{"data":{"id":"sbm36b241497384eb4c1e733","short_id":23,"created":"2025-07-18T06:11:29.779Z","space_id":"spc35f39a68c3255bca82dcb","project_id":"prj35f39a54b2b946a3ebba7","org_id":"org20ee740c8b3c21feb3566","content":{"8q21898g":["09399e"],"zovp5q48":"Alinta Energy","skip-to-end-of-s_bb8651":"yes","upload-a-submiss_9dbd27":"fil374181c533eba112c80b6"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil374181c533eba112c80b6":{"id":"fil374181c533eba112c80b6","bucket":"files-au-climate","remote_path":"climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/Final_Alinta_Energy_Exposure_Drafts_of_the_legislative_instruments_that_will_support_the_Guarantee_of_Origin_GO_scheme_Redacted.8922109d.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/Final_Alinta_Energy_Exposure_Drafts_of_the_legislative_instruments_that_will_support_the_Guarantee_of_Origin_GO_scheme_Redacted.8922109d.pdf","filename":"Final_Alinta Energy_Exposure Drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme_Redacted.pdf","transcribed":"18 July 2025\n\nDepartment of Climate Change, Energy, the Environment and Water\n\nSubmitted through DCCEEW website\n\nExposure Drafts of the legislative instruments that will support the Guarantee of Origin\n(GO) scheme\n\nAlinta Energy welcomes the opportunity to provide feedback to the Department of Climate\nChange, Energy, the Environment and Water (DCCEEW) on the Exposure Drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme.\n\nWe are an active investor in energy markets across Australia, with an owned and contracted generation portfolio of over 3,300 MW and more than one million electricity and gas customers.\n\nOur feedback is specifically on Section 52(2)(d) of the Exposure draft - Future Made in\nAustralia (Guarantee of Origin) Rules 2025. which states that\n\n“The Regulator must not retire a REGO certificate in the following prescribed\ncircumstances: for a REGO certificate that is not a below-baseline certificate …\n\nd) the registered owner of the certificate requests that the certificate be retired\nmore than 24 months after the time period to which the certificate relates.”\n\nThe proposed 24-month time limit for retiring REGO certificates does not align with the timeframes typically required between certificate creation and surrender.\n\nWe recommend that REGO retirement rules be aligned with current industry practices and allow a 48-month vintage period. This would support effective market participation and avoid unintended consequences.\n\nUnder current practices for managing Large-scale Generation Certificates (LGCs), each stage\n(as outlined in the table below) follows timeframes that align with standard commercial and operational practices. A 24-month REGO retirement limit would not accommodate these established practices, particularly for customer contracting and surrender.\n\nActivity Time taken\nRegistration Up to 3 months\nTransfer to Retailer Up to 3 months\nCustomer Up to 24 months\nContracting\nSurrender Up to 18 months (For example, January generation for the following\nyear surrender)\n\nWe also note that other schemes allow longer vintage periods, which better align with industry standards. For instance:\n\n1. The National Australian Built Environment Rating System (NABERS) allows a 36-month\nvintage for voluntary surrender in the Renewable Energy Indicator for LGCs.1\n2. The Climate Active market-based method also allows a 36-month vintage period for\nLGCs surrender.2\n\nThank you for considering our submission. We would be happy to meet with you and discuss it further. If you would like to arrange a meeting, please contact , Manager Public\nPolicy, at .\n\nYours sincerely\n\nGeneral Manager, Government & Regulatory Affairs\n\n1 NABERS, Renewable Energy Indicator FAQs, “Are vintage restrictions on LGCs recognised for voluntary surrender?”, accessed on 18 July 2025.\n2 Climate Active, Electricity Accounting, pg. 7. Accessed on 18 July 2025.","size":183960,"redacted":[],"meta":{"name":"Final_Alinta_Energy_Exposure_Drafts_of_the_legislative_instruments_that_will_support_the_Guarantee_of_Origin_GO_scheme_Redacted.8922109d.pdf","local_path":"files/3jkKicsJecDDhTO5ySnCtdKV.pdf"},"config":{}}}}}