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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?
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?
GreenPower agrees this is a good starting point but calls for a national approach for all renewable gasses. GreenPower’s Renewable Gas Certification Pilot will inform consideration of GO schemes for biomethane and we look forward to working with DISER on its integration with the hydrogen GO scheme.
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.
GreenPower agrees with this initial approach. Fugitive emissions and process losses will need to be considered appropriately.
Is hydrogen production at a pressure of 3MPa and 99% purity appropriate conditions for measuring the emissions associated with hydrogen?
No comment.
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).
Biomethane SMR should be include in the first phase of the GO scheme as this provides a relatively low-cost production pathway for renewable hydrogen. GreenPower’s Renewable Gas Certification Pilot may provide an effective pathway for this.
Do you agree that ISO standards and the GHG protocol provide the appropriate basis for the overarching framework for a hydrogen 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?
Should IPCC Guidelines, the NGERS determination and the Climate Active Electricity Accounting rules be leveraged to provide guidance on the detailed emissions calculations?
Recent adoption of the GHG Protocol Guidance by Climate Active is a positive development towards national consistency among schemes and programs. However, there is some inconsistency where reporting entities can mix location- and market-based methods, and these should be resolved or avoided in the GO scheme.
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?
Excluding offsets will maximise transparency and comparability on the emissions associated with production.
GreenPower’s position is that this also best aligns with the GHG Protocol, which notes that emissions should be avoided where suitable alternatives exist. Gross carbon emissions should be reported by the end-consumer, who can then offset their total emissions.
This ensures consumers have full visibility of the emissions associated with a product (e.g. carbon offset electricity products don’t provide this visibility and should be avoided).
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?
Industry should play an important role in informing the development of the scheme. Continuous representation, such as through technical working groups or steering groups would ensure the scheme remains effective and responds to market changes.
Do you support the creation of Australia’s hydrogen GO scheme as a certificate scheme?
What would you consider to be the best regulatory framework to support hydrogen Guarantee of Origin scheme?
GreenPower recommends that the regulatory framework should fully align with international guidance. GreenPower notes that NGER, the current regulatory framework, does not currently fully align with international guidance.
To align with international guidance, new legislation could be implemented and specify that the environmental attribute of the renewable energy is contained in the certificate. This would avoid double counting issues like they currently exist with LGCs. GreenPower encourages legislation that comprehensively addresses the above points and calls for DISER to carefully consider whether implementation through existing legislation is appropriate.
How frequently do you consider hydrogen GO certificate creation will be required?
No comment.
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?
This should be carefully considered as some parameters may change frequently, especially for additional production processes, such as for hydrogen from biomethane. Others can be assessed annually or only once at the ‘accreditation’ stage of the production facility.
An appropriate hybrid approach may be a list for each technology/feedstock combination, which determines what and how frequently reporting needs to be done for each parameter.
For example, the emissions intensity of biomethane production could vary over the year depending on the technology used, the production process and feedstock available. Biomethane would therefore need to be checked more regularly.
Do you agree with the approach set out for scope 1 emissions?
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?
GreenPower agrees with the use of the market-based method because it recognises voluntary action and recognises that Australia operates a national market for Renewable Energy Certificates (RECs).
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?
It is GreenPower’s position that any emissions associated with electricity use and consumption (Scope 2) emissions should be matched with the purchase and surrender of renewable energy certificates. GreenPower considers this best practice. Matching emissions with the surrender of renewable electricity certificates will ensure no additional emissions are added to the atmosphere in the first place, there is a clear and transparent link to the environmental benefit and this avoids double counting of environmental attributes.
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?
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?
Hydrogen produced from electricity with matched Renewable Energy Certificates should be considered as being produced from renewable energy sources, with resulting minimal or zero carbon emissions. The market-based method enables hydrogen producers to achieve 100% renewable energy use, whereas the location-based method does not.
Do you agree that a means of identifying consumption of below-LRET-baseline renewable electricity generation would be beneficial for the hydrogen certification scheme?
Do you agree that a means of identifying consumption of below-LRET-baseline renewable electricity generation would be beneficial for the hydrogen certification scheme?
Recognition of below baseline generation as renewable for the purposes of hydrogen production would ensure consistent treatment of all renewable energy generation. However, the GO scheme should ensure effective integration with voluntary hydrogen programs so that hydrogen consumers can choose to purchase hydrogen made using new or additional renewable electricity capacity.
What are your views on establishing a new renewable guarantee-of-origin certificate for verifying below-baseline and post-2030 renewable electricity?
What are your views on establishing a new renewable guarantee-of-origin certificate for verifying below-baseline and post-2030 renewable electricity?
See page 6 of our submission for a detailed discussion on this under the heading 'a holistic approach to renewable electricity certification now and post-2030 will enable consistent carbon reporting and successful voluntary markets'.
What would be the effect of having a general certification scheme for renewable electricity?
See page 6 of our submission for a detailed discussion on this under the heading 'a holistic approach to renewable electricity certification now and post-2030 will enable consistent carbon reporting and successful voluntary markets'.
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 certification should recognise other sources of renewable electricity, including those outlined outlined in Section 3.5.1?
The outlined approach seems thorough and takes into account recent and future developments such as the ACT surrendering LGCs on behalf of all consumers in the jurisdiction. GreenPower welcomes this approach as it would support voluntary markets and consumer choice. Any GO certificates to be considered under the GreenPower scheme may have to meet additional requirements to be in line with the program’s objectives. To enable this, the GO certificates should include information about whether the generator is GreenPower accredited.
Do you agree that emissions should be attributed to co-products where they are on-sold?
Do you agree that emissions should be attributed to co-products where they are on-sold?
No comment.
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?)
No comment.
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?
No comment
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?
No comment.
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?
A materiality threshold could be beneficial however this should not reset, meaning that the threshold applies to a baseline and any changes over multiple years are added up. E.g. if the emissions change 2% every year, the threshold would be crossed in the third year.
What would you consider to be an appropriate threshold?
No comment.
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
This would align with GreenPower’s Renewable Gas Certification Pilot that is currently under development.
Is the list of attributes and features to be tested correct?
Is the list of attributes and features to be tested correct?
Integration with biomethane certification and how the GO scheme can enable a voluntary renewable hydrogen market.
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)?
GreenPower would welcome collaboration on hydrogen certification trials both through its Renewable Gas Certification Pilot and for green hydrogen certification for voluntary markets. Several project proponents have expressed interest in exploring certification trials including to produce renewable hydrogen and biomethane.
What reporting frequency should be adopted for trials to deliver learnings and results quickly?
Quarterly reporting would enable frequent project adjustments and delivery of findings for a GO scheme delivery in the coming 1-2 years.
Submission - submission2
Submission - General comment
Thank you for the opportunity to make a submission.
GreenPower welcomes further collaboration with DISER in the renewable energy space.
Kind regards,
The GreenPower team
Submission - File for publishing
Submission - File for publishing
