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27 March 2025
Guarantee of Origin and Trade Section
Department of Climate Change, Energy
the Environment and Water
Submitted via email: GuaranteeofOrigin@dcceew.gov.au
Dear Guarantee of Origin and Trade Section,
Submission: Exposure Draft of the Guarantee of Origin Rules 2025
CS Energy welcomes the opportunity to provide a submission to the Exposure Draft of the
Guarantee of Origin Rules released for consultation on 28 February 2025.
About CS Energy
CS Energy is a Queensland-owned and based energy company that provides power to
some of the state’s biggest industries and employers. We generate and sell electricity in the
wholesale and retail markets, and we employ almost 700 people who live and work in the
regions where we operate.
CS Energy owns thermal power generation assets, and we are building a more diverse
portfolio that includes renewable energy, battery storage, hydrogen-ready gas fired
generation and pumped hydro.
We also have a renewable energy offtakes portfolio of almost 300 megawatts, which we
supply to our large commercial and industrial customers in Queensland.
Overall views
CS Energy supports the introduction of a Guarantee of Origin (GO) scheme for tracking and
verifying the emissions of clean energy products and supporting the voluntary use of
renewable energy. This submission focuses on the first Exposure Draft of the GO Rules,
which covers the administrative aspects of the scheme, profile registration, certification and
the role of the regulator.
It is critical that these foundations are appropriately developed to ensure that participants
are informed and regulated in a way that best reflects the objectives of the scheme. Upon
review, the following key points were identified:
Brisbane Office Callide Power Station Kogan Creek Power Station
PO Box 2227 PO Box 392 PO Box 41
Fortitude Valley BC Qld 4006 Biloela Qld 4715 Brigalow Qld 4412
Phone 07 3854 7777 Phone 07 4992 9329 Phone 07 4665 2500
Fax 07 3854 7300 Fax 07 4992 9328 Fax 07 4665 2599
CS Energy Ltd ABN 54 078 848 745 www.csenergy.com.au
CS Energy Limited submission to Exposure Draft of the Guarantee of Origin Rules 2025
• CS Energy considers that, so long as an applicant’s proprietary production processes
do not impede their ability to report their emissions, they should not be required to
publicly share said processes. A requirement to publicly share proprietary processes
without adequate basis will likely deter producers who employ these processes from
participating in the scheme; and
• It is unclear how the regulator would exercise its discretionary powers over decision
making, including:
o Deciding whether to cancel or suspend a profile registration;
o Deciding whether to transfer profile ownership;
o Deciding whether it is practicable to seek consent to transfer ownership; and
o The ability to consider any other information, other than that prescribed by the
rules, that it deems relevant when making decisions.
To provide greater clarity and certainty, CS Energy proposes that a set of transparent criteria be developed for regulatory decision making and enforcement.
Proprietary Technology Protections
When discussing clause 12 (production profile registration) in the consult paper, the point was raised that “If there is no means to report on a process outlined in the methodology
(because it relates to a proprietary equipment…), the regulator may refuse to register the profile”. Further, the Future Made in Australia (Guarantee of Origin) Bill 2024 established that Product GO (PGO) certificates will contain details of the “production pathway specified in the production profile”.
CS Energy agrees that if proprietary processes impede a profile holder’s ability to accurately measure and report their emissions, they may not be fit for participation. However, we are seeking clarification as to whether reporting of proprietary processes or equipment will be publicly shared. CS Energy considers that, so long as an applicant’s proprietary production processes do not impede their ability to report their emissions, they should not be required to publicly share said processes.
If proprietary processes are displayed without adequate basis on PGO certificates, which will be accessible through a public register, this may disincentivise participation in the scheme. Specifically:
• Firms employing such processes may view this requirement as a barrier to entry;
• For those participants who do navigate this hurdle, this notion may deter innovation, for
fear that adoption of new processes may lead to deregistration from the scheme;
• Stifled innovation will reduce competitiveness, production efficiency and product quality;
and
• Ultimately, this may discourage prospective investment in new technologies.
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CS Energy Limited submission to Exposure Draft of the Guarantee of Origin Rules 2025
Regulator Discretion
The discussion around clause 10 in the consult paper states that “whether to suspend or cancel a person’s registration would depend in part on the state of mind formed by the
Regulator in relation to the circumstances”.
CS Energy regards that more consideration is required to distinguish between scenarios where suspension and cancellation may occur. Currently, the regulator must “reasonably believe” an event has occurred for suspension to arise, whereas it must “believe on reasonable grounds” that the event occurred for cancellation. CS Energy finds this language rather ambiguous and, in some regard, synonymous.
Our proposal is that more transparent criteria should be developed to guide the regulator in their decision making. Further, it may be worth exploring the scenarios where regulator intervention is anticipated, to establish what responses are most appropriate.
Similar criteria may be applied to other decision-making areas as well, such as when transferring profile ownership. The regulator has the power to transfer profile ownership at its own initiative but must have regard to “whether it is practicable to seek consent to the transfer from the holder of the profile”. CS Energy considers that in most instances, bar perhaps death or deregistration of a party, consent should be sought from the holder.
Hence, criteria should be developed to guide these decisions.
Closing Remarks
CS Energy looks forward to the opportunity to contribute to future consults regarding the scheme; particularly those relating to Renewable Energy GO certificates, energy storage systems, aggregated systems and retirement of below baseline certificates.
If you would like to discuss this submission, please contact
Yours sincerely
Head of Policy and Regulation
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