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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?
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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27 March 2025
Jemena Limited
ABN 95 052 167 405
Level 16, 567 Collins Street
Melbourne, VIC 3000
PO Box 16182
Melbourne, VIC 3000
T +61 3 9173 7000
F +61 3 9173 7516
www.jemena.com.au
Re: Jemena submission: Future Made in Australia (Guarantee of Origin) Rule 2025 –
Exposure draft (tranche 1)
Jemena welcomes the opportunity to respond to the consultation on the Future Made in Australia (Guarantee of Origin) Rule 2025 Exposure Draft (tranche 1). As the project proponent of Australia’s first biomethane grid- injection facility, Jemena is an industry leader in renewable gas and well placed to provide constructive feedback on the Commonwealth government’s Guarantee of Origin scheme.
Jemena operates a diverse portfolio of energy assets across northern and eastern Australia, including the
Jemena Gas Network in New South Wales, the Jemena Electricity Network in northwest Melbourne, and major gas transmission lines. With over $12 billion in infrastructure, we deliver energy to millions of households, institutions, and industries daily.
As an integrated energy infrastructure and services company, which owns, operates, designs, constructs and maintains both gas and electricity assets, we recognise our responsibility to make changes to how we operate to help Australia meet its net zero emissions targets, while retaining system reliability. We are seeking to address our own emissions to achieve our 2050 net-zero ambition, as well as using existing technologies and supporting the development of new technologies to deliver choice in renewable energy sources.
At Jemena, we see gas as a fuel in transition, not just a transition fuel. Today, Australians – and our trading partners – rely on Australia’s natural gas resources. Tomorrow, this demand for Australian energy is increasingly likely to come in the form of clean energy embodied goods, derived from feedstocks such as biomethane and renewable hydrogen. By displacing increasing amounts of natural gas with these carbon neutral alternatives, we believe that existing gas infrastructure can play a critical role in a more secure and cost effective transition for industry to 2050.
This position was recently endorsed by the Energy and Climate Change Ministerial Council (ECMC) during its meeting in March 2025. During this session, the Commonwealth and State governments committed to investigating a national policy approach for renewable gas, recognizing its essential role in the decarbonisation of hard-to-abate industries.
To demonstrate the potential of renewable gases, Jemena has developed an hydrogen electrolyser project in
Western Sydney and a biomethane injection facility in Malabar (NSW), with support from the Australian
Renewable Energy Agency (ARENA). These are outlined further in the Appendix of our submission.
We welcome the Department’s development of the product guarantee of origin (PGO) scheme, and its initial focus on hydrogen. However, we encourage the Department to prioritise biomethane as the next eligible green commodity under the PGO scheme. As a more cost-competitive and technologically mature renewable gas, biomethane can help reducing industrial emissions today, while hydrogen evolves and becomes more commercial over the long term.
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Key points
Biomethane is a cost-effective decarbonisation option available now and should be included in the
Product GO Scheme from the start to help reduce Australia's emissions, especially for hard-to-electrify
industries.
Jemena recommends that when considering expanding the PGO to include biomethane and low
carbon liquid fuels, the department should prioritise reducing Australian industry emissions over the
export market, as feedstocks are limited and should be used for local needs first.
For more information regarding Jemena’s submission or to arrange a discussion please contact ,
Market Development Manager – Renewable Gas .
Yours sincerely,
General Manager Renewable Gas
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1. Supportive in-principle
The Guarantee of Origin (GO) scheme is crucial because it plays a vital role in supporting the emerging renewable gas industry and helps industry to decarbonise.
We have reviewed the exposure draft of the GO scheme and support its provisions, as well as the Department’s ongoing efforts to facilitate the scheme’s implementation. The GO scheme will duly recognise the financial value of producing renewable gases, while balancing the capability to measure a product’s lifecycle emissions and enabling the tradeability of the renewable characteristics of the product where relevant. The exposure draft includes suitable provisions for the creation and registration of Product GO certificates. Jemena looks forward to further engagement with the Department as it looks to expand the scheme to biomethane.
2. Expand Product GOs to cover biomethane as a matter of priority
We understand that the initial proposal is for the Product GO scheme to include hydrogen only and the
Department is considering expansion to other renewable gases down the line. However, we are concerned by the Department’s comment on page 5 of the consultation paper, which states “The PGO certification stream will commence with hydrogen and expand to other products, such as low carbon liquid fuels and green metals.”
Jemena urges the Department to prioritise expanding the PGO to biomethane over low-carbon liquid fuels
(LCLF) like sustainable aviation fuel. Biomethane is a proven technology that can immediately reduce industrial emissions with proper support.
With recent reforms to the Safeguard Mechanism, many of Australia’s large emitters are seeking low-carbon gas solutions. Jemena's Malabar injection facility shows the technology is available today to replace natural gas. Expanding the PGO to biomethane is a no-regrets policy that can help stimulate the supply required to meet ever increasing demand from industrial customers.
3. Ensure decarbonisation of Australian industry is prioritised over the export
market
Jemena urges the Guarantee of Origin team to prioritise decarbonising Australian industry and end users over the export market when expanding the PGO scheme to biomethane and LCLFs. Without this focus, Australia's limited feedstock may decarbonise international industries instead of local ones.
Current support schemes for LCLF and biomethane are production-focused, aiding PGO creation. However, these certificates might be surrendered to international markets willing to pay more than Australian industries.
Many countries across Asia Pacific are not able to produce sufficient renewable energy, so are looking import.
These international investments could push biomethane and LCLF development towards an export-only market.
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Appendix A - Jemena’s renewable gas projects
Western Sydney Green Hydrogen Hub
The $15 million ARENA co-funded Western Sydney Green Hydrogen Hub is a demonstration project which includes a 500kW electrolyser (to produce green hydrogen using renewably sourced electricity from the grid), a 335-metre buffer pipeline (to demonstrate green hydrogen storage in the gas network), a hydrogen injection panel (which is blending to 2% green hydrogen into the Jemena gas network) and power generation equipment (to test the production of electricity using hydrogen). The project demonstrates the potential to store renewable energy as green hydrogen using a dedicated hydrogen pipeline. This green hydrogen can then be blended into the gas network or produce electricity utilising the onsite fuel cell and microturbine for export into the national electricity grid.
Malabar Biomethane Demonstration Project
Our Malabar Biomethane Demonstration Project, a partnership with Sydney Water, began converting biogas from Sydney Water’s largest wastewater plant to biomethane as part of Australia’s first biomethane network injection project in June 2023. The ARENA co-funded project is injecting high-quality biomethane gas from Jemena’s gas upgrader facility directly into Jemena’s New South
Wales distribution network. The project has an initial capacity of 95 terajoules of renewable gas per annum. This is about equivalent to the average annual gas usage of 6,300 NSW homes.
In March 2023 Jemena took another significant step in the activation of an Australian renewable gas market, by signing an agreement with retailer Origin Energy for the sale and purchase of gas produced at the Malabar Biomethane Demonstration Project.
In August 2023 the NSW Government’s GreenPower launched their renewable gas certification pilot to help commercial and industrial gas users directly support renewable gas projects and reduce emissions from energy use. Jemena is very pleased that the Malabar Biomethane Injection Plant, which is scheduled to become the first renewable gas facility registered under the certification, is helping to build a voluntary market for renewable gases.
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