**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?
Please provide additional information if you don’t think the enrolment process is well balanced.
Chevron supports the revision of the scheme proposal to a single registered participant account type rather than registration into four participant types.
Do you consider the proposed profile registration process appropriate?
Please provide additional information if you don’t think the assessment process is well balanced.
In recognition that a participant may not have visibility or control over the full supply chain, Chevron supports the proposed ability to transfer the responsibility to provide post-production and consumption information to other participants. Product GOs should enable the feed (well-to), production (well-to-gate) and transport (gate-to-user) emission data to be identified separately. This would enable integration with international certification schemes that may have narrower system boundaries (such as gate-to-gate or gate-to-user) as well as to maintain primary source data across the system so as to support the transparency and accuracy of the scheme.
In the general information requested for a profile registration, Chevron suggests ‘details of Indigenous community endorsement for facilities operating on Native Title lands (where applicable)’, while important, does not relate to the emissions intensity of the product and goes beyond the scope of this scheme. It should therefore be removed as a requirement.
Chevron supports the current approach to consumption profiles as well as making information about the intended use of the related product optional in the profile which allows certificates to be severable from the physical product.
Do you consider the proposed assessment process appropriate?
Please provide additional information if you don’t think the assessment process is well balanced. i.e. the minimum scope of LSTRs, the discretionary powers of the CER, etc
In general, Chevron supports third-party assurance to maintain the scheme’s integrity and emphasises a preference to align these assurance practices across all relevant schemes, such as NGERs, to minimise duplication of work and associated costs. We would be pleased to provide detailed feedback if provided further information on the proposed scope of a LSTR and how this aligns with these existing assurance activities.
Are the ongoing obligations proposed under the scheme appropriate?
Please provide additional information if you don’t think the ongoing obligations are well balanced. i.e. the proposed powers of the CER to maintain ongoing compliance
Chevron supports this proposal and recommends leveraging NGER Section 19 data to streamline reporting efforts.
Where a profile needs to be revised (as a result of a facility modification or ‘material change to the production process’) the process should ensure that certificate generation may be promptly resumed in order to meet commercial requirements.
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.
Chevron understands that hourly data may be well suited for electricity markets and supports optionality in the creation period range for batch processing, and longer durations that aligns to the NGER or Financial Reporting year for facilities with continuous processing.
Chevron supports measurement, reporting and verification methodologies with temporal boundaries that are aligned with currently available product life cycle accounting standards, principally the GHG Protocol Product Life Cycle Accounting and Reporting Standard and ISO14067:2018. A maximum duration of 12 months as proposed in the scheme will allow interannual and intra-annual variability in production to be averaged over the ‘batch’ period of time.
Chevron supports the 12-month vintage rule approach to use of renewable electricity certificates as an input to a Product GO, and welcomes expansion of the scheme to include the ability to optionally demonstrate more strict temporal correlation if required.
Do you consider the proposed certificate completion process appropriate?
Please provide additional information if you don’t think the certificate completion process is well balanced. i.e. are there any types of data that are likely to cause errors in reporting
Chevron promotes the use of full lifecycle greenhouse gas accounting or carbon foot printing of activities and products based on primary data for significant portions of the value chain. We are pleased to support the well-to-user system boundary proposed for Product GOs. Further, we welcome the revision of the scheme to allow emissions from different segments of the supply chain to be identified and reported separately. This would enable primary data from each participant in the value chain to be appended at each step.
Emissions accounting of transport and storage may continue to be challenging when considering different custody transfer arrangements. Products may be transported, stored, redistributed, re-sold or converted to secondary products prior to final use. Consider a simple scenario whereby a primary customer purchases the product direct from a producer, then on-sells and distributes to a secondary customer. More than one party involved in the transport and storage section of a supply chain would require multiple transport and/or storage profiles to be applied to a Product GO. Consideration should be given under the scheme as to how manage completion of certificates when multiple parties are involved along the supply chain, each requiring entry of their own primary data.
The most flexible, cost-effective, and scalable solutions should be promoted and incentivised to reduce the emissions intensity of products listed on GO certificates as long as the emissions attributes are not claimed by multiple parties. However, the Department should also ensure the Guarantee of Origin scheme is compatible with the Emissions Reduction Fund’s Carbon Capture and Storage (CCS) method, in that the carbon intensity on Product GOs should be eligible to recognise emissions reduction from third-party CCS Projects that sequester CO2 on behalf of the hydrogen production facility. According to the Emissions Reduction Fund’s CCS method, Australian Carbon Credit Units (ACCUs) that are credited to a CCS project may be attributed to a Safeguard Facility where the emission abatement occurred. The surrender of these ‘attributed ACCUs’ will be realised as emissions reduction against the facility baseline under the Safeguard Mechanism. However, a Product GO for blue hydrogen products would need to similarly recognize surrender of attributed ACCUs from an associated CCS ERF Project to ensure the reduction in carbon intensity is correctly represented. It is recommended the carbon intensity calculation on Product GOs similarly recognise the surrender of ‘attributed ACCUs’ from an associated CCS project.
Chevron encourages expansion of the Product GO to enable offset-pairing with products. We support transparency of the initial carbon intensity of the product being identifiable on the certificate, with the ability to demonstrate further offset or credit adjustments that have been paired with the product.
Do you consider the proposed certificate retirement process appropriate?
Please provide additional information if you don’t think the certificate retirement process is well balanced.
Chevron supports the ability to transfer GO certificates between participants to align with contractual or commercial arrangements. That said, the scheme will need to ensure registration of consumption participant profiles is either extended to international entities, as the ultimate user of the product, or alternatively be surrendered by an Australian entity on behalf of an international consumer at the point of departure from the port as the ‘delivery gate’.
Do you consider the proposed ARC process appropriate?
Please provide additional information if you don’t think the ARC process is well balanced.
Chevron supports Annual Reconciliation Check process to finalise Product GOs from further amendments. However, the proposed timing of the process should be altered to align with, or shortly follow, section 19 of the NGERs scheme. This would ensure alignment and consistency, as well as minimise regulatory burden, across Australia’s regulatory schemes. Consideration may need to be given to timing of ARCs for producers who elect the longer (e.g. 12 month) batch period to ensure there is adequate lead preparation time. Chevron would support optionality for the reporting and reconciliation periods to allow flexibility in response to commercial imperatives while maintaining consistency under the scheme.
Chevron strongly support aligning the GO Scheme with emissions accounting methodologies of NGER, Safeguard mechanism and any future climate-related financial disclosures requirements. It is recommended emissions reported under NGER Section 19 may be utilised and apportioned to calculate emissions intensity on Product GOs. This would minimise duplicative reporting and third-party assurances.
Where responsibility of completing post-production emissions data has been transferred from the producer to another party, the ARC on a given Product GO should be conducted only the profile or batch data owned by that participant. That is, the scheme will need to conduct ARCs on a participant basis for each Product GO where profile and batch information has been provided by multiple participants.
Do you consider the proposed certificate correction process appropriate?
Please provide additional information if you don’t think the certificate correction process is well balanced
Where a profile needs to be revised (as a result of a facility modification or ‘material change to the production process’) the process should ensure that certificate generation may be promptly resumed in order to meet commercial requirements.
What information should be publicly available on the GO Registers compared to privately available information that can be shared?
Chevron supports a technology-neutral approach to hydrogen production, with a focus on reducing carbon intensity. We believe a technology neutral approach will maximise emissions reduction and facilitate flexibility across the economy.
Chevron supports transparency in emissions, and to prevent disclosure of potentially commercially sensitive information, we recommend data is available in aggregate, rather than individual transaction/Product GO level or only to view a participant’s own transactions or interactions with a Product GO.
Please provide feedback on the product prioritisation and methodology development process
Chevron believes all technologies and energy sources should be available to achieve Net Zero in order to maximise the range of potential pathways to achieve net zero goals globally. As stated, Chevron supports a technology-neutral approach to hydrogen production, with a focus on reducing carbon intensity. Future expansion of the scheme with additional product-specific methodologies will enable flexible, scalable, and cost-efficient emission reductions activities across the economy.
The scheme will initially cover three production pathways for hydrogen including electrolysis, steam methane reformation (SMR) and coal gasification. However, calculator has ‘natural gas reforming’ rather than strictly SMR. The GO scheme should not artificially dictate technology selection for projects based on those acceptable under the scheme. Rather it should allow for the most efficient and effective technologies to be selected. This would work to expand the scheme to include ATR, eSMR, and other technologies. Chevron’s position appears to be consistent with the language used in the emissions calculator, however clarification of this point is important for the efficacy of the scheme.
Chevron supports periodic reviews to ensure the program works as intended, and any improvements to be made. Additionally, we recommend industry and participant feedback be sought and considered in the periodic reviews. We support swift adoption and deployment of methodologies for prioritised technology to ensure the most competitive carbon reduction technologies are deployed to support the industry.
Product GOs should enable the feed (well-to), production (well-to-gate) and transport (gate-to-user) emission data to be identified separately to enable integration with international certification schemes that may have narrower system boundaries (such as gate-to-gate or gate-to-user.)
Chevron welcomes the additional rigour proposed to the review of the operation of the scheme from every 5 to every 3 years, noting the requirement to balance operational effectiveness with regulatory certainty. As such, Chevron would recommend a shorter initial review period in order to address any key concerns with the functionality of the system earlier.
Chevron would welcome further consultation on the specifics of the proposed cost recovery approach, in particular how a levy may be determined and applied to participants in the scheme.
