Published name
An initial focus on hydrogen production is proposed to facilitate timely establishment of a hydrogen GO scheme. Do you agree with this as a starting point?
A well-to-gate boundary is proposed as the initial boundary across which the emissions are to be calculated for hydrogen GO scheme. Do you agree this is an appropriate and acceptable starting point for the boundary?
A well-to-gate boundary is proposed as the initial boundary across which the emissions are to be calculated for hydrogen GO scheme.
One important point to consider is the long term certainty of carbon offsetting. For example, a tonne of CO2 sequestered or used as EoR medium could be considered 100% fixed in the present time however if in the long term, there is a possibility of re-emission. It is important to consider these in the GO scheme and apply a credit according to the long term certainty of the carbon fixing technique.
Is hydrogen production at a pressure of 3MPa and 99% purity appropriate conditions for measuring the emissions associated with hydrogen?
Is hydrogen production at a pressure of 3MPa and 99% purity appropriate conditions for measuring the emissions associated with hydrogen?
Is hydrogen production at a pressure of 3MPa and 99% purity appropriate conditions for measuring the emissions associated with hydrogen?
The definition of "gate" as 3MPa delivery should be reviewed.
If hydrogen is produced at atmospheric pressure and compressed up to use pressure, which could be as high as 35 -50 MPa (fueling purposes), there will unlikely be a 30 MPa intermediate stream with clear physical plant boundaries. Whilst a benchmark can be calculated, clear guidelines should be provided to avoid ambiguity and creative accounting e.g. how to treat the overall compression efficiency, when only first 3-4 stages produce 3MPa.
For chemical production 3 MPa provides a reasonable breakpoint.
The department recognises the need to extend the coverage of the scheme over time to include hydrogen derivatives and downstream products, additional production pathways and additional steps in the value chain. - What additional components should be covered and when? (noting the commitment to include hydrogen energy carriers as an early next step).
1. Storage and purification to upgrade hydrogen for chemical process feed e.g. ammonia and methanol as a minimum, all the way to product storage and pump-out (to port facilities or tanker loading)
2. Taking into account power generation from waste heat of the chemical production e.g. ammonia, which is fed back to the power distribution
Do you agree that ISO standards and the GHG protocol provide the appropriate basis for the overarching framework for a hydrogen GO scheme?
Do you agree that ISO standards and the GHG protocol provide the appropriate basis for the overarching framework for a hydrogen GO scheme?
As a starting point yes, but these standards are high level and will need significant augmentation for the GO scheme.
Should IPCC Guidelines, the NGERS determination and the Climate Active Electricity Accounting rules be leveraged to provide guidance on the detailed emissions calculations?
What is your preferred approach to offset inclusion within a domestic hydrogen GO scheme?
What is your preferred approach to offset inclusion within a domestic hydrogen GO scheme?
We need science backed and clear carbon accounting. The carbon offset should also flow the well to gate boundary. This way each project is accountable within its system boundary.
Do you agree that the Australian government should lead the administration of an Australian GO scheme?
Do you agree that the scheme should be administered by the Clean Energy Regulator?
What should be the role of industry in co-designing a government led scheme?
the CER, needs to have equal share of all industries in the decision making board. Also key point to make here is that the regulations must ultimately pave the way for renewable energy based hydrogen to be the dominant form. This is to ensure the hydrogen produced in Australia has a universal market, including Europe.
Do you support the creation of Australia’s hydrogen GO scheme as a certificate scheme?
Do you support the creation of Australia’s hydrogen GO scheme as a certificate scheme?
There is an urgent need for an emissions intensity based scheme to activate the market for low carbon hydrogen. Without a scheme, the market potential cannot be quantified and the developers are left to their own devices to make the business case work,
What would you consider to be the best regulatory framework to support hydrogen Guarantee of Origin scheme?
A verifiable emission intensity certificate is a must. The framework must have a clear and detailed guidelines on the calculation of this important parameter. The framework must promote and transition to green hydrogen.
Lastly, an independent auditing body should also be considered to ensure no mis-reporting.
How frequently do you consider hydrogen GO certificate creation will be required?
once a year
How frequently should data be reported; Is the proposed 12 month period adequate?
How frequently should data be reported; Is the proposed 12 month period adequate?
Given the ever changing landscape, once every 12 months is a must. This frequency could be increased if mis-reporting is found.
Do you agree with the approach set out for scope 1 emissions?
Do you agree with the approach set out for scope 1 emissions?
Yes, largely agreed, however would recommend use of continuous online sampling to ensure an action can be taken by the operator if a deviation occurs. Otherwise the risk is that the "as designed" emission factors continue to be used, even if there is a significant difference in actual operation.
Do you agree with the approach set out for upstream emissions?
Do you agree that the calculation of electricity (scope 2) emissions should be based on the market-based method?
Do you agree that the calculation of electricity (scope 2) emissions should be based on the market-based method?
A market based approach is a good starting point however ultimately a location based approach should be pushed or credited as it is more granular. Otherwise, the we risk siloing areas of the country to continue with the business as usual approach as there is no incentive to change the power mix.
Would you suggest any changes to the Climate Active approach (set out in detail in Attachment D) for the purposes of a hydrogen GO scheme?
no
What are your views on using voluntary surrender of LGCs to verify the consumption of renewable electricity under the market based method, compared to the alternative of a location-based method?
Do you agree that a means of identifying consumption of below-LRET-baseline renewable electricity generation would be beneficial for the hydrogen certification scheme?
What are your views on establishing a new renewable guarantee-of-origin certificate for verifying below-baseline and post-2030 renewable electricity?
What would be the effect of having a general certification scheme for renewable electricity?
no comment
Do you agree that certification should recognise other sources of renewable electricity, including those outlined outlined in Section 3.5.1?
Do you agree that emissions should be attributed to co-products where they are on-sold?
Are the by-products identified for each pathway likely to be co-products (or are they more likely to be waste products?)
Are the by-products identified for each pathway likely to be co-products (or are they more likely to be waste products?)
e.g. waste heat and oxygen from electrolysis
Do you think that the allocation methods suggested in each pathway are appropriate and practical?
Do you think that the allocation methods suggested in each pathway are appropriate and practical?
as per the tehrmo-chemical distribution of carbon within the process. This should be scientific, not commercial.
There are similar standards available in the natural gas industry for allocation of products.
Do you agree with an approach limiting provisions for CCS and CCUS in an initial Guarantee of Origin scheme to those included under the NGER determination, noting that these will be expanded or adjusted as new CCUS technologies and industrial processes are implemented?
What are the likely or possible applications of CCUS technologies in the hydrogen industry?
In general CCUS suffers from economic hurdles. the benefit of CCUS can only be if it ultimately reduces the use of single use carbon based sources/fuels. As a nation, we must measure the affect of CCUS, rather than just assuming that it is having the desired affect. e.g. includes methanol production for non-fuel uses, aggregate production for construction
Do you agree with setting a materiality threshold allowing entities to exclude a small amount (e.g. 2.5 to 5%) of total emissions from analysis?
Do you agree with setting a materiality threshold allowing entities to exclude a small amount (e.g. 2.5 to 5%) of total emissions from analysis?
this is a significant portion, pretty much lets fugitive emissions of methane to remain unaccounted.
What would you consider to be an appropriate threshold?
0.5 - 1%. There may be uses for fossil fuels for emergency management in production facilities such as use as flare pilots etc.
Is a trial phase an appropriate next step for testing and refining the proposed methodologies?
Is a trial phase an appropriate next step for testing and refining the proposed methodologies? - Trial phase
but need to set a strict time limit for the trials.
Is the list of attributes and features to be tested correct?
Would you like to be involved in a trial (noting an affirmative response will not guarantee participation)?
Would you like to be involved in a trial (noting an affirmative response will not guarantee participation)?
thyssenkrupp wuld offer industry and chemical process production expertise in setting emissions standard for the value chain.
What reporting frequency should be adopted for trials to deliver learnings and results quickly?
monthly
Submission - File for publishing
Submission - File for publishing
