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Australian Government
Department of Climate Change, Energy, Environment, and Water
Submitted via email: RenewableEnergy@dcceew.gov.au
27 March 2025
Exposure Draft - Future Made in Australia (Guarantee of Origin) Rules 2025
The Australian Energy Council (‘AEC’) welcomes the opportunity to make a submission to the
Department of Climate Change, Energy, Environment, and Water’s (‘Department’) consultation
on the Exposure Draft - Future Made in Australia (Guarantee of Origin) Rules 2025.
The AEC is the peak industry body for electricity and downstream natural gas businesses
operating in the competitive wholesale and retail energy markets. AEC members generate and
sell energy to over 10 million homes and businesses and are major investors in renewable energy
generation. The AEC supports reaching net-zero by 2050 as well as a 55 per cent emissions
reduction target by 2035 and is committed to delivering the energy transition for the benefit of
consumers.
The AEC has been deeply engaged with the progress of the Renewable Electricity Guarantee of
Origin (‘REGO’) scheme since its initial policy consultation in October 2023. The REGO scheme
represents an important part of Australia’s energy transition and will create an enduring
certification framework to empower the voluntary market to confidently purchase clean energy.
The AEC’s preferred design is one that encourages transparency and where the rules do not differ
between the various types of renewable generation.
With respect to the Tranche 1 Exposure Draft, the AEC provides the following feedback:
• Clause 6, meaning of related scheme – depending on demand for the two certificate
schemes, some renewable facilities may elect to create both Large-scale Generation
Certificates (‘LGCs’) and REGOs in the same year. So long as it is not for the same MWh
of renewable energy (i.e. to prevent double counting), the Rules must ensure this is
administratively straightforward to do. This is likely to be relevant to pre-1997 renewable
power stations which will create LGCs for above-baseline and REGOs for below-
baseline.
• Clause 28, energy sources – the AEC supports using a streamlined application for power
stations that are already accredited under the Renewable Energy (Electricity) Act 2000
(Cth) (‘REE Act’).
• Below-baseline certificate retirement restrictions – the AEC notes the direction of the
Department to place restrictions on below-baseline certificates due to concerns about
impacts on LGC price. The AEC maintains the view that such restrictions are contrary to
the purpose of the REGO as a mechanism to certify all renewable generation. Given there
are already restrictions on the activities below-baseline REGOs can be surrendered for,
the AEC considers further explanation is required as to the reasons for introducing a
vintage requirement.
More broadly, the AEC notes the need for:
• Ongoing collaboration with industry with respect to the transition from LGCs and STCs to
REGOs to ensure there are no inadvertent impacts for retailers and their mandatory
surrender obligations under the REE Act.
Level 13, 575 Bourke Street P +61 3 9205 3100 ABN 92 608 495 307
Melbourne 3000 E info@energycouncil.com.au ©Australian Energy Council 2025
GPO Box 1823 Melbourne Victoria 3001 W energycouncil.com.au All rights reserved.
• A faster rollout of the scheme to other products, especially low carbon liquid fuels, green
metals, and biomethane, noting the commitment to link funding for things like green
hydrogen, aluminium, and steel to the GO Scheme.
• Coordination with other governments, departments, and agencies to ensure the REGO
co-exists neatly with NGER amendments and other schemes like GreenPower and
Climate Active.
• A clear timeframe for rollout of the scheme to prepare participants in terms of systems,
processes, and contracting.
Any questions about this submission should be addressed to
Yours sincerely,
Policy Manager
Australian Energy Council
Level 13, 575 Bourke Street P +61 3 9205 3100 ABN 92 608 495 307
Melbourne 3000 E info@energycouncil.com.au ©Australian Energy Council 2025
GPO Box 1823 Melbourne Victoria 3001 W energycouncil.com.au All rights reserved.
