricity and carbon offsets that they pay for or voluntarily buy.
Australia needs a Department of Climate Change and Energy for households and household customers as much as it has one for industry schemes.
It is unfair for DCCEEW to create another scheme to benefit industry when it has not even clarified the default renewable component of standard grid electricity and has not legally allocated renewable electricity use at zero emissions to GreenPower customers.
A low carbon economy and market needs to move forward together and not leave ordinary Australian's behind.
Do you agree with the post-production boundary definition?
Please provide additional information if you disagree with the definition
As per my answer to the first question.
What additional summary values would be useful on GO Certificates beyond the overall emissions, production emissions and post-production emissions?
Please just get the fundamentals right to apply clear and consistent allocation, trading, claims and disclosure rules across the economy.
What (if any) additional emissions estimation approaches should be considered?
There must be a clear disclosure and categorisation that the emissions associated with products and supply chain accounting is Scope 3. This paper appears silent on this matter and that creates a risk that the respect for accounting within scopes may be perverted where there is inadequate guidance.
REGO certificates deal wth scope 2 emissions but as soon as renewable claims are used in supply chain accounting, the disclosure to product customers is scope 3. This is basic and fundamental to carbon accounting but DCCEEW has just omitted any reference to this foundation.
Are the approaches to allocating emissions to co-products appropriate?
It is not yet possible to address this question as the basic market based foundations of apportioning supplier Scope 1 and 2 emissions to a product and supply chain as uphill scope 3 emissions have not been established by DCCEEW.
How practical will it be to report the quantities of each input and output for every creation claim?
Carbon accounting is possible for many products, but only where there are clear and consistent rules for accounting in scopes, allocating, trading and claiming indirect scope 2 and scope 3 emissions, basic debit and credit rules to prevent double counting and no parallel location based claims of the same scope 2 attributes.
Should some inputs or outputs be estimated in the reporting profile up front to reduce reporting burden, and if so, which?
Almost all carbon accounting is based on estimates. they need to be the best estimates used with accounting, allocation, trading and end user claims rules that have integrity and prevent systemic double counting.
What additions or amendments should be made to the proposed measurement guidance, default emissions factors and upstream emissions factor sources?
There needs to be a clear disclosure that GO Certificates are a SCOPE 3 EMISSIONS DISCLOSURE OF A PRODUCT.
DCCEEW have described Guarantee of Origin Certificates (GO Certificates) as " the mechanism for recording and tracing
information in the GO scheme". This is a continuation of the Departmental policy of never describing key ingredients of its assurance frameworks, schemes and units with an accurate plain English description. The ACCC has asked industry to use clear and easily understood language to describe products, but the industry cannot do this when DCCEEW create schemes in code.
CONSUMPTION OF CERTIFICATES?[redacted]
[redacted] Suitable terminology could include:
* Surrender and cancellation of GO and REGO/LGC Certificates
* Relinquishment of Go and REGO/LGC Certificates
* Retirement of GO and REGO/LGC Certificates.
The way that DCCEEW is referring to consumption of certificates can blur information and mislead end users and stakeholders on important information regarding allocated consumption of renewable electricity at zero emissions, as different to what ever attributes are or are not legally integrated into a certificate. In addition, GO certificates are about allocating upstream scope 3 emissions to a product or through a supply chain. It is important to maintain the common understanding that this is what the accounting framework is to assure and that Certificates must be retired, relinquished and cancelled to achieve this. It is not about consuming certificates per se.
What additional data sources could be leveraged for additional factors?
Any up hill Scope 1 emission that can be associated with a product supply chain
Any up hill Scope 2 emission that can be associated with a product supply chain
Any up hill Scope 3 emission that can be associated with a product supply chain
How should the co-product allocation values be sourced?
