{"data":{"id":"sbm36b1f8d3468b0fda84988","short_id":20,"created":"2025-07-18T04:52:20.934Z","space_id":"spc35f39a68c3255bca82dcb","project_id":"prj35f39a54b2b946a3ebba7","org_id":"org20ee740c8b3c21feb3566","content":{"8q21898g":["09399e"],"zovp5q48":"AGL Energy","skip-to-end-of-s_bb8651":"yes","upload-a-submiss_9dbd27":"fil373d5381d6f48d26ee970"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil373d5381d6f48d26ee970":{"id":"fil373d5381d6f48d26ee970","bucket":"files-au-climate","remote_path":"climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/AGL_submission_Guarantee_of_Origin_Tranche_2_Exposure_Draft_1_Redacted.04e2293d.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/AGL_submission_Guarantee_of_Origin_Tranche_2_Exposure_Draft_1_Redacted.04e2293d.pdf","filename":"AGL submission - Guarantee of Origin Tranche 2 Exposure Draft  (1)_Redacted.pdf","transcribed":"AGL Energy Limited\nT 02 9921 2999 Level 24, 200 George St\nF 02 9921 2552 Sydney NSW 2000\nagl.com.au Locked Bag 1837\nABN: 74 115 061 375 St Leonards NSW 2065\n\nAustralian Government\nDepartment of Climate Change, Energy, Environment, and Water\nBy email: GuaranteeOfOrigin@dcceew.gov.au\n\n18 July 2025\n\nGuarantee of Origin – Tranche 2 Exposure Draft\nAGL Energy (AGL) welcomes the opportunity to make a submission in response to the Australian Government’s\nTranche 2 consultation package on the subordinate legislation to support the Guarantee of Origin framework.\nAGL is a participant in several environmental markets across carbon, renewables, energy efficiency. Since its inception, AGL has been engaged in the process of developing the Guarantee of Origin (GO) Scheme, strongly supporting the passage of the Guarantee of Origin Bills in 2024 and providing feedback to previous consultations1. The Product Guarantee of Origin (PGO) framework will assist in the delivery of broader decarbonisation objectives and ensure that claims around the emissions intensity of domestic products and commodities are accurate and transparent. The Renewable Electricity Guarantee of Origin (REGO) framework will provide an enduring framework for certification of renewable electricity and support ongoing transparency and assurance over the emissions intensity of green products.\nAn enduring architecture for green certification that can be leveraged for several use cases\nAGL is strongly supportive of framework that can support certification of zero-emissions electricity into the future. We consider that there will be several use cases for this scheme in the future, not only to support discrete PGO claims for commodities and products, but also to provide a general basis for future claims regarding the emissions intensity of electricity consumption across the economy, which could underpin additional certification and assurance frameworks, and support the emergence of both mandatory and voluntary green schemes.\nAt present, claims regarding renewable electricity are largely made using Large-Scale Generation\nCertificates (LGC) that are created under the mandatory RET, which also allows for an additionality component for LGCs that are surrendered by participants in addition to the mandatory RET target. Although we agree that the structure for REGOs should largely adapt from the RET where possible, in considering the design of the REGO scheme, it is important to remember that fundamentally REGOs are not an additionality certificate, but rather a certification tool.\nConcerns relating to the additionality of zero-emissions generation are important, particularly in an environment where renewables are being underwritten by government schemes, but these do not need to be embedded in the architecture of the REGO scheme, which should remain focussed on being a transparent and trusted record of the emissions intensity of generation output, which can then be used for several potential use cases.\nAs a general principle, the architecture of REGOs should therefore be set up to cover all forms of renewable electricity generation, with certificates attributes allowing the clear identification of the source of generation, which can then be used to inform different use cases for the surrender of REGOs, under any frameworks or codes that are agreed upon by relevant stakeholders.\nWe note that for small-scale generation, owing to the very large number of small-scale resources with comparably small generation output, this may present challenges given the volumes of data, especially if\n\n1\nSee: AGL submissions to GO and REGO consultations in February 2023, GO and REGO consultations in October 2023, and Tranche\n1 of the GO Rules in March 2025.\nattributes such as granular time matching and locational data are to be preserved. We look forward to engaging with the government on design options to consider this issue, including the potential for deeming arrangements such as those that were helpful in creating small-scale technology certificates (STCs) under the current RET.\nHowever, for below-baseline hydro generation there is no such concern. Generation output from these sources can be easily identified and attributed under the proposed framework for REGOs.\nOn this basis, AGL provides the following feedback on the Draft Rules:\n• There seems to be no clear rationale for imposing an absolute restriction on vintage requirements\nfor renewable generation to 24 months, and 18 months for below-baseline generation.\n• In our view, a vintage restriction is not required as a fundamental element of the scheme. Instead,\ndifferent use cases could identify eligible REGOs to meet specific claims. In our view, the market\nshould be given time to establish these use cases, and accordingly a useful starting point would be\nto keep REGO coverage broad, rather than codify restrictions in regulation.\n• The 18-month restriction introduces complexity and potential stratification with other REGOs. In our\nview, this adds unnecessary complexity to the overall intention of certifying zero-emissions\ngeneration. Having separate vintage requirements is arbitrary, reduces comparability across\nparticipant claims, and may complicate emissions accounting given that an 18 month limit may\ncreate misalignment with financial or calendar year reporting.\n• We reiterate that concerns regarding the additionality of below baseline REGOs do not necessarily\nneed to be addressed directly within the scheme’s architecture, but instead can be more effectively\nmanaged under the frameworks under which specific claims are being made, or at common law.\nWe are otherwise broadly supportive of the proposed rules and regulations, noting that in considering broader feedback from this consultation, we would encourage the government to continue to focus on the ambition of making certification of renewable electricity as broad, transparent, and simple as possible for all stakeholders. This will encourage greater adoption of the certification scheme and unlock future use cases to support Australia’s energy transition.\nShould you have any questions in relation to this submission, please contact (Senior Manager\nPolicy) on .\nYours sincerely,\n\nGM Policy and Market Regulation\nAGL Energy\n\nAbout AGL\nProudly Australian since 1837, AGL delivers around 4.5 million gas, electricity, and telecommunications services to our residential, small and large business, and wholesale customers across Australia. AGL operates the largest electricity generation portfolio in Australia of any ASX-listed company, with a total operated generation capacity of almost 8000\nMW across Australia. AGL is Australia’s largest privately-owned hydro power station operator and operates the largest portfolio of renewables and storage assets of any ASX listed company. Since 2006, AGL has invested billions of dollars in the construction and delivery of over 2 GW of renewable and firming capacity in the National Electricity Market\n(NEM).\n2","size":118165,"redacted":[],"meta":{"name":"AGL_submission_Guarantee_of_Origin_Tranche_2_Exposure_Draft_1_Redacted.04e2293d.pdf","local_path":"files/zkH88Kj7XyI7I2U295yEEVzI.pdf"},"config":{}}}}}