Published name
Please provide any comments in relation to these provisions (clauses 1-6).
- ‘Clause 6, meaning of related scheme’ - an issue relevant to below-baseline facilities will be the ability for a single renewable facility (e.g. an existing pre-1997 hydropower station) to create both Large-scale Generation Certificates and REGOs in the same year. While it is critical that the same MWh of renewable energy cannot create two certificates (double counting), it is appropriate that pre-1997 stations can create both LGCs for above-baseline and REGOs for below-baseline in the same year.
- As Hydro Tasmania understands it, Clause 36 would require notification that a REGO facility was also a participant in a related scheme (the RET).
- The CER must ensure that creation of LGCs and REGOs can occur concurrently and without unnecessary complexity. For example, a single Electricity Generation Return (EGR) would be the most appropriate approach, or failing this, the two administered schemes should be able to draw from the same provision of data to the CER.
Please provide any comments in relation to these provisions.
- It is not immediately clear to Hydro Tasmania from the consultation document, whether the registration process for a renewable power station creating REGOs will be more substantial than the current arrangements under the RET (including requirements around metering).
- The desire to have a consistent approach across PGOs and REGOs is understandable given their different but related aims.
- Where there are differences between the registration processes for PGO and REGO facilities it would help stakeholders if this was made clearer in future accompanying documentation.
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?
Please provide any comments in relation to these provisions.
- Hydro Tasmania supports utilising a streamlined application process for power stations already accredited under the REE Act.
- It is not clear why is there no clause 29?
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?
Please provide comments.
Regarding the treatment of below-baseline certificates Hydro Tasmania would like to make the following comments:
- We look forward to participating in consultation around below-baseline rules.
- The consultation paper reflects the policy decisions laid out in section 108 of the GO Act.
- The decision to limit retirement of below-baseline certificates to within 18 months of generation of the electricity they represent is appropriate, however, Hydro Tasmania strongly believes this should be the case for retirement of all REGOs. The rationale for this is the REGO scheme is about attribution of renewable generation to customers. It makes little (or no) sense to suggest that an electricity user in 2033 is using renewable electricity from 2031. There was no need for such a restriction in the RET as banking and even borrowing of certificates was a beneficial mechanism to lower costs for consumers and reduce the overall consumer impacts of the RET. This rationale does not apply in an attribution scheme.
With respect to other schemes:
- RE100 requires that the certificate, “must be reasonably close in time to the period over which a claim to use of renewable electricity is made”. However, “reasonably close” is not defined.
- ‘Green-e’ has a requirement for a 21-month vintage eligibility window.
- Climate Active requires LGCs within three years.
- EUR-Lex Article 6 requires time matching and states that: “From 1 January 2030, the temporal correlation condition shall be considered complied with if the renewable liquid and gaseous transport fuel of non-biological origin is produced during the same one-hour period as the renewable electricity produced”.
- GHG Protocol has criteria that seeks to, “ensure that the generation on which the emission factors are based occurs close in time to the reporting period”. Though once again, any vintage limitation does not appear to be specified.
Given that DCCEEW has already established an 18 month requirement for below-baseline REGOs, Hydro Tasmania strongly believes this should be extended to all REGO generators and replicated in requirements for PGOs.
In Hydro Tasmania’s September 2024 submission to the Senate Standing Committee reviewing the Future Made in Australia (Guarantee of Origin) Bill 2024 we stated:
- “In our discussions with DCCEEW, Hydro Tasmania has proposed that all REGOs must be surrendered within 18 months of generation. Our continuing view is that this should apply to all REGOs, not just below-baseline REGOs as the current Bill drafting appears to imply (by including this clause in Section 108 not in Section 107).
- This is because the REGO scheme is about attribution and not about compliance with a mandatory GWh target (as the RET has been).
- Banking REGOs from any generation source or ‘attributing’ electricity from greater than 18 months prior to its use is inconsistent with the aims of the REGO and Guarantee of Origin frameworks. As further evidence, using REGOs in National Greenhouse and Energy Reporting (NGER) would be negatively impacted if REGOs can be banked as it would distort the calculation of the Residual Mix Factor used under the market-based method.”
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27 March 2025
Department of Climate Change, Energy, the Environment and Water (DCCEEW)
Lodged via the DCCEEW website: https://consult.dcceew.gov.au/tranche-1-exposure-draft-guarantee-of-origin-rules
Dear DCCEEW,
Exposure draft (tranche 1) – Future Made in Australia (Guarantee of Origin) Rules 2025
Hydro Tasmania welcomes the opportunity to review the Exposure Draft (Tranche 1) Rules 2025. As a below-baseline renewable electricity generator we look forward to further consultation with
DCCEEW and the Clean Energy Regulator on Renewable Electricity Guarantee of Origin (REGO).
While Hydro Tasmania is unlikely to be a user of Product GO certificates in the short-term, we support the development of these including their further expansion to low carbon liquid fuels and green metals.
Part 1 Preliminary (clauses 1-6)
- ‘Clause 6, meaning of related scheme’ - an issue relevant to below-baseline facilities will be
the ability for a single renewable facility (e.g. an existing pre-1997 hydropower station) to
create both Large-scale Generation Certificates and REGOs in the same year. While it is
critical that the same MWh of renewable energy cannot create two certificates (double
counting), it is appropriate that pre-1997 stations can create both LGCs for above-baseline
and REGOs for below-baseline in the same year.
- As Hydro Tasmania understands it, Clause 36 would require notification that a REGO facility
was also a participant in a related scheme (the RET).
- The CER must ensure that creation of LGCs and REGOs can occur concurrently and without
unnecessary complexity. For example, a single Electricity Generation Return (EGR) would be
the most appropriate approach, or failing this, the two administered schemes should be able
to draw from the same provision of data to the CER.
Part 2: Registration for the Act
Applications for registration and related matters (clauses 7-9)
- No comments.
Suspension and cancellation of registration (clause 10)
- No comments.
Part 3 Certification of products:
Registration of profiles (clause 11-16)
- It is not immediately clear to Hydro Tasmania from the consultation document, whether the
registration process for a renewable power station creating REGOs will be more substantial
than the current arrangements under the RET (including requirements around metering).
- The desire to have a consistent approach across PGOs and REGOs is understandable given
their different but related aims.
- Where there are differences between the registration processes for PGO and REGO facilities
it would help stakeholders if this was made clearer in future accompanying documentation.
Correction and transfer of registered profiles (clause 17-18)
- No comments.
Suspension and cancellation of registered profiles (clause 19)
- No comments.
Certification of products (clause 20-21)
- No comments.
Registration of PGO certificates (clause 22-23)
- No comments.
Annual reconciliation checks (clause 24-25)
- No comments.
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Corrections and invalidating incorrect certificates (clause 26-27)
- No comments.
Part 4: Certification of renewable electricity
Energy sources (clause 28)
- Hydro Tasmania supports utilising a streamlined application process for power stations
already accredited under the REE Act.
- It is not clear why is there no clause 29?
Applications to register facilities - accredited power stations and generation systems (clauses 30-31)
- No comments.
Registration of facilities - accredited power stations and generation systems (clauses 32-33 and
Schedule 1)
- No comments.
Registered renewable electricity facilities - Other matters (clauses 34-37)
- No comments.
Other matters relating to renewable electricity certification
Regarding the treatment of below-baseline certificates Hydro Tasmania would like to make the following comments:
- We look forward to participating in consultation around below-baseline rules.
- The consultation paper reflects the policy decisions laid out in section 108 of the GO Act.
- The decision to limit retirement of below-baseline certificates to within 18 months of
generation of the electricity they represent is appropriate, however, Hydro Tasmania
strongly believes this should be the case for retirement of all REGOs. The rationale for this is
the REGO scheme is about attribution of renewable generation to customers. It makes little
(or no) sense to suggest that an electricity user in 2033 is using renewable electricity from
2031. There was no need for such a restriction in the RET as banking and even borrowing of
certificates was a beneficial mechanism to lower costs for consumers and reduce the overall
consumer impacts of the RET. This rationale does not apply in an attribution scheme. With
respect to other schemes:
3
o RE100 requires that the certificate, “must be reasonably close in time to the period
over which a claim to use of renewable electricity is made”. However, “reasonably
close” is not defined.
o ‘Green-e’ has a requirement for a 21-month vintage eligibility window.
o Climate Active requires LGCs within three years.
o EUR-Lex Article 6 requires time matching and states that: “From 1 January 2030, the
temporal correlation condition shall be considered complied with if the renewable
liquid and gaseous transport fuel of non-biological origin is produced during the same
one-hour period as the renewable electricity produced”.
o GHG Protocol has criteria that seeks to, “ensure that the generation on which the
emission factors are based occurs close in time to the reporting period”. Though once
again, any vintage limitation does not appear to be specified.
- Given that DCCEEW has already established an 18 month requirement for below-baseline
REGOs, Hydro Tasmania strongly believes this should be extended to all REGO generators
and replicated in requirements for PGOs.
In Hydro Tasmania’s September 2024 submission to the Senate Standing Committee reviewing the
Future Made in Australia (Guarantee of Origin) Bill 2024 we stated:
- “In our discussions with DCCEEW, Hydro Tasmania has proposed that all REGOs must be
surrendered within 18 months of generation. Our continuing view is that this should apply to
all REGOs, not just below-baseline REGOs as the current Bill drafting appears to imply (by
including this clause in Section 108 not in Section 107).
- This is because the REGO scheme is about attribution and not about compliance with a
mandatory GWh target (as the RET has been).
- Banking REGOs from any generation source or ‘attributing’ electricity from greater than 18
months prior to its use is inconsistent with the aims of the REGO and Guarantee of Origin
frameworks. As further evidence, using REGOs in National Greenhouse and Energy Reporting
(NGER) would be negatively impacted if REGOs can be banked as it would distort the
calculation of the Residual Mix Factor used under the market-based method.”
If you wish to discuss any aspect of this submission, please contact me
Yours sincerely,
Manager Policy Development
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