Public Consultation on Tranche 1 of the Exposure Draft of the Guarantee of Origin Rules

Commencement should include details on the transition from the Large-scale Generation Certificates (LGCs) under the Renewable Energy (Electricity) Act 2000 (REE Act) to the introduction of Renewable Electricity Guarantee of Origin (REGO) certificates.
There is significant investment underway in the energy sector to support the national 82% renewable electricity by 2030 target and deliver the transition to net zero. Ambiguity about the interactions between these schemes can affect contracts to support investment in new generation and storage facilities. E.g. a 10 year power purchase agreement (PPA) signed in 2025 currently faces uncertainty around how renewable electricity will be recognised after the cessation of LGCs in 2030, as well as the potential impact on the value of these LGCs from the potential introduction of REGOs before 2030. This makes it challenging to agree the value of this renewable electricity between parties.
The move from mandatory use of LGCs to meet obligations for liable entities (generally retailers) to voluntary use and trading of REGOs could create other challenges. E.g. REGOs will have greater granularity than LGCs (e.g. time stamping) which could result in a premium for REGOs and bias producers towards this scheme. Also, the inclusion of storage and aggregated services under REGOs could further increase supply of these certificates which could incentivise the market to move more trading into this enduring mechanism.
The potential for producers to be incentivised to choose REGOs over LGCs could affect the volume and value of LGCs and has the potential to impede the ability of liable entities (generally retailers) to meet their renewable power percentage obligations under the Renewable Energy Target (RET). It is also not clear what would happen to a liable entity using the shortfall arrangement under the RET if they are carrying a shortfall of LGCs when the scheme ends in 2030.
Similarly, the potential for small-scale renewable scheme (SRES) certificates to be replaced with REGOs from aggregated services could also have an impact on the operation of the REE Act and GO schemes through the transition period.

While nominating whether assistance is received should be administratively simple, we would not support a requirement to report details of the grant or assistance administered by the Commonwealth under Clause 9(b). As we noted in our submission to the Guarantee of Origin scheme design paper in October 2023, we do not agree with requiring registered persons to repeatedly provide information administered elsewhere in Government.
We also consider there is a risk of inconsistent reporting across facilities. E.g. even the relatively simple national 82% renewable electricity by 2030 target is variously reported as 82% renewables (even though it is just electricity, not biomethane, biodiesel, etc), 82% in the NEM (even though all five major grids are included), 82% capacity (even though it’s a generation/output target), etc. across the market and media sources.

We propose the time period indicating an ‘inactive registration’ be extended to 18 months. Some customers only engage with reporting processes on an annual basis so suspending or cancelling registration after 12 months’ inactivity would put them regularly at risk of having to re-register. This is particularly significant given the creation of a certificate requires active engagement by the consumer through the proposed process in the first tranche of the Exposure Draft Rules. An 18 month period would prevent the need for regular suspensions while still meet the intention to remove inactive and unnecessary registrations.

Origin recognises and supports the importance of ensuring credibility of certification schemes and addressing the challenges of perverse incentives. We also support efforts to develop a comprehensive, flexible and consistent scheme to cover all clean products. However, it is important that efforts to address these risks are proportionate and do not introduce prohibitive administration requirements. This will support successful and liquid markets for products with PGOs.
This is particularly important for this voluntary scheme that requires the production, delivery and consumption of a product to be reported by three parties either directly or through agreed approaches to creating PGO certificates. If the administrative cost of participating is too high, there is a risk that the person responsible for one or more of the profiles chooses to use a different scheme. For example, a consumer has the option to adopt alternative schemes, such as GreenPower’s Renewable Gas Certification, or offset their emissions with Australian Carbon Credit Units (ACCUs). It is not clear how a producer of renewable gas would be able to benefit from PGO certification if there was limited participation in the PGO scheme by consumers.
The Exposure Draft Rules introduce a number of additional reporting fields from those outlined in the Act. For example, how the product is moved from the delivery gate to the facility using the product and evidence that the facility can use the product. We appreciate recent experience with other schemes, such as concerns regarding refrigerated cabinet activities in VIC and NSW energy efficiency schemes, reinforces the need to ensure the certified emissions reductions are achieved. However, the level of information required to support certification should not be prohibitively burdensome.
Similarly, as noted under Part 2, we also do not support an obligation to report the details of relevant Commonwealth and jurisdictional schemes which are administered elsewhere in Government. Under the Act, the only requirement is for a consumer to indicate whether the facility is an NGER facility or a designated large facility under the Safeguard Mechanism. Requiring details of grants, assistance and schemes for the production, delivery and consumption profiles significantly increases the reporting burden. The participants are also not best placed to provide the details of government schemes and this requirement risks inconsistent details across reporting entities.

We support the proposed approach.

We support the proposed approach for consistent treatment of registered persons and registered profiles.

Similar to the registration of application and registration of profiles, Origin recognises the importance of ensuring credibility. However, the addition of several new reporting requirements in the draft rules could introduce prohibitive administration requirements. These include the requirement to report on total electricity used, the percentage of electricity from a renewable source, the grid to which the renewable electricity is connected, and the time the renewable electricity was produced for production and delivery of a product.
Time stamping (which is not a feature of current certification schemes) also introduces new complexities such as the needing to report and validate the time period for renewable electricity production. Introducing new requirements can have material impacts on operating costs for an organisation as they implement new systems to accommodate additional characteristics like time stamping. We maintain our view that the level of information required to support voluntary certification should not be prohibitively burdensome.

We generally support the proposed approach. However, we note the requirement to demonstrate timing for delivery and use (Clause 23(2)(b)) could pose similar challenges to requiring time stamps for the use of renewable electricity in production and delivery. We note that GreenPower has decided not to pursue time stamping for its renewable gas guarantee of origin (RGGO) certification for renewable gases.
We also suggest that the language in the example provided for Clause 23 could be improved. Currently it could be taken to imply that the same unit of gas is able to generate certificates through two different schemes. It will be important for the credibility of the scheme that this perception of the potential to enable double counting, whether perceived or real, is avoided.
We consider it could be challenging to provide the information in Clause 23 for exports of clean products. We note the language in Section 28 of the Act refers to delivery gates as the location where a product is placed on a ship or exported other than by being placed on a ship. We propose that for exports the evidence of delivery could be demonstrated through evidence of shipping or other means of transport.

We do not have any comments on these clauses.

We generally support the proposed approach and appreciate the steps included to address concerns regarding each profile through engaging with the relevant persons before a certificate can be invalidated. But we suggest including a ‘make good’ provision on the producer in the event the contract is cancelled. This would address the risk that a consumer who purchased the clean product in good faith loses their certification and could be accused of greenwashing if they used this certification in subsequent products and services.
We also have concerns about the ability to invalidate a certificate if consumption information is not added within 12 months. The voluntary nature of the scheme and the requirement to receive permission to report on behalf of a consumer, as well as the requirement of additional information through the exposure draft rules presents a risk of this outcome. This applies to the requirement to specify the number and nature of facilities using the product, as well as the movement of the product from the delivery gate to the facility, for both domestic and international consumers. Noting the consultation paper suggests this means international consumers might need to identify any associated international schemes and certification details.
We appreciate the scheme covers both renewable gases and products created with this renewable energy, such as green metals, which means the scheme needs to cover a range of circumstances. However, current international schemes to accredit guarantees of origin are focused on the source or production of energy and not how it is used. There is a risk that a consumer does not report, does not formally enable another to report on their behalf and/or does not provide the information required to report on their behalf. This could bias producers of renewable gases towards other certification schemes which would not invalidate your certification if the consumer does not report on their movement and use of the product.

We support efforts to align the definition of renewable energy sources with the Renewable Energy (Electricity) Act 2000 (REE Act) for consistency with established and accepted definitions.
We look forward to engaging on efforts to recognise and integrate energy storage systems and aggregated systems.

We support efforts to align the REGO approach with requirements with the REE Act to ensure consistency across schemes and minimise reporting obligations. This will help facilitate a smooth and successful transfer from LGCs and STCs to REGOs.
But similar to our comments on the PGO application and registration we do not support facilities being required to repeatedly report the details of schemes administered elsewhere by the Government. Leveraging existing information administered by governments can also help avoid double dipping between schemes. E.g. a solar unit with Victorian Energy Efficiency certificates (VEECs) under the Victorian Energy Upgrades program (VEU) should not be able to create REGOs and the VIC Government will be best placed to advise on participation and coverage of their scheme.
We look forward to engaging on efforts to recognise and integrate energy storage systems and aggregated systems.

We support efforts to align the REGO approach with requirements with the REE Act to ensure consistency across schemes and minimise reporting obligations.

We note the one month period required by the Act is shorter than other frameworks, e.g. significant reversals under the CER’s ACCU permanence obligations.
We do not support the notification of events being extended to changes in jurisdiction policies and programs. It is often not clear within a month of a scheme coming in effect whether a facility would be in scope. The facility is also not best placed to report when they become (or cease to be) subject to a government scheme. Accessing this information via the government process administering the scheme will provide more consistent and timely reporting than asking each facility to provide their own interpretation. This could become prohibitively burdensome given the rapid changes in policies and programs across each level of government.