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Brickworks Building Products Pty Ltd
ABN 63 119 059 513
L9, 60 Carrington St
Sydney NSW 2000
info@brickworks.com.au
www.brickworks.com.au
11th April 2025
Department of Climate Change, Energy, the Environment and Water
Re: National Greenhouse and Energy Reporting (NGER) scheme - 2025 Public
Consultation
Brickworks Building Products Pty Ltd (“Brickworks”) welcomes the opportunity to comment on the 2025 public consultation paper for the National Greenhouse and Energy Reporting
(NGER) scheme.
Brickworks is Australia's leading domestic manufacturer of building products. Our building products are essential to constructing new homes and addressing housing affordability.
Brick manufacturing is a hard-to-abate sector as it requires a very high heat process. We consume up to 3 PJ of natural gas each year in Australia, which is used to fire bricks at over 1,000 degrees Celsius. We support injecting and blending biomethane into the gas network as a decarbonisation pathway for hard-to-abate large gas users.
We support the Department’s proposal to introduce NGER market-based reporting arrangements for scope 1 emission reductions for grid-injected renewable gas.
We thank the Department for the support it has provided the working group, which co- developed the proposed framework to allow gas users to be recognised by the Federal
Government for purchasing grid-injected biomethane and hydrogen.
We recommend removing the proposed temporal link requirement, which requires renewable gas to be injected into the natural gas network within the same NGER reporting year in which its attributes are claimed. A temporal link is not utilised under the NGER scope 2 market-based reporting for determining eligible RECs for renewable electricity purchases. Furthermore, we are concerned that the proposed temporal link requirement will result in the unexpected forfeiture of GreenPower Renewable Gas Guarantee of Origin
(RGGO) certificates when they are unable to be created, transferred and surrendered
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Brickworks Building Products Pty Ltd
ABN 63 119 059 513
L9, 60 Carrington St
Sydney NSW 2000
info@brickworks.com.au
www.brickworks.com.au within the proposed period between the end of the financial year and the NGER reporting date. There are numerous reasons why RGGO certificates may not be created by
Greenpower, transferred from producers to retailers and/or large gas users and surrendered within the proposed timeframe, particularly for renewable gas produced late in the financial year. If RGGO certificate creation or transfers were unexpectedly delayed until after the NGER reporting date, the proposed NGER rules would make these certificates unusable, despite the renewable gas being produced and an actual emission reduction occurring.
The proposed temporal link requirement creates circumstances where actual emission reductions from renewable gas won't be reportable under the NGER scheme. We believe this is an unintended consequence of the proposed temporal link requirement, and we suggest aligning the NGER market-based reporting framework to the GreenPower
Renewable Gas Certification Rules (GreenPower Rules). Alignment with GreenPower
Rules would allow any valid RGGO certificate to be surrendered and recognised under the
NGER scheme, which we believe is a practical and robust way forward. GreenPower Rules state that RGGO certificates remain valid for three years and three months from the first day of the last month that the renewable gas was produced. Aligning with GreenPower
Rules would facilitate flexible, market-aligned decarbonisation reporting without compromising emission reporting integrity. We suggest that any valid RGGO certificate should be eligible for surrender and reporting under NGER if it is within the GreenPower
Rules validity period at the time of surrender before the NGER reporting date.
We also suggest removing the proposed application of a loss factor to RGGO certificates, which effectively reduces the amount of renewable gas that may be reported as consumed by a facility. Gas network unaccounted for losses are fugitive emissions that are already reportable by the gas network operator under existing NGER rules. Gas retailers and users are not responsible for supplying gas to gas distribution networks for their unaccounted losses. As gas distribution networks are responsible for purchasing gas to offset their unaccounted for losses, and are responsible for reporting their fugitive emissions under the NGER scheme, applying a loss factor to renewable gas purchases results in double counting these losses. For example, the proposed loss factor for biomethane of 1%
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Brickworks Building Products Pty Ltd
ABN 63 119 059 513
L9, 60 Carrington St
Sydney NSW 2000
info@brickworks.com.au
www.brickworks.com.au requires a large gas user to purchase biomethane volumes that are more than 100% of its gas needs to have sufficient GreenPower RGGO certificates to report a 100% renewable gas purchase under the proposed NGER framework. This would require physically selling the excess biomethane to a gas trading market since it is not consumed by the large gas user’s facility. The proposed loss factors are misaligned with how gas retailers and large gas users buy natural gas in the wholesale gas markets. The proposed biomethane loss factor has an unintended consequence that 1% of all GreenPower RGGO certificates will never be recognised as a scope 1 emission reduction under the NGER scheme. To avoid double counting fugitive pipeline emissions, the proposed loss factor adjustment should be removed from the market-based reporting arrangements for biomethane and hydrogen.
While we strongly support the proposed NGER market-based reporting arrangements for biomethane and hydrogen, we suggest removing the temporal link requirement, aligning with GreenPower Rules for RGGO certificate expiry, and removing the loss factor adjustment. We believe these improvements will avoid any unintended consequences from the NGER market-based reporting arrangements for biomethane and hydrogen without compromising the integrity of reporting scope 1 emissions reductions.
Brickworks is a member of Bioenergy Australia, and we support its submission to the consultation paper. Please do not hesitate to contact me to discuss the issues raised in this submission further.
Yours sincerely,
Melissa Perrow
General Manager Energy
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