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
Industry association for the renewable energy sector
Where are your company’s headquarters located? - company location
Which sector best describes your organisation’s operations in Australia? - D Electricity, Gas, Water and Waste Services
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 CEC considers it vital that a hydrogen certification scheme is available from the time in which clean hydrogen produced in Australia is available for sale/trade for a domestic or international market. With a number of projects in an advanced stage of project development, we recommend that a certification scheme/convention for the Australian market be put in place in 2021.
If the ideal date was not achievable, what would be the latest date a certification scheme could be in place by without adversely affecting your Australian operations? - Select year, starting from 2021
If the ideal date was not achievable, what would be the latest date a certification scheme could be in place by without adversely affecting your Australian operations? - Why?
As above, the CEC has members who are already negotiating offtake agreements for projects that could be producing within the next 18 months. A certification scheme will be required to support from the commencement of this trade, and will also be helpful for product marketing.
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?
While the ultimate aim is for a single international certification scheme, this could take years to develop – a delay which could stifle marketing and production.
As such, until such a scheme is in place, the CEC supports the development of a domestic certification scheme which is flexible enough to support both domestic and international trade.
The simple convention proposed in the National Hydrogen Strategy covering greenhouse gas emissions associated with production (scope 1 and 2), production technology type and production location, addresses the primary issues.
Given the existing support from the Commonwealth, state and territory governments for this certification convention, the CEC can see no impediment to these reporting requirements being announced/confirmed in 2020, with a view to introduction in 2021.
This can be introduced in parallel to Australia’s active participation in international discussions about the development of a globally-recognised certification standard. The fact that Australia will have introduced its own standard, providing information which is likely to be regarded as essential by any buyer, is likely to only increase Australia’s influence on the outcomes of those negotiations.
Until the time that a single international scheme is available, where Australian-made hydrogen is sold in markets that use other labelling conventions, the producers would apply both labels (Australian and destination market) to their product.
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 National Greenhouse and Energy Reporting Scheme, administered by the Clean Energy Regulator, is aligned with international carbon accounting standards and is the most appropriate framework for the reporting of emissions.
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?
Certification of renewable hydrogen will rely on the ability to demonstrate the use of renewable electricity in the production of the hydrogen.
The scheme which tracks and verifies the generation of renewable electricity is the Renewable Energy Target, administered by the Clean Energy Regulator.
The CEC also supports the potential for ‘fungibility’ between large-scale generation certificates (LGCs) and Australian Carbon Credit Units (ACCUs), which, if allowed, would extend the interaction between Australia’s carbon reduction schemes.
Given the likely interaction between the certification scheme, LGCs and potentially ACCUs, the CEC considers that the Clean Energy Regulator may be the most appropriate Government body to administer a certification scheme for renewable hydrogen/renewable gas.
Legislation currently administered by the CER include:
• Clean Energy Act 2011
• National Greenhouse and Energy Reporting (NGER) Act 2007
• Renewable Energy (Electricity) Act 2000
• Carbon Credits (Carbon Farming Initiative) Act 2011, and
• Australian National Registry of Emissions Units (ANREU) Act 2011.
What are the three most important features a certification scheme should have? - 1
1. Clear description of CO2-e emissions per kilogram/kilojoule of hydrogen
What are the three most important features a certification scheme should have? - 2
2. Clear description of technology type
What are the three most important features a certification scheme should have? - 3
3. Verification scheme to monitor and track compliance.
What are the three most important things a scheme should avoid? - 1
Unnecessary complexity and bureaucratisation of a simple labelling convention, which would slow the implementation of the scheme and drive up the project reporting/compliance costs.
What are the three most important things a scheme should avoid? - 2
Getting bogged down in distinctions between 'green', 'blue' and 'grey' hydrogen etc, which will slow down progress on international agreement. Reporting of Kg of CO2 per Kg/kj of hydrogen is the most critical piece of information to facilitate trade.
Is there anything else you would like to bring to our attention? - Is there anything else you would like to bring to our attention?
Hydrogen may not be the only gas/liquid fuel which requires a certification scheme. Almost 60 per cent of the renewable hydrogen projects currently under development in Australia plan to deliver ammonia as the end product, which is easier to store and transport, and a certification scheme may also be required for green ammonia.
It’s important therefore that we maintain flexibility to allow for potential expansion (down the track) of the certification scheme to cover other relevant renewable gases, as relevant.
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
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