What is your name? - Name
What is your organisation? - Organisation
Which of the following best describes the current or intended operations of your business? - Which of the following best describes the current or intended operations of your business?
Which of the following best describes the current or intended operations of your business? - Other
Peak body representing mining companies interested in using and producing hydrogen
Where are your company’s headquarters located? - company location
Which sector best describes your organisation’s operations in Australia? - Other (please specify)
Peak Body representing Mining and Mineral Processing
Is your organisation currently a liable entity under the National Greenhouse Energy & Reporting Scheme - Is your organisation currently a liable entity under the National Greenhouse Energy & Reporting Scheme
How much hydrogen do you estimate you will produce in 2021? - How much hydrogen do you estimate you will produce in 2021?
Beyond 2021 what do you anticipate will be your maximum annual production of hydrogen, and when will you reach that milestone? - maximum annual production of hydrogen
Beyond 2021 what do you anticipate will be your maximum annual production of hydrogen, and when will you reach that milestone? - Year you will reach that milestone
How much hydrogen do you estimate you will consume in 2021? - How much hydrogen do you estimate you will consume in 2021?
What do you anticipate will be your maximum annual consumption of hydrogen, and when will you reach that milestone? - maximum annual production of hydrogen
Which do you consider more important for your Australian operations? - Which do you consider more important for your Australian operations?
For the scheme you nominated above, what is the ideal date to have it in place by? - For the scheme you nominated above, what is the ideal date to have it in place by?
For the scheme you nominated above, what is the ideal date to have it in place by? - Why?
The global hydrogen market is still emerging. The timing of a certification scheme should be cautiously balanced between a realistic and deep market developing and providing investors in an market with the necessary confidence of certified products.
This timing reflects a more reasonable and cautious approach that also allows for international negotiation. This timing will allow the domestic and international markets to emerge and let relevant technologies compete to provide the most cost-effective product.
If both domestic and international schemes are important (Q7), should there be separate schemes or a single scheme? If there are separate schemes, what elements would be the most important to align and what linkages need to occur? - If both domestic and international schemes are important (Q7), should there be separate schemes or a single scheme? If there are separate schemes, what elements would be the most important to align and what linkages need to occur?
A single scheme is preferable. As hydrogen will be a traded commodity, Australia should be linked to a single scheme, similar to markets for other major energy commodities. This could be developed multilaterally or be based on the expansion of a bilateral scheme.
A certification scheme would measure and track the carbon emissions associated with hydrogen production. Are there any existing carbon accounting methodologies that a certification scheme should align with or adopt (e.g. the Australian National Greenhouse and Energy Reporting System?). - A certification scheme would measure and track the carbon emissions associated with hydrogen production. Are there any existing carbon accounting methodologies that a certification scheme should align with or adopt (e.g. the Australian National Greenhouse and Energy Reporting System?).
The scheme would need to fulfill Australia's international reporting requirements, so NGERS would be a starting point. Consideration could also be given to relevant ISO and IPCC standards where they do not disadvantage the competitiveness of Australia's affordable hydrogen.
Are there any other existing Australian regulatory frameworks that might interact with a certification scheme? - Are there any other existing Australian regulatory frameworks that might interact with a certification scheme?
In considering other regulation, the economic regulatory framework for hydrogen should be efficiently structured and administered. It should not be cumbersome, complicated, time-consuming or inefficient. Too many regulators and regulatory issues slow down investment.
What are the three most important features a certification scheme should have? - 1
Technology neutrality. The National Hydrogen Strategy states that 'Clean hydrogen is
produced using renewable energy or using fossil fuels with substantial carbon capture
and storage (CCS). This definition reflects a technology-neutral stance."
A certification scheme that delineates technologies provides mixed messages to investors and is not aligned to the original policy intent of the National Hydrogen Strategy.
What are the three most important features a certification scheme should have? - 2
Ensuring a certification scheme does not disadvantage any producers of clean hydrogen from Australia.
Is there anything else you would like to bring to our attention? - Is there anything else you would like to bring to our attention?
Australia's consideration of developing a certification scheme should account for Australia's strategic interests and competitive advantages. These include Australia's wealth of feedstock to produce affordable, competitive, clean hydrogen, including black and brown coal. Australia should aim to export all cost-competitive origins of clean hydrogen to enable the widest possible market penetration.
Australia should ensure that any certification scheme does not limit Australia's ability to benefit from the emerging economic opportunity in the near future. Clean hydrogen technologies such as coal with CCUS are cost competitive and will be able to produce hydrogen at scale. A narrow certification scheme could jeopardise Australia's current efforts to take advantage of the massive economic opportunity of the emerging hydrogen market.
The design of the certification scheme should also account for the technological readiness of all forms of clean hydrogen production. A certification scheme should not disadvantage technologies that are more commercially mature when some will not be ready to produce hydrogen at a commercial scale for some time.
Well designed certification schemes provide investor guidance and confidence. Certification can also be a hindrance to the development of a commodity market unless all forms of the commodity can utilise the same market framework and infrastructure. In this respect, certification schemes should be designed around the concept of 'clean hydrogen' which is aligned with the National Hydrogen Strategy endorsed by COAG Energy Ministers. This provides Australia with the best scope to take advantage of an emerging hydrogen market.
A technology neutral approach will ensure Australia is in a position where it can supply hydrogen from a diverse range of processes hydrogen. Dictating to the market is likely to result in longer-term failure.
Finally, as the Government has supported a technology-neutral approach to the National Hydrogen Strategy, it is important to ensure that all forms of cost -competitive hydrogen production are represented in government policy and program development processes. To this effect, the Department should include a representative from the coal industry to provide guidance on a certification scheme. A representative from the Hydrogen Energy Supply Chain Project could fill this technical role.
Commercially sensitive information - If you wish your answers to be treated as commercial-in-confidence, please tick this box
Participating in the technical advisory group - If you would like to be considered for membership of the technical advisory group, please tick this box.
Which state government do you represent? - Location
Are there other applications not listed above that you consider to be important? - Please list them.
Not Answered
If a certification scheme was introduced, governments would need to consider how it interacts with existing domestic legislation and voluntary frameworks. For example, certifying renewable energy content for hydrogen production would require considering interactions with the Large Scale Renewable Energy Target. Other examples might include emissions reporting, energy market legislation, or building environmental certification schemes. - Which legislation or voluntary frameworks in your state might interact with a certification scheme?
Not Answered
Which do you consider more important for your state? - Which do you consider more important for your state?
For the scheme you nominated above, what is the ideal date to have it in place by? - Select year, starting from 2021
For the scheme you nominated above, what is the ideal date to have it in place by? - Why?
Not Answered
If the ideal date was not achievable, what would be the latest date a certification scheme should be in place by without adversely affecting potential projects or policies in your jurisdiction? - Why?
Not Answered
Unique ID
