**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.
Note that CCS sits within the production profile, however it may be a third-party activity. Under the listed categories of profiles, either the Gasification/SMR facility operator could hold a production profile and report on CCS as part of this, OR the CCS operator could also have a production profile in conjunction with the Gasification/SMR facility operator.
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.
We agree that ACCUs issued from within the system boundary will need to be surrendered for the emissions reductions to be recognised under the GO scheme.
We disagree that ACCUs or other carbon offsets cannot be used to reduce the emissions intensity of products listed on GO certificates. Given the implemented Safeguard Mechanism reforms and the transition to declining Safeguard Baselines, it is possible that many Safeguard facilities will not be able to continuously reduce their emissions to be below a declining Safeguard Baseline. Hence they would need to surrender ACCUs to achieve a net emission which is equal to their Baseline. As such, 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.
We also believe that the "within 12 month" correlation allowed for REGOs to be surrendered for Product GOs is too lenient. Whilst we understand that time matching is an onerous proposition for an emerging industry, 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).
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
We believe the use of 1kg hydrogen per GO certificate creates an onerous reporting burden.
Batch period and product volume per certificate should both be able to be nominated by the producer and will typically be cognisant of customer demand volumes/batches.
We believe this approach could be used to streamline reporting and regulatory burden.
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?
• Electricity consumption and Scope 2 emissions should be recorded using both approaches: a gross (location-based) and net (market-based) approach.
• CCS should also be recorded on a gross and net basis: gross = total carbon dioxide produced through process; net = gross carbon dioxide less carbon sequestered
• Capacity factors, annual operating hours and times of operations should be submitted: This will allow a greater level of data transparency for auditing purposes / public display of how much grid power is being consumed during periods with low renewable generation (e.g. electrolysers operating at night / during renewable droughts, etc.)
Please provide feedback on the product prioritisation and methodology development process
We support the proposed approach and timing, and believe that stakeholders should also be permitted to provide feedback on existing products that should be de-escalated or removed from the list
We believe that hydrogen carriers such as ammonia should rank first on the product prioritisation list.
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