Low Emission Technology Australia
6 Aug 2021

Published name

Low Emission Technology Australia

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?

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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?

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Is hydrogen production at a pressure of 3MPa and 99% purity appropriate conditions for measuring the emissions associated with hydrogen?

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Is hydrogen production at a pressure of 3MPa and 99% purity appropriate conditions for measuring the emissions associated with hydrogen?

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Do you agree that ISO standards and the GHG protocol provide the appropriate basis for the overarching framework for a hydrogen GO scheme?

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Should IPCC Guidelines, the NGERS determination and the Climate Active Electricity Accounting rules be leveraged to provide guidance on the detailed emissions calculations?

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What is your preferred approach to offset inclusion within a domestic hydrogen GO scheme?

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Do you agree that the Australian government should lead the administration of an Australian GO scheme?

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Do you agree that the scheme should be administered by the Clean Energy Regulator?

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Do you support the creation of Australia’s hydrogen GO scheme as a certificate scheme?

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How frequently should data be reported; Is the proposed 12 month period adequate?

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Do you agree with the approach set out for scope 1 emissions?

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Do you agree with the approach set out for upstream emissions?

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Do you agree that the calculation of electricity (scope 2) emissions should be based on the market-based method?

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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?

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Do you agree that a means of identifying consumption of below-LRET-baseline renewable electricity generation would be beneficial for the hydrogen certification scheme?

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What are your views on establishing a new renewable guarantee-of-origin certificate for verifying below-baseline and post-2030 renewable electricity?

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Do you agree that certification should recognise other sources of renewable electricity, including those outlined outlined in Section 3.5.1?

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Do you agree that emissions should be attributed to co-products where they are on-sold?

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Are the by-products identified for each pathway likely to be co-products (or are they more likely to be waste products?)

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Do you think that the allocation methods suggested in each pathway are appropriate and practical?

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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?

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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?

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Is a trial phase an appropriate next step for testing and refining the proposed methodologies?

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Is the list of attributes and features to be tested correct?

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Would you like to be involved in a trial (noting an affirmative response will not guarantee participation)?

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Submission - File for publishing

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Submission - File for publishing

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