{"data":{"id":"sbm36b324b3154e27da0ad27","short_id":30,"created":"2025-07-18T10:19:53.493Z","space_id":"spc35f39a68c3255bca82dcb","project_id":"prj35f39a54b2b946a3ebba7","org_id":"org20ee740c8b3c21feb3566","content":{"8q21898g":["09399e"],"zovp5q48":"Fortescue","skip-to-end-of-s_bb8651":"yes","upload-a-submiss_9dbd27":"fil3741aade0ceb76d1c6bb4"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3741aade0ceb76d1c6bb4":{"id":"fil3741aade0ceb76d1c6bb4","bucket":"files-au-climate","remote_path":"climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/Fortescue_GO_Rules_July2025_Redacted.1ff0b188.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/Fortescue_GO_Rules_July2025_Redacted.1ff0b188.pdf","filename":"Fortescue GO Rules July2025_Redacted.pdf","transcribed":"18 July 2025\n\nSecretary\nDepartment of Climate Change, Energy,\nEnvironment and Water\nDear ,\n\nExposure Drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme\n\nA proudly Australian company with balance sheet strength, Fortescue is a global leader in large-scale, ultra-efficient and highly complex developments with a proven track record in developing and operating assets in remote and isolated locations. Fortescue has a strong focus on decarbonisation, evidenced by its industry leading target to achieve real-zero carbon emissions across our terrestrial mining operations by\n2030. We are establishing a global portfolio of renewable energy, green iron, green hydrogen and derivatives, battery system and green technology projects and operations that are at the forefront of the global energy transition.\n\nFortescue welcomes the opportunity to provide comment on the Exposure Drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme. Fortescue is broadly supportive of the\nExposure Drafts and the frameworks they create as they support the trajectory of Australia becoming a producer, consumer and exporter of verifiably green products. The GO scheme is an integral feature of the emerging green hydrogen, green iron and broader green products industry in Australia, providing an important source of transparency. Fortescue would like to thank the Department and the Regulator for moving with pace on this next phase of the GO scheme introduction.\n\nFortescue is particularly interested in the ongoing development of the Product GO (PGO) certification stream that plans to extend the coverage of the PGO scheme to downstream hydrogen products, specifically green iron ore and green iron. Fortescue is developing our Christmas Creek Green Metal\nProject to produce green iron metal in the Pilbara region of Western Australia. Scheduled for first production in 2026, this project aims to decarbonise iron production by utilizing renewable energy and green hydrogen technology. The facility will employ an electric smelting furnace to create up to 1500 tonnes per annum of high purity green iron. Alongside this work to produce green iron, Fortescue is decarbonising our traditional mining operations entirely to achieve Real-Zero by 2030. This means no fossil fuel usage or voluntary offsets by 2030 in our terrestrial operations, removing our scope 1 and scope 2 emissions profile.\n\nWe will achieve this by eliminating 600 million litres of diesel usage per annum and building 2 to 3 gigawatts of renewable energy generation and storage, preventing more than 2.4mtpa of emissions per\n\nExposure Drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme\nPage 1 of 3\nyear from Australia’s emissions profile. To support this work, Fortescue will rely on the GO scheme to verify both the emissions reductions occurring in the production of our iron ore which can then be exported from the Pilbara, and then alternatively for the downstream value adding process to convert our green iron ore to green iron for export to traditional steel makers. Therefore, it is critical that the PGO scheme methodologies covering these products are developed as quickly as possible to verify that our current Real Zero 2030 decarbonised iron ore and future green iron claims are valid.\n\nThis submission will make comments regarding the Exposure Draft – Future Made in Australia (Guarantee of Origin) Rules 2025 and the Exposure Draft – Future Made in Australia (Guarantee of Origin)\nMethodology Determination 2025. For comments on the Cost Recovery Statement please see our submission provided to the Clean Energy Regulator (CER).\n\nThis consultation establishes the process for additional method development via adding them as chapters once complete. Fortescue supports this process as it provides a clear and swift method of developing and implementing critical pieces of the GO scheme. As noted above, Fortescue is currently constructing our green iron pilot project that will lean on the GO scheme to verify the emissions for green iron produced in the Pilbara from 2026. We will require the development of the iron ore and iron methodologies to be progressed as swiftly as possible.\n\nFurther, the process to leverage commonalities between methods that are similar, or use the same inputs, such as water, should be encouraged wherever possible to further speed up the development and implementation process.\n\nFortescue commends the Department for its work to date with international markets and jurisdictions to align the GO scheme wherever possible with existing methodologies, customer and government expectations for project certifications. Doing so creates a respected and trustworthy system that allows industries to market their product in a global setting. Recognising that it is not the Commonwealth’s role to be responsible for certificate delivery into international markets, further information would be welcomed on how this transfer of data will be managed with international partners and to what extent the CER will facilitate this process. As the GO scheme will be trusted and aligned with international expectations, interoperability should be a relatively simple, but critical, step for the GO scheme.\n\nAs the GO scheme matures over time and new methodologies are added, Fortescue encourages the\nDepartment to consider broader hydrogen production methods to be included in the GO scheme.\nCompanies such as Fortescue backed Sparc Technologies photocatalysis technology may prove to be an important method of producing low cost hydrogen and would require a methodology to be developed for use in the GO scheme. Ongoing prioritisation of methodologies based on maturity and industry interest will be critical.\n\nOur final comment relates to the consideration of market value for co-products when producing hydrogen but also applies in principle to other production methods. As production of green products grows over time there may be a material change in what is considered the market value for some co-products due to the\n\nExposure Drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme\nPage 2 of 3\nsheer volume that is produced. For example, oxygen will be a considerable co-product from electrolysis that may push prices lower and require continued analysis of true market value. Further, oversupply of some co-products may push prices very low over time. In these cases, while there is limited or no value to these products, it may be appropriate that they remain legitimate co-products with assignable emissions values.\n\nThank you for the opportunity to comment on this consultation. If you would like to discuss any of the issues raised in this submission or to arrange a briefing, please contact or myself on the below details.\n\nYours sincerely\n\nFORTESCUE\n\nExposure Drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme\nPage 3 of 3","size":23599,"redacted":[],"meta":{"name":"Fortescue_GO_Rules_July2025_Redacted.1ff0b188.pdf","local_path":"files/idZuomeWlIC6Vj66qFY_P8-0.pdf"},"config":{}}}}}