{"data":{"id":"sbm36cafe850021aa2a34b04","short_id":40,"created":"2025-07-23T01:29:04.512Z","space_id":"spc35f39a68c3255bca82dcb","project_id":"prj35f39a54b2b946a3ebba7","org_id":"org20ee740c8b3c21feb3566","content":{"8q21898g":["09399e"],"zovp5q48":"ENGIE","skip-to-end-of-s_bb8651":"yes","upload-a-submiss_9dbd27":"fil3741bd84e4852cfba2ec7"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3741bd84e4852cfba2ec7":{"id":"fil3741bd84e4852cfba2ec7","bucket":"files-au-climate","remote_path":"climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/20250723_ENGIE_submission_GO_scheme_Exposure_Drafts_Redacted.371a3fa4.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/20250723_ENGIE_submission_GO_scheme_Exposure_Drafts_Redacted.371a3fa4.pdf","filename":"20250723 - ENGIE submission - GO scheme Exposure Drafts_Redacted.pdf","transcribed":"Add\n\nGuarantee of Origin and Trade & Renewable Electricity Guarantee of\nOrigin section\nDepartment of Climate Change, Energy, the Environment and Water\nGPO Box 3090\nCanberra ACT 2601\n\n23 July 2025\n\nTo Guarantee of Origin and Trade & Renewable Electricity Guarantee of Origin section,\n\nExposure Drafts of the legislative instruments that will support the Guarantee of Origin\n(GO) scheme\n\nENGIE Australia & New Zealand (ENGIE) appreciates the opportunity to respond to the Department of\nClimate Change, Energy, the Environment and Water (the Department) on its consultation on exposure drafts of the legislative instruments that will support the Guarantee of Origin (GO) scheme.\n\nThe ENGIE Group is a global energy operator in the businesses of electricity, natural gas and energy services. In Australia, ENGIE operates an asset fleet which includes renewables, gas-powered generation, and battery energy storage systems. ENGIE also provides electricity and gas to retail customers across\nVictoria, South Australia, New South Wales, Queensland, and Western Australia.\n\nIn this submission, ENGIE has provided feedback on the Future Made in Australia (Guarantee of Origin)\nRules 2025 (Rules) and the concept paper on the policy direction for the rules relating to energy storage systems.\n\nFuture Made in Australia (Guarantee of Origin) Rules 2025\n\nIndustry requires consultation on the GO Register in the lead-up to go-live\n\nENGIE is concerned that the Department and the Clean Energy Regulator have not yet engaged with industry on the progress of the GO Register. There will be significant functionality required beyond that available in the current Renewable Energy Certificate (REC) Register to support the information required by the draft Rules. In particular, the REC Register does not currently enable the required granularity to support hourly time-stamped Renewable Electricity Guarantee of Origin (REGO) certificates. If the GO Register does not function effectively at go-live, this will likely have a negative impact on market participation in the GO scheme.\n\nPage 1\nENGIE would appreciate the Department and the Clean Energy Regulator providing industry with a timetable of upcoming consultations, including on the GO Register, so that industry can better understand the timeframes leading up to the commencement of the GO scheme.\n\nENGIE has comments on various aspects of the rules relating to REGO certificates\n\nPrescribed time period\n\nENGIE appreciates that providing flexibility of the time periods over which certificates can be created may allow more facilities to participate in the GO scheme in its initial phase. However, there is a risk that enabling too many variables (such as, different combinations of time period and renewable energy source) will result in very low liquidity of each REGO certificate type, particularly in the earlier years of the GO scheme.\n\nIn terms of the time zone to be used for time-stamping of REGO certificates, ENGIE supports the Australian\nFinancial Markets Association’s (AFMA) proposal that a harmonised time zone is used for time-stamping of all REGO certificates.1\n\nHourly time-stamping\n\nENGIE would appreciate some clarity from the Department on the required format for hourly time- stamping on a REGO certificate. For example, whether this would require a full length time-stamp that includes the relevant hour, calendar day, calendar month and calendar year.\n\nIn relation to the management of residual amounts from electricity generation, ENGIE considers this will be particularly relevant for facilities that are creating hourly time-stamped REGO certificates. The creation of hourly REGO certificates will potentially result in the accumulation of significant residual amounts every calendar month. From a market value perspective, a monthly time-stamped residual REGO certificate is likely to be less valuable than an hourly time-stamped REGO certificate, particularly for those REGO certificates created for peak demand hours. For this reason, the Department should consider enabling the creation of fractional REGO certificates, either in the initial design or in the next iteration of the GO scheme\nRules. For reference, the European Union’s Renewable Energy Directive III of October 2023 permitted a guarantee of origin to be divided into fractions of 1 MWh.2\n\nEligible amount – electricity generation systems\n\nENGIE supports the Department’s proposal for the eligible amount for a facility being based on the general formula in regulation 14 of the Renewable Energy (Electricity) Regulations 2001.\n\n1\nAustralian Financial Markets Association 2025, Submission – Tranche 2 Exposure Drafts: Guarantee of Origin scheme, July, p. 1\n2\nEuropean Parliament and the Council of the European Union 2023, Directive (EU) 2023/2413 of the European Parliament and of the Council, Article\n16f – Overriding public interest, 18 October. Page 2\nREGO certificate retirement\n\nENGIE does not support the inclusion of rule 52(2)(d) of the Rules, which prevents the retirement of a REGO certificate if 24 months has elapsed after the time period to which the certificate relates.\n\nENGIE agrees that certificate vintage requirements can enhance the credibility of REGO certificates and ensure that the relevant electricity generation occurs close to the time of the electricity consumption.\nHowever, ENGIE does not consider the Department should be establishing vintage requirements through the Rules. Any vintage requirements are more appropriately established through market-based methods including through individual programs, such as Climate Active, GreenPower and RE100.\n\nThe removal of the proposed 24-month retirement restriction would enable the market’s use of REGO certificates to adapt to the different use cases that may emerge and the different vintage requirements that may be imposed by different program operators. To the extent that the market does not consider that older\nREGO certificate vintages have value in voluntary claims, or that certain vintages are not permitted to be used in individual programs, the market value of those REGO certificates will likely decline towards zero.\n\nENGIE contends the imposition of a REGO certificate vintage requirement would reduce the liquidity of\nREGO certificates, which is of particular concern in the earlier years of the GO scheme when there will likely already be a relatively small supply of REGO certificates. In other aspects of the REGO certificate design the\nDepartment has prioritised flexibility, such as the prescribed time periods over which certificates may be created, so it is unclear why the Department has not also proposed flexibility in vintage requirements.\n\nRegardless of the vintage requirement chosen, if any, ENGIE contends that this should be applied consistently across all REGO certificates, including below-baseline certificates.\n\nEnergy Storage Systems Concept Paper\n\nThe inclusion of energy storage systems in the GO scheme will be most valuable to the market where there is effective storage tracking and temporal and geographical matching of the energy inputs and outputs of storage systems. ENGIE acknowledges this is a complex endeavour and is still in early stages of development internationally.3 However, to enable energy storage systems to make valid claims related to the time-shifting of renewable energy production attributes, it is important the GO scheme adapts to create closer linkages between electricity inputs and outputs for energy storage systems.\n\nWhile it may be prudent to adopt a simple approach initially to enable the Rules for energy storage systems to be ready for the GO scheme commencement, the Department should commit to future work programs to investigate options to align with international developments.\n\n3\nFor example, EnergyTag is a non-profit organisation that sets a voluntary standard for hourly matching and granular certificates that is being piloted across several jurisdictions. More detail is available here - https://energytag.org/standards/ Page 3\nThe proposed Rules create a misalignment between electricity inputs and discharge from energy storage systems\n\nThe proposed formula for ‘certificates to retire’ set out in the concept paper does not require any retired\nREGO or LGC certificates to match the time period for the dispatched electricity (for example, an hour).4\nThis allows the energy storage system operator to retire a REGO certificate for any eligible time period (i.e.\nan hour, a calendar day, a calendar month, or a calendar year) to demonstrate the electricity it has dispatched is renewable.\n\nAs noted above, while complex time-matching of energy inputs and outputs of storage systems may not be feasible for the initial iteration of the GO scheme, it may be appropriate for the Rules to require energy storage systems to retire certificates that match the time period of the dispatched electricity. For example, the creation of hourly time-stamped REGO certificates based on imported electricity could require the retirement of hourly time-stamped REGO certificates. This approach may help to improve the liquidity of hourly time-stamped REGO certificates in the early years of the GO scheme. The key use case for energy storage systems in the GO scheme is to utilise hourly time-stamps to time-shift renewable electricity generation to where it has a higher market value. For example, without a requirement to match the time periods of retired and created REGO certificates, solar generation facilities may be less incentivised to utilise hourly time-stamping due to the likely lower market prices for REGO certificates that are time- stamped during sunlight hours.\n\nREGO certificates from energy storage systems should retain a link to the attributes of retired REGO certificates\n\nIn relation to the import of electricity from sources other than directly supplied renewable electricity, ENGIE notes that the Department has proposed that relevant REGO certificates created by energy storage systems would be required to list the use of ‘grid supplied electricity’ with the option to list the eligible renewable energy sources associated with the retired REGO certificates.5\n\nAt a minimum, ENGIE contends it should be mandatory for REGO certificates created by energy storage systems to list the eligible renewable energy sources associated with the retired REGO certificates and directly-supplied renewable electricity. This would ensure that discharged electricity retains some traceability with the underlying renewable energy source.\n\nIdeally, the REGO certificates created by energy storage systems would also be able to include other facility-specific information from the associated retired REGO certificates, such as the name and location of the facility. This type of information may be relevant for some purchasers of REGO certificates, such as data\n\n4\nDepartment of Climate Change, Energy, the Environment and Water 2025, Concept Paper – Energy Storage Systems: Guarantee of Origin Scheme,\nJune, p. 21\n5\nIbid, pp. 24 & 25 Page 4\ncentres, that may want to understand the underlying source of the renewable energy input and the additionality of the original generation facility.\n\nClarity is required on the treatment of residuals accrued from imported electricity\n\nENGIE notes that section 92 of the Future Made in Australia (Guarantee of Origin) Act 2024 (Act) sets out the creation of certificates in respect of residual amounts for renewable electricity generation. However, the Act does not set out how residual amounts of REGO certificates should be treated when the certificates are retired for the purpose of creating REGO certificates from discharge of an energy storage system.\n\nThe proposed formula for ‘certificates to retire’ set out in the concept paper states that the number of certificates that must be retired to register energy storage certificates for a time period must be rounded up to the nearest whole number.6 For example, an energy storage system that has discharged 5.7MWh for a time period (including any relevant losses) would need to retire six REGO certificates (equivalent to 6MWh) for the time period, which leaves a residual of 0.3MWh.\n\nFor an energy storage system that is creating hourly time-stamped REGO certificates, the volume of residual amounts arising from the retirement of REGO certificates for imported electricity may be quite significant over each calendar month. ENGIE would appreciate clarity on whether the Department will propose that residual amounts from import into energy storage systems will be able to be used to create additional\nREGO certificates in a similar manner to section 92 of the Act.\n\nConcluding remarks\n\nENGIE welcomes further opportunities to engage with the Department on the continued development of the GO scheme. Should you have any queries in relation to this submission please do not hesitate to contact me on, telephone,\n\nYours sincerely,\n\nManager, Regulation and Policy\n\n6\nIbid, p.21\n\nPage 5","size":208534,"redacted":[],"meta":{"name":"20250723_ENGIE_submission_GO_scheme_Exposure_Drafts_Redacted.371a3fa4.pdf","local_path":"files/CG7Nr57od6Noa45MhbCCe0QB.pdf"},"config":{}}}}}