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, representing stakeholders across the full value chain of hydrogen / ammonia energy
Where are your company’s headquarters located? - company location
Which sector best describes your organisation’s operations in Australia? - Other (please specify)
Industry Association
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?
Australian hydrogen project developers are looking to begin large-scale production by mid-decade, following a ~3 year construction phase. These projects will supply international trading partners looking to begin imports in 2025-27. To secure project financing, Australian developers must first confirm a price (premium) with offtakers. To enable this, a certification scheme must be in place by 2022-3 so that projects reach financial close and begin construction on time, and trading can begin mid-decade. Otherwise, these Australian investments will be delayed, and other international producers will benefit.
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?
Investment decisions will be delayed if the scheme is not in place by 2023, and Australian supply contracts may be lost to overseas competitors.
Note that if a globally accepted scheme is unlikely to be finalized by 2023, a bilateral scheme (with Japan) or regional scheme (Japan and US, Republic of Korea, Singapore, New Zealand, eg) should be established. This would support Australian exports to its most significant hydrogen trading partners.
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?
Single, to reduce cost / complexity, increase transparency, and support exports as most significant economic opportunity.
Derivative products, including ammonia, must be carefully considered at the outset for scheme alignment / linkages, with importance for both domestic markets (green fertilizers) and international trading (hydrogen carriers). If ammonia is not explicitly included in the hydrogen certification scheme, a separate ammonia certification scheme will be required. Therefore, the hydrogen certification scheme should be designed to “plug and play” with derivative products (beyond ammonia, this includes methanol, MCH, liquid hydrogen, etc).
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 Australian scheme should align with IPCC carbon accounting methodologies.
Alignment with the EU’s CertifHy may also be useful, as well as with EU Carbon Credit scheme (eg, for ammonia as fuel in power generation).
Coordination with regulations currently under development within the IMO, to implement its Initial GHG Strategy, would be extremely valuable, so that Australian hydrogen (and its derivatives) can enter the low-carbon maritime fuel market at the earliest opportunity.
For market flexibility, it is important that accounting includes an absolute number, not just relative numbers (eg, % versus baseline).
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?
No comment.
What are the three most important features a certification scheme should have? - 1
Derivative products, eg: ammonia, methanol, MCH, etc, will require additional certification. A “plug and play” hydrogen certification scheme that can be integrated into certification schemes for derivative products would be of great value. The same metrics should apply, but careful consideration should be given to the additional certification requirements of “hydrogen carriers” so that the Hydrogen Certification Scheme is successful in supporting both the domestic fertilizer / explosives market and the hydrogen export industry.
What are the three most important features a certification scheme should have? - 2
Simple, relevant, and unambiguous metrics including at a minimum: CO2e (all GHGs, not just carbon) emissions (Scope 1 and 2), production technology, production location. This may require standardized energy use and efficiency estimations.
These metrics should enable the Hydrogen Certification Scheme to provide neutral, factual disclosure of production technology (origin, process), allowing markets to value these aspects according to demand (eg, blue v green, or carbon sequestration v forestry offset).
What are the three most important features a certification scheme should have? - 3
The Certificate Scheme should enable certificate trading, so that the low-carbon attribute can be separated from the molecules.
Mechanisms to support trust — both public and between trading parties — and enforce compliance will be essential: transparency, independent verification, and certificate life-cycle management (retirement).
What are the three most important things a scheme should avoid? - 1
Significant cost and complexity.
What are the three most important things a scheme should avoid? - 2
Oversimplicity. Both provenance and carbon intensity are essential metrics; without both, a scheme could create ambiguity in GHG credit between hydrogen products with same carbon intensity but different origin.
It is crucial that the scheme doesn’t exclude technology pathways by defining eligibility along mainstream expectations. For example, the terms brown, blue, or green are useful shorthand but inadequate as definitions of process technologies. These simplistic colour codes exclude many feasible low-carbon production pathways, for example nuclear electrolysis or pyrolysis technologies or ammonia capture from wastewater.
What are the three most important things a scheme should avoid? - 3
Irreconcilable clash with international scheme/s, especially likely near-term trading partners and IMO.
Is there anything else you would like to bring to our attention? - Is there anything else you would like to bring to our attention?
Blue hydrogen and ammonia will be critical for setting up the relevant scale infrastructure, establishing early markets, and providing initial product volumes.
However, the key transition is from blue to green and the design of the Hydrogen Certification Scheme should support this transition. All fossil-based hydrogen production, regardless of carbon intensity, creates demand for additional long-term fossil exploration and extraction and, with a low-cost basis, may stifle innovation in green technologies.
The Scheme could support this green transition, for example, with a ’sunset’ provision, following successful establishment of a market for low-carbon hydrogen, by which blue hydrogen production is excluded from the scheme if, eg, construction of the production unit begins after 2030.
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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