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?
Where are your company’s headquarters located? - company location
Which sector best describes your organisation’s operations in Australia? - Other (please specify)
Hydrogen Engineering Australia (HEA) is responsible for the project coordination of the Hydrogen Energy Supply Chain (HESC) Project undertaken in Victoria. The HESC Project is led by a consortium of experienced industry partners from Japan and Australia: HEA, Kawasaki Heavy Industries, Electric Power Development Co Ltd (J-Power), J-Power Latrobe Valley, Iwatani Corporation, Marubeni Corporation, AGL, and Sumitomo Corporation and is also supported by the Japanese, Commonwealth and Victorian Governments.
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 HESC Project is now in the pilot phase until 2021 and the decision to proceed to a commercial phase will be made in the 2020s with operations targeted in the 2030s, depending on the successful completion of the pilot phase, technical readiness, financial viability, regulatory approvals, social licence to operate and hydrogen demand. A guarantee of origin scheme would affect the decision to proceed to a commercial phase as hydrogen off-taker(s) in Japan must be interested in how hydrogen would be certified as ‘clean’ and it would affect the off-taker(s)’ decision. Investors’ decision would be also affected.
Furthermore, the requirements of a hydrogen certificate would inform the carbon capture rate that the market requires for the hydrogen produced from a commercial HESC. This would impact carbon capture technology selection in a commercial phase and our negotiations with a Carbon Capture and Storage (CCS) provider such as the CarbonNet Project.
Depending on the scope of a guarantee of origin scheme, it could also affect other commercialisation considerations (e.g. water usage, hydrogen purity, emissions associated with electricity, transportation and storage of hydrogen, materials to be used for a commercial phase facilities).
As explained above, the scheme would affect many aspects of a commercial phase project. The quicker a framework is developed, the quicker we can build its requirements into our commercialisation plans. In this regards, the ideal date for the HESC is 2022, which is assumed the quickest date.
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?
Given the HESC Project’s prospective commercialisation activities timeframe mentioned above, we strongly believe that it should be in place by 2023 at least.
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?
Ideally there would only be one internationally administered scheme for hydrogen, which could be applied for domestic market. This would best facilitate trade and remove the need for complicated double accounting or conversions as hydrogen crosses international borders.
Consumers in different countries may have different tastes in their hydrogen (normally based on cost or emissions considerations). Countries may have different domestic emissions reductions system depending on institutional capacity, policies, legislation and national circumstances.
So, a greenhouse gas (GHG) threshold for hydrogen production and its classification scheme should be tailored to its national circumstances and should not be stipulated in such international scheme.
Whilst, the calculation methodologies for GHG emissions and factual data such as production location and date, feedstock used and its associated GHG emissions and the system boundary for lifecycle emissions (which emissions to be covered by the certificate) for each pathway of hydrogen production should be the most important and tracked and developed as the international standard to secure its international consistency. So that producers in Australia would be able to interface with global hydrogen markets.
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 methodologies for estimating emissions and monitoring National Greenhouse Energy and Reporting (NGER) scheme provides is one of existing schemes that could be align and contribute to collect data for an emission intensity scheme of hydrogen produced in Australia.
In addition, it is noteworthy that International Partnership for Hydrogen and Fuel Cells in the Economy (IPHE) announced the establishment of Hydrogen Production Analysis Task Force on 10 March 2020 (refer to https://1fa05528-d4e5-4e84-97c1-ab5587d4aabf.filesusr.com/ugd/45185a_3d98ff47736643c080434e4453058ab0.pdf). This Task Force aims to develop a mutually agreed upon methodology for determining the CO2 equivalent and other pollutants emissions with associated with the production of hydrogen. During its efforts, the European CertifHy project and any other relevant projects in other countries are to be tabled and considered to understand their approaches to determine GHG emissions from processes that produce hydrogen. It is important and worthwhile for Australia to participate in the Task Force and lead a discussion to build the pathway for the internal and international scheme.
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?
Clean Energy Regulator, which is responsible for administrating legislation to reduce carbon emissions and increase the use of clean energy, including the NGER scheme, should be mutually interacted against a hydrogen scheme to ensure consistency. Australian Carbon Credit Units (ACCUs) scheme also could be coupled with to ensure the quality of “clean hydrogen” production, if the scheme provides net mitigation by carbon offsetting (please refer to our response to Question 7.)
What are the three most important features a certification scheme should have? - 1
Ultimately a guarantee of origin scheme should be technology neutral and inclusive and should not exclude any primary energy nor any different production methods such as production pathway with Carbon Capture and Storage (CCS) and Carbon Capture, Utilisation and Storage (CCUS). Other “carbon-neutral” or “carbon-reduction” activities such as use of biomass for hydrogen production, carbon offsetting and tree-planting should be also taken into account. The HESC Project Partners envisage a scheme where the same emissions thresholds apply to all forms of “clean hydrogen”, without resorting to terminology around different colours of hydrogen.
What are the three most important features a certification scheme should have? - 2
A certification system, especially methodology for estimation of GHG emissions should be transparent in approach and assumptions to build confidence. Development of transparent and consistent methodology is critical to the international scheme. Australia positions itself to become a leader in exporting hydrogen to the world and it is important to focus on a scheme that is accepted internationally. We strongly encourage that Australia would play a lead role in urgently shaping an international guarantee of origin scheme built for the global hydrogen market.
What are the three most important features a certification scheme should have? - 3
It is likely that an international body would be best placed to promote a guarantee of origin scheme on a global scale.
Potential international organisations include the International Standardisation Organization (ISO) Indeed, the ISO is already developing standards around hydrogen fuel quality. Finally, the International Energy Agency (IEA) could also play a role, given the amount of ground-breaking thinking already done in this area through various hydrogen advisory panels, reports, etc.
The hydrogen industry could provide their input into these forums through their national government representatives. The Hydrogen Council should also be afforded a seat at any table discussing an international guarantee of origin scheme.
What are the three most important things a scheme should avoid? - 1
As explained in Question 4, a greenhouse gas (GHG) threshold for hydrogen production and its classification scheme should be tailored to its national circumstances and should not be stipulated in such international scheme.
Classification of hydrogen by colours just because of hydrogen sources should be avoided because it might lead to misunderstanding on the actual GHG emitted from hydrogen production process and incorrect image of ‘clean hydrogen’.
Is there anything else you would like to bring to our attention? - Is there anything else you would like to bring to our attention?
Attention also should be paid to EU Sustainable Finance Taxonomy as it is a classification system with defining what activities are considered in line with sustainable development principles and will be used as a basis for the development of a taxonomy through the Australian Sustainable Finance Initiative (ASFI). This should not be too strict a regulatory burden at the infancy stage of the hydrogen industry development, thus preventing, or limiting, key investment into the hydrogen economy. In turn, this could stifle the realisation of their plans for a hydrogen society by 2050.
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.
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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?
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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?
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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?
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