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AMPOL LIMITED
29-33 BOURKE RD
ALEXANDRIA NSW 2015
ABN 40 004 201 307
ACN 004 201 307
11 April 2025
Department of Climate Change, Energy, the Environment and Water
GPO Box 3060
Canberra ACT 2601
Submitted via online consultation hub
Response to National Greenhouse and Energy Reporting scheme – 2025 Public Consultation
Introduction
Ampol Limited (Ampol) welcomes the opportunity to provide a submission to the Department of Climate
Change, Energy, the Environment and Water (the Department) on its National Greenhouse and Energy
Reporting (NGER) scheme – 2025 Public Consultation (consultation paper).
Ampol strongly supports the inclusion of co-processed fuels under the National Greenhouse and Energy
Reporting scheme (NGERs). Having advocated for its inclusion in the 2024 NGERs updates public consultation,
Ampol welcomes the acknowledgement of co-processed fuels as part of the forward work program in 2025.
Please see the following submission which outlines specific points of feedback.
About Ampol
As Australia’s leading fuel supplier with over 120 years of operations experience, Ampol recognises the essential role it plays in working with the Government and regulators. Ampol manages Australia’s largest fuel and convenience network as well as refining, importing, and marketing fuels and lubricants. With its extensive experience, Ampol has grown to become the largest transport fuels company listed on the Australian
Securities Exchange.
In Australia, Ampol’s robust supply chain is underpinned by market-leading infrastructure, including 14 terminals, six major pipelines, 53 wet depots, approximately 1,800 retail sites (including over 630 company owned and operated sites), and one refinery located in Lytton, Queensland, which is covered under the
Safeguard Mechanism.
Ampol is transitioning in line with customer demand, technology availability, and an ambition to achieve net zero emissions across its Australian operations (scope 1 and 2 emissions) by 2040, with interim targets also established for 2025 and 2030. Ampol has continued the rollout of its electric vehicle charging bays with 144 charging bays across 59 sites in Australia and 171 charging bays across 53 sites in New Zealand (as at 31
December 2024). Ampol has also commenced importing RD to demonstrate the potential to decarbonise heavy industry and is exploring options to produce advanced biofuels at the Lytton refinery, with the ambition to manufacture RD and RAK toward the end of the decade. We are also considering co-processing opportunities for RD using existing infrastructure which would be available in the market in the short-term.
Feedback
Ampol recognises that the NGER scheme is a key data source which supports Australia’s international and domestic reporting obligations and informs domestic climate and energy policies. Emissions reported under
the NGER scheme underpin the operation of the Safeguard Mechanism, which covers Ampol’s own Lytton refinery based in Brisbane.
As referenced in the consultation paper, the potential recognition of co-processed fuels under the NGER scheme has been included in the Department’s 2025 forward work program. Ampol strongly supports this recognition, as it would enable more accurate reporting of scope 1 emissions from co-processed liquid fuels – a critical step in developing a co-processing industry in Australia.
Inclusion of co-processed fuels builds on the July 2024 NGER scheme amendments, which introduced market- based reporting for scope 1 emissions from the combustion of renewable fuels 1 (RD and RAK) co-mingled with their fossil fuel equivalents and supplied through shared infrastructure. During that consultation, Ampol advocated for additional changes to better reflect the lower emissions benefits of co-processed fuels.
Recognition of co-processed fuel under the NGER scheme would likely support greater uptake of renewable fuels by customers and assist in reducing the national greenhouse gas inventory. In turn, this may support
Ampol’s broader feasibility assessment for a dedicated renewable fuels refinery at Lytton, targeted for commissioning by the end of the decade.
It is critical that co-processed fuels are explicitly referenced under the NGER scheme, rather than merely implied, as they are distinct from blended renewable fuels. Blended fuels are typically produced by blending two or more neat, separately produced and certified fuels to a desired ratio. On the other hand, co-processed fuels are produced by simultaneously processing fossil and biomass-derived feedstocks in the same refining process to produce a single, finished fuel product. An advantage of co-processing is that it leverages existing refinery infrastructure with minimal modifications, making it a practical first step in renewable fuels manufacturing. Globally, over 40 refineries are certified under the International Sustainability and Carbon
Certification (ISCC) scheme as co-processing facilities.
Ampol is actively investigating co-processing of RD at its Lytton refinery by integrating biogenic feedstocks – such as animal fats – into the refining diesel hydrotreating process. Co-processing production is expected to commence by 2027, subject to a final investment decision in 2025. This aligns with Ampol’s broader strategy to develop a renewable fuels industry in Australia. Ampol is already importing and supplying finished RD via isotainers to select B2B customers, and co-processing would help localise a renewable fuels supply chain, which is in service of both onshore energy security and emissions reductions.
Ampol envisages that existing co-processing certification frameworks such as ISCC could be acknowledged under the NGER scheme as proof of renewable diesel production, as these frameworks aim to ensure traceability and robust accounting practices are in place for co-processing facilities. This is a logical extension of the typical market-based accounting approach ratified in the previous NGER scheme amendments.
On a related note, Ampol is supportive of the Department linking the NGER scheme with renewable fuel certifications prioritised for development under the Guarantee of Origin scheme. Ampol understands that this would also include co-processed fuels at the appropriate time. Further, Ampol is committed to working with the Department and the Clean Energy Regulator to ensure the NGER scheme remains fit for purpose, particularly as the transport fuels industry evolves in line with the broader energy transition.
Conclusion
Ampol appreciates the opportunity to provide feedback to the Department on its 2025 NGERs Consultation
Paper. As discussed in the above submission, Ampol is strongly supportive of the inclusion of co-processed fuels under the NGERs emissions accounting framework.
To discuss the response in further detail, please contact Eden Baker, Sustainability and Investor Relations
Manager (eden.baker@ampol.com.au).
1
‘Renewable fuels’ is an industry term used for liquid hydrocarbons made from non-petroleum based renewable feedstocks such as purpose grown biomass, or from waste material such as tallow or used cooking oil. Sustainable aviation fuel (SAF)
– otherwise known as renewable aviation kerosene (RAK) – and renewable diesel (RD) are industry terms used for particular types of renewable fuels.
