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Bioenergy Australia (Forum) Pty Ltd
ABN 14 155 856 821
Bioenergy Australia Submission: Future Made in Australia (Guarantee of Origin) Rules 2025 - Exposure
draft (tranche 1)
Bioenergy Australia (BA) is the national industry association committed to accelerating Australia’s bio economy. Our mission is to foster the bioenergy sector to generate jobs, secure investment, maximise the value of local resources, minimise waste and environmental impact, and develop and promote national bioenergy expertise into international markets.
This submission from Bioenergy Australia is on behalf of the Renewable Gas Alliance (RGA) and The
Low Carbon Fuels Alliance of Australia and New Zealand (LCFAANZ). These alliances were founded to accelerate the development and deployment of Low Carbon Liquid Fuels (LCLF) and Renewable Gas, in
Australia. Individual members of the alliances will be providing more detailed submissions specific to their business and expertise.
Australia’s Bioenergy Roadmap (ARENA, November 2021) outlines how, by the start of the next decade, Australia’s bioenergy sector could contribute to around $10 billion in extra GDP per annum and 26,200 new jobs (predominately regional), reduce emissions by about 9 per cent, divert an extra
6 per cent of waste from landfill, and enhance fuel security. Now is the time to capitalise on these opportunities by prioritising support for low carbon liquid fuels and biomethane within the Guarantee of Origin Scheme.
Bioenergy Australia thanks the Department for the opportunity to provide feedback on the
Consultation paper: Exposure draft (tranche 1) – Future Made in Australia (Guarantee of Origin) Rules
2025. We welcome the development of the GO Scheme and believe its introduction will be a significant lever in unlocking Australia’s renewable energy market.
Product Prioritisation in the GO Scheme
On page 5 of the consultation paper, it states “The PGO certification stream will commence with hydrogen and expand to other products, such as low carbon liquid fuels and green metals.”
We encourage the Department to specifically reference “biomethane and biogas” noting that these products have been explicitly committed to by the Government1 and we understand that efforts are already underway to develop a GO methodology for biomethane. Given that these are nascent industries, consistent and clear support is critical for fostering market growth and boosting investor confidence.
Furthermore, as mentioned in previous submissions, we query the Government’s approach to product prioritisation under the GO Scheme.
1
Guarantee of Origin key to superpower status | Ministers
Low carbon liquid fuels and biomethane are proven technologies that are already being produced and adopted globally. These products are immediately compatible with existing infrastructure and assets and can serve as drop-in replacements for current fossil fuel products and natural gas. With increasing demand for these products both domestically and internationally, and projects in active development, these products will be key contributors to Australia’s renewable energy market.
Given the widespread recognition of the readiness, availability, and feasibility of low carbon fuels and biomethane, we recommend fast-tracking their inclusion in the GO Scheme.
We believe it’s important that method development for hydrogen does not impact the timeline for these other products and recognise that work on hydrogen may also help inform the development of methodologies for low carbon liquid fuels and biomethane. We encourage the department to progress the development of low carbon liquid fuels and biomethane within the GO Scheme alongside hydrogen.
Clause 28 Definition
We propose the definition of ‘agricultural waste’ in clause 28 be expanded to explicitly include agricultural residues. Limiting the definition to ‘waste’ may have the potential to exclude a wide range of potential agricultural resources for being used for higher value as part of the GO Scheme and unnecessarily limiting market development.
PGO Certificates
While we strongly support the development of the Guarantee of Origin (GO) Scheme, it is essential that the Scheme is designed to effectively support the growth of emerging markets. A key consideration is ensuring that Product Guarantee of Origin (PGO) certificates are fit-for-purpose to support low carbon liquid fuels and biomethane. We make the following comments:
• We emphasise the importance of the PGO certificates integrate with the NGER scheme for
Scope 1 emissions reporting and reduction claims. This interoperability is critical for the
development of the low carbon liquid fuels and renewable gas market in Australia and
recommends the Rules explicitly address alignment between the schemes to ensure
consistency in definitions, methodologies, and reporting requirements.
• Section 51(5) of the GO Act explicitly allows PGO certificates to reference REGO certificates
used as inputs to production. However, we seek clarification on whether the same applies in
reverse—specifically, whether renewable gases represented by PGOs can be recognised when
used to generate electricity, resulting in REGOs. We believe this clarification is important to
reinforce the role of renewable gases such as hydrogen and biomethane in supporting
electricity system reliability, for example, by supplying renewable gas to existing gas-fired
power stations. This bidirectional interoperability is critical to maximising the value of
renewable gases within an integrated energy system.
Connection with HPTI
Hydrogen can be a key input into various forms of low carbon fuel production. We note that some of our members have raised concerns about whether facilities that produce and consume green hydrogen on-site under the same ownership would qualify for GO certificates and, in turn, the
Hydrogen Production Tax Incentive (HPTI). Further clarification on this would be appreciated.
The development of the GO Scheme and the inclusion of low carbon liquid fuels and biomethane represent a significant step in advancing Australia's net-zero ambitions. This move will not only attract critical investment for project development and expansion, incentivize their use to reduce emissions, and reinforce customer confidence in the value of these products, but also demonstrate the
Australian Government's commitment to achieving its emissions reduction objectives.
Thank you for taking the time to consider our submission. Any questions or request for further assistance are welcome and can be directed to .
Sincerely,
CEO Bioenergy Australia
