**Published name**
Would you like to subscribe to our mailing list to receive correspondence and updates on the Guarantee of Origin scheme?
How do you intend to participate with the GO scheme?
How do you plan to use GO certificates?
Do you consider the proposed enrolment process appropriate?
Do you consider the proposed profile registration process appropriate?
Do you consider the proposed assessment process appropriate?
Are the ongoing obligations proposed under the scheme appropriate?
Do you consider the proposed certificate creation process appropriate?
Please provide additional information if you don’t think the certificate creation process is well balanced.
See below re: GHG emissions thresholds and concerns regarding the IPHE methodology
Do you consider the proposed certificate completion process appropriate?
Do you consider the proposed certificate retirement process appropriate?
Do you consider the proposed ARC process appropriate?
Do you consider the proposed certificate correction process appropriate?
What information should be publicly available on the GO Registers compared to privately available information that can be shared?
We support strong transparency requirements. To contribute to informed public debate and building trust, disclosures should be proactive, comprehensive, and publicly accessible. The information should be made freely available online. Free access to, and subsequent re-use of, open data are of significant value to society.
Please provide feedback on the product prioritisation and methodology development process
We have two concerns regarding the methodology underpinning the scheme.
1. The scheme should include GHG emissions thresholds. The proposed approach risks being seen as an endorsement of hydrogen production pathways that will considerably impact GHG emissions for decades. The IPHE method on GHG emissions accounting from hydrogen will become an ISO standard, but it does not set any emissions intensity thresholds. This risks greenwashing if H2 producers base the claim of “low-emission” H2 on “IPHE compliance” or “ISO compliance”.
The “2023 Breakthrough Report” co-authored by the International Energy Agency (IEA), the International Renewable Energy Agency (IRENA), and the UN Climate Change High-Level Champions has examined the polices required to support stronger international collaboration to drive faster reductions in global greenhouse gas emissions. While the report does not define a specific carbon intensity limit for low-carbon and renewable hydrogen, it states: “…these production routes will need to achieve verifiable low-carbon intensities that trend towards near zero by 2030. This implies that fossil-based hydrogen production must operate with high carbon capture rates applied to all streams containing carbon dioxide, and that the captured carbon is permanently stored underground to prevent its release into the atmosphere. Additionally, it is critical that methane leakage is minimised to near zero, if not completely avoided. Rigorous measurement, reporting and verification of emissions will be necessary”.
https://iea.blob.core.windows.net/assets/b551dc82-c4d3-4330-8975-2d3e07739a6f/THEBREAKTHROUGHAGENDAREPORT2023.pdf
2. There is an urgent need to address some gaps in the IPHE methodology.
a. The scheme should set clear and stringent requirements for the GHG emissions associated with the upstream natural gas value chain with respect to measuring, monitoring, reporting, and verification. The scheme should reference level 4 and level 5 reporting under the OGMP 2.0 framework.
b. The scheme should clear and stringent requirements for the permanence of carbon storage. For example, the scheme could reference the Carbon Capture and Sequestration Protocol under California’s Low Carbon Fuel Standard program.
In both cases, third-party verification and public reporting would enhance the credibility of the measurement.
See: https://theicct.org/wp-content/uploads/2023/07/ISO_blue_hydrogen_GHG_ICCT_DNV.pdf
