JOGMEC

**Published name**

JOGMEC

Do you agree with the way the production boundary is defined?

Yes

Do you agree with the post-production boundary definition?

Yes

What additional summary values would be useful on GO Certificates beyond the overall emissions, production emissions and post-production emissions?

(a) The breakdown of production emissions and post-production emissions is useful to calculate the value between different gates defined by others. It is expected to indicate the followings as emissions information at least.
- Upstream emissions intensity (Gate-to-gate for upstream)
- Direct emissions intensity (Gate-to-gate for production)
- Transportation emissions intensity (Gate-to-gate for transportation)
- Storage emissions intensity (Gate-to-gate for storage)
- Emissions intensity for losses
It is also expected to indicate emissions intensity to two decimal places.

(b) In case that the product in one batch period is supplied to two or more consumers, the GO certificate may be divided based on the quantity and presented to each consumer. It is expected that the GO certificate covers the quantity of product as general information.

What (if any) additional emissions estimation approaches should be considered?

For estimating emissions, it is preferable to set the materiality threshold at 5% of the total emissions from each source within the production boundary instead of 2.5% in accordance with the following international practices well known.
- Science Based Targets initiative(SBTi), "CRITERIA AND RECOMMENDATIONS FOR NEAR-TERM TARGETS, TWG-INF-002|Verson 5.1|April 2023"
- GHG Protocol, "A Corporate Accounting and Reporting Standard, REVISED EDITION"
- Climate Registry, "General Verification Protocol, Version 2.1, Updates and Clarifications, Last Revised: October 10, 2019"
- British Standard Institution(BSI), PAS 2050:2011 "Specification for the assessment of the life cycle greenhouse gas emissions of goods and services"

Are the approaches to allocating emissions to co-products appropriate?

We agree with the approaches suggested.

How practical will it be to report the quantities of each input and output for every creation claim?

There may be a case that the applicant cannot provide confidential information classified by a licensor as inputs. How will the application be treated in this case? And even if it is allowed by a licensor to provide confidential information, how is the information handled/managed by CER and a third party for keeping confidential? The policy and means of confidential information management are needed to be clarified.