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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.
We stress the importance of Clause 28, which defines eligible renewable energy sources and explicitly excludes biomass from native forests. This is an important rule that must be preserved. We urge DCCEEW and other Commonwealth entities to maintain a consistent approach to the definition of eligible renewable energy sources, which excludes biomass from native forests.
Do you have any feedback on the further policy considerations for REGO outlined in the consultation paper?
Please provide comments.
In our submission we briefly address two additional points regarding the rules for eligible renewable energy sources. First, the rules and design decisions made for hydrogen should be done in ways that are compatible with future scheme expansion to a wide variety of sectors and products, including for agricultural products. Second, the eligibility of crop residue as a sustainable source of renewable energy should be subject to further consideration and research.
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?
Would you like to upload a document?
Upload a submission
Submission in response to: Future Made in Australia
(Guarantee of Origin) Rules 2025
26 March 2025
Submission by:
[redacted] at the Australian National University’s College of Law, Governance and Policy
[redacted] at the Australian National University’s College of Law, Governance and Policy
Submission in response to Public Consultation on Tranche 1 of the Exposure Draft of the Guarantee of Origin Rules
We thank DCCEEW for its continued engagement with stakeholders and appreciate the opportunity to provide feedback on the GO scheme rules.
We appreciate the department’s ongoing commitment to reviewing and improving the scheme, with a view to incorporating new products in the future. In this regard, we stress the importance of Clause
28, which defines eligible renewable energy sources and explicitly excludes biomass from native forests. This is an important rule that must be preserved. Similarly, biomass from native forests should be excluded from all related schemes, including those for biofuels. For example, while
Australian Renewable Energy Agency’s (ARENA) Australia’s Bioenergy Roadmap acknowledges community concerns about the sustainability of forestry and agricultural resources, it does not explicitly address this exclusion. As the PGO Scheme evolves, it is essential that forestry and agricultural “wastes” not be considered zero-emissions inputs to biofuel production. We urge
DCCEEW and other Commonwealth entities to maintain a consistent approach to the definition of eligible renewable energy sources, which excludes biomass from native forests.
Below, we briefly address two additional points:
1. Issues to consider for future scheme expansion
In line with our previous submissions, we would like to emphasise that the rules and design decisions made for hydrogen should be done in ways that are compatible with future scheme expansion to a wide variety of sectors and products, including for agricultural products. The production of many products involves both land-based and manufacturing elements. Products that use agricultural waste as a carbon source are an example of such. Agricultural products that use industrially produced fertilizer are another. Complications may arise because currently approaches to embedded emissions accounting are generally not consistent between agricultural and manufacturing sectors. Therefore, ad hoc approaches of developing product-specific methodology as new products are added may
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create challenges in consistency of reporting / risk of double-counting when schemes expand beyond initial products (hydrogen for GO scheme, and six products for EU’s CBAM).
In relation to the above, we would like to point to:
2. Areas of the scheme that should be investigated further
We appreciate the department’s continuous consideration of whether additional rules or further clarifications are needed regarding the eligibility of sources for renewable energy. We believe the eligibility of crop residue as a sustainable source of renewable energy should be subject to further consideration and research. While crop residue is recognized as a potential renewable source for biofuel production, and is used globally, the scientific community has already raised significant concerns about the sustainability of removing crop residue for energy production. Removing crop residue for biofuels can lead to a decrease in soil organic carbon and significant increases in C02 emissions (Lal, 2004; Liska et al., 2014), essentially changing soil from a sink to a large source of emissions. ARENA also highlighted community concerns regarding the removal of agricultural residues, which are essential for soil fertility and carbon sequestration (ARENA, 2021). As ARENA
(2021) acknowledged, data on the types, volumes, and locations of organic wastes and residues available for bioenergy presented as part of the Bioenergy Roadmap report, does not assess the technical, economic, or sustainability aspects of these resources. Utilising crop residue for energy without considering and mitigating the potential negative impacts on carbon stocks and on soil health may lead to unsustainable outcomes. This will be important to consider if the GO scheme is extended to biofuels in the future.
From the embedded emissions perspective, crop residue should not be considered as zero emission.
As soon as crop residue becomes a ‘valuable’ commodity and can be verified as ‘on-sold’, it becomes a co-product (GHG, 2014; WBCSD, 2023), which should be subject to emissions allocation from the entire crop production process. In addition, none of the existing product embedded emissions accounting schemes consider carbon opportunity cost (COC) of land (Searchinger et al., 2018). The
COC represents the lost potential for carbon sequestration when land is used for activities that maintain lower carbon stocks than its natural state. In both using land for crop production and removing crop residue, embedded emissions accounting schemes should account for the highest alternative value use of the resource in terms of carbon sequestration, which in many cases is letting the land return to its natural state. Failing to account for this opportunity cost can lead to misleading evaluations of land-use changes (Searchinger et al., 2018). The COC is important for many land-based products and should be taken into consideration as an additional accounting module for the GO scheme, particularly if it expands to include agricultural products.
References
ARENA. (2021). Australia’s Bioenergy Roadmap Report. Australian Renewable Energy Agency.
https://arena.gov.au/knowledge-bank/australias-bioenergy-roadmap-report/
GHG. (2014). GHG Protocol Agricultural Guidance Interpreting the Corporate Accounting and
Reporting Standard for the agricultural sector.
Lal, R. (2004). Is crop residue a waste? Journal of Soil and Water Conservation, 59(6), 136A-139A.
https://doi.org/10.1080/00224561.2004.12435755
Liska, A. J., Yang, H., Milner, M., Goddard, S., Blanco-Canqui, H., Pelton, M. P., Fang, X. X., Zhu, H., &
Suyker, A. E. (2014). Biofuels from crop residue can reduce soil carbon and increase CO2
emissions. Nature Climate Change, 4(5), 398–401. https://doi.org/10.1038/nclimate2187
CRICOS Provider [redacted]
Searchinger, T. D., Wirsenius, S., Beringer, T., & Dumas, P. (2018). Assessing the efficiency of changes
in land use for mitigating climate change. Nature, 564(7735), 249–253.
https://doi.org/10.1038/s41586-018-0757-z
WBCSD. (2023). Pathfinder Framework Guidance for the Accounting and Exchange of Product Life
Cycle Emissions, version 2.0. ,” Partnership for Carbon Transparency (PACT), World Business
Council for Sustainable Development (WBCSD).
CRICOS Provider [redacted]
