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Do you have any additional feedback in relation to PGO rules (Parts 1-3 of the exposure draft) discussed in the consultation paper that you haven’t already provided?
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Do you have any feedback on the further policy considerations for REGO outlined in the consultation paper?
Do you have any additional feedback in relation to REGO rules or policy considerations discussed in the consultation paper that you haven’t already provided?
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Level 8, 77 Castlereagh Street
Sydney, NSW 2022
atco.com.au
27 March 2025
The Department of Climate Change, Energy, Environment and Water (DCCEEW)
GuaranteeOfOrigin@dcceew.gov.au via Consultation Hub
To the Guarantee of Origin and Trade team,
Re: Consultation on Exposure Draft (Tranche 1) - Future Made in Australia (Guarantee of Origin)
Rules 2025
Thank you for the opportunity to provide feedback on the Guarantee of Origin (GO) exposure draft rules.
ATCO recognises the importance of the GO scheme to support the development of new products differentiated by their origins and emission impact, and appreciates the work undertaken by DCCEEW to progress the scheme.
ATCO is one of the few producers of renewable hydrogen in Australia. We have closely followed the development of the GO scheme and actively participated in workshops and trials run by the Clean Energy
Regulator to provide feedback on the availability of potential data and test the robustness of accounting methods for the scheme. Implementation of the GO scheme will provide our consumers with the confidence to differentiate products produced through lower emission production methods compared to traditional emission intensive approaches.
The key points this submission conveys are:
1. Prioritise the development of new methodology determination to incorporate
biomethane into the GO scheme.
2. Inclusion of timestamping information on certificates can enable efficiencies for
producers across domestic and international schemes.
3. Flexibility on certificate content would further strengthen compliance with
international schemes, leading to the creation of certificates for export purposes.
4. Clarify the CER’s ‘own initiative’ when transferring profiles (clause 18).
ATCO understands that while the GO scheme will commence with hydrogen, there are plans underway to extend the GO scheme to other products, including biomethane and low carbon liquid fuels. The consultation paper indicates that methodology determinations will need to be made for these products. In this regard, ATCO requests that alongside methodology determination for hydrogen production from electrolysis, biomethane should also be prioritised for incorporation into the GO scheme. Biomethane is a proven technology and as a product that is already in use, the ability to verify the emission impact will help to differentiate and develop the market for these lower emission products.
ATCO Australia Pty Ltd | ACN 74 091 033 546 | Registered Office: Level 12, 2 Mill St Perth 6000
ATCO is supportive of the timestamping requirements in clause 20, which will provide precise information on certificates to allow producers to satisfy international and domestic requirements. The ability to meet global certification requirements will be necessary for projects planning to supply export markets. For example, a market assessment of Germany for ATCO’s ScaleH2 project, a large-scale hydrogen production and ammonia export project, identified three factors to comply with the definition of “renewable” for the supply of hydrogen. These factors include additionality considering the age of renewable generation, temporal correlation considering the time of generation and geographic correlation considering the location of generation. The ability to validate this information from GO certification will be needed to meet global customer requirements and supply hydrogen to European markets.
ATCO also supports the scheme in providing flexibility for producers to input information that may be necessary for complying with international schemes for export. This would increase efficiencies across schemes, both domestic and international, and reduce administrative burden for producers. ATCO notes that the provision (particularly paragraph 20(1)(h)) would allow producers to create certificates for export and that these certificates can have information specific to the export market. This will amplify the value of the certificate’s relevance internationally instead of being confined to Australia.
Lastly, ATCO seeks clarification in relation to clause 18 in part 3 of the draft rules regarding transfer of profiles. Subclauses 18(1) and 18(4) refer to the Clean Energy Regulator’s ‘own initiative.’ It is presently unclear and not defined in the draft rules what the CER’s own initiative means and the circumstances in which the Regulator would take such action. While the CER’s role in administering the scheme is understood, the rationale behind this provision in relation to profile transfers is not evident.
We thank DCCEEW again for the opportunity to make a submission. If you have any questions or would like to discuss any of the comments made in this submission, please contact myself or General
Manager – Renewables and Storage
Yours sincerely,
Executive General Manager – Strategy, Technology and Corporate Affairs.
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