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10 April 2025
Consultation response:
National Greenhouse and Energy Reporting (NGER) Scheme
ACT Group is a leading global provider of market-based sustainability solutions, helping our
9000+ clients achieve their climate goals in over 75 countries.
Founded in 2009, we have a team of 500 globally based experts working across 7 offices in
Amsterdam, London, Paris, New York, Shanghai, Tokyo, and Singapore. We empower our clients’ decarbonization process through a suite of 200+ innovative solutions, ranging from energy attribute certificates for renewable electricity, biomethane, hydrogen, and SAF to carbon credits, emissions allowances, energy efficiency, responsible agriculture, and digital decarbonization platform.
In 2024, our global portfolio includes, but not limited to, 3 TWh of market-based biomethane, 169
TWh of market-based renewable electricity, 1.9 TWh of energy efficiency project development, and 8 million tCO2e emissions abatement solutions. For overall Biomethane portfolio, we have provided our clients with a total of 16 TWh of biomethane since our market inception in 2009.
In Australia, we are working with companies from different sectors such as mining, manufacturing, retail, and the financial service industry. These companies can be large RE100 members and smaller local companies whom we are helping with not only access to local
Australian products such as LGCs and ACCUs but also supplying them with products for their activities abroad such as international EAC's (I-REC, REC, GoO, REGO etc.), biomethane and carbon project development.
For further reference, please visit our website at https://www.actgroup.com
The introduction of market-based reporting of emissions from consumption of biomethane and hydrogen
In this submission, ACT Group focuses on the market-based reporting from consumption of biomethane and hydrogen. As part of our global sustainability solutions, we believe renewable gas – biomethane and hydrogen – can play a key role in Australia’s decarbonization journey towards a climate neutral energy system.
• Mandatory, certificate-backed approach
ACT Group believes the certificate-backed approach, i.e. completion or retirement of an
eligible renewable gas certificate by an NGER scheme reporter, or on their behalf, will
enable a full and exclusive claim of the scope 1 emissions attributes of the renewable gas
represented by the certificate and help prevent multiple accounting of the same
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renewable gas molecule by other entities. We also support the recognition of both RGGO
and PGO under the NGER scheme. This approach is well-known by companies who have
operations in more mature renewable gas markets such as European Union and United
Kingdom, which would help provide a common understanding for companies in Australia.
However, we suggest the certificate recognized by NGER scheme should contain all the
required information that is relevant to scope 1 emissions accounting, for instance, not
limited to, CO2-eq emissions value of the corresponding renewable gas and the amount
of renewable gas volume per type of feedstock.
• Temporal link requirement
ACT Group believes the temporal link requirement is necessary to help maximise the
accuracy and comparability of NGER scheme data by ensuring scope 1 emissions
reported by a facility for a reporting year represent emissions that occurred in that
specific year, not in an earlier or later period. The temporal link requirement is well-known
by companies who have operations in more mature renewable gas markets such as
European Union and United Kingdom, which would help provide a common
understanding for companies in Australia.
• Reasonable physical link requirement
ACT Group believes the reasonable physical link requirement is needed to support the
high-integrity, traceable claims to the Scope 1 emissions attributes of individual
renewable gas consignments, in particular when traceability is entailed by the
consumption of renewable gas delivered from a common gas grid. However, the NGER
scheme should provide a comprehensible meaning of the word “reasonable” so as to give
all NGER scheme reporters a common definition of the boundary of this requirement. In
this case, we support the gas grid physical interconnection as the basis of the physical
link boundary (i.e. East Coast Gas Market separated from the Western Australia Gas
Market). The reasonable physical link requirement is well-known by companies who have
operations in more mature renewable gas markets such as European Union and United
Kingdom, which would help provide a common understanding for companies in Australia.
On the other hand, as food for thought, facilitating book and claim style reporting within
the national boundary as a single market could also be a beneficial option in encouraging
a more rapid adoption of renewable gas in the early phase of the scheme. However, this
approach might require a more coordinated, transferrable tracking system between the
gas network operators to avoid double counting where the renewable gas supply is not
physically interconnected to the end-user.
• Biomethane displacement ACCU requirement
ACT Group supports the biomethane displacement ACCU requirement to help limit the
risk of greenwashing and multiple accounting of environmental attributes from the same
biomethane production activity.
• Accounting for pipeline losses
ACT Group supports the accounting for pipeline losses with a loss factor of 1% for
biomethane and 0.9% for hydrogen. Considering that the loss factor is based on an
average of the unaccounted-for-gas percentages for each state and territory, we believe
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this loss factor would help provide a fair accounting of the corresponding renewable gas
delivered from a common gas grid while maintaining the flexibility of market-based
reporting for the consumption of biomethane.
ACT Group is pleased to provide our feedback and suggestions in the Public Consultation on
2025 Updates to the National Greenhouse and Energy Reporting (NGER) Scheme. We support the NGER’s proposed amendments on the market-based reporting of emissions from consumption of renewable gas and welcome the opportunity to participate in further discussions.
Thank you for taking the time to consider our submission. Any questions about this submission, please contact Hilman Dwi Putra, Lead Biomethane Asia Pacific, hputra@actcommodities.com
Yours sincerely,
John Davis
Managing Director, APAC
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