{"data":{"id":"sbm36f568af514d82b7833ae","short_id":49,"created":"2025-07-31T07:09:05.233Z","space_id":"spc35f39a68c3255bca82dcb","project_id":"prj35f39a54b2b946a3ebba7","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil36f568914c4d7f5fafa0d","8q21898g":["answer_the_surve","09399e"],"zovp5q48":"bp Australia","upload-a-submiss_9dbd27":"fil36f567ba624dee8856d85","would-you-like-t_08a393":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil36f567ba624dee8856d85":{"id":"fil36f567ba624dee8856d85","bucket":"files-au-climate","remote_path":"climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/2025_July_bp_submission_to_draft_GO_rules_and_methodology.0163099a.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/2025_July_bp_submission_to_draft_GO_rules_and_methodology.0163099a.pdf","filename":"2025 July bp submission to draft GO rules and methodology.pdf","transcribed":"bp Australia Pty Ltd\nA.B.N. 53 004 085 616\n717 Bourke Street\nDocklands, Victoria 3008\nAustralia\n\n1 August 2025 bp Australia submission to the Draft rules and methodology for the Guarantee of Origin bp Australia welcomes the opportunity to review and provide feedback on the draft rules and methodology for the Guarantee of Origin (GO). We acknowledge that the initial focus of the GO is on setting the overarching framework and the estimation of emissions for the hydrogen PGO and REGO. bp has an interest in arrangements for both the REGOs and hydrogen PGO, but has also reviewed the drafts for applicability for the proposed future PGOs for LCLFs.\nAbout bp bp has been in Australia for over 100 years with operations in every state and territory including:\n• Fuels to consumers and on-road / offroad business fleets, via a network of import\ninfrastructure, terminals and retail network (with convenience offering).\n• EV charging available at select sites in Queensland, New South Wales, Victoria, Tasmania,\nWestern Australia and the ACT.\n• Aviation and marine fuel supply across air and marine ports.\n• Supply of lubricants (Castrol)\n• Lightsource bp (LSbp) - a major developer and operator of commercial scale solar farms\n• Gas interests in Western Australia as a foundation partner of the Woodside-operated\nNorthwest Shelf Joint Venture (JV) and are developing the Browse project with our JV\npartners. We’re working on ways to decarbonise these operations to provide domestic and\nexport natural gas.\n• Working with partners exploring the possibility of a Carbon Capture and Storage (CCS) hub,\nAngel, off the coast of Western Australia.\n• Progressing plans for an energy hub in Kwinana to potentially produce green hydrogen and\nrenewable fuels (SAF and renewable diesel).\nDetailed feedback on the draft rules\nPart 1 section 5: Approved auditors.\n\nConsideration should be given to how this would work for auditing data on supply chains outside of Australia – important for LCLFs. We think consideration could be given to leveraging\n\nPage 1 of 5\ninternational certification systems to support claims under the GO. GO Audits could then focus on whether those certification systems align with GO and that the producer has the certificate from that system to support claims.\n\nPart 1 section 6: related schemes.\n\nWe understand that as the PGO for LCLFs is developed additional international schemes will be added, for example, international schemes like CORSIA and other countries LCLF mandates?\n\nSection 16: Delivery profile.\n\nFurther consideration/clarification is needed to understand how the GO will avoid different treatment of delivery emissions between dedicated pipeline all the way to the customer and just to the entry point of shared pipeline infrastructure. This is important where a PGO is used in the supply chain of another PGO. bp assumes the intention would be to have an equivalent basis for carbon intensity regardless of how a product is delivered. This will be important particularly when different suppliers of the same product are competing based on carbon intensity. The GO should avoid advantaging one over another just because of the emissions accounting approach to delivery emissions.\n\nFurther consideration and clarity is need to understand how delivery emissions might be apportioned for products that are blended, noting LCLFs will likely be supplied blended.\nBlending can occur at the refinery or further down the supply chain. An equivalent approach will be needed for dealing with these emissions.\n\nA producer won’t always know how the product will be delivered to the end consumer for liquid fuels. For example, fuel could enter a shared pipelines and then be transported by vehicle or direct via pipeline to end consumer.\n\nSection 18. Consumption profile application.\n\nSustainable aviation fuel is by definition a blend of SPK and jet fuel to a maximum of 50% blend. Since proposal is to issue GO only for the SPK will always be a blend when consumed.\nNote the SPK will enter the shared supply infrastructure well before the airport tank.\n\nSection 23. Paragraph 23(1)(e) &(f).\n\nIt would be good for the rules to set out how a grid will be defined. It would also be good to be clearer that this is demonstrated/evidenced by the associated REGO. Also, it would be good for the legislative instrument for the HPTI grid matching arrangements to also be made.\n\nParagraph 23(g) additional attributes.\n\nPage 2 of 5\nIt would be preferable to have greater clarity on the definition of “types of water” in the schedule. Also, since the policy intention is to support claims about the sustainability of the water used, additional guidance/frameworks on what constitutes a “sustainable” water source would be needed. bp anticipates for LCLFs this will be a very important aspect of the GO framework. We believe that other environmental and social sustainability attributes will need to be demonstrated if the industry is to maintain its integrity and social license. bp sees many of these other criteria being defined in related international arrangements. bp believes that specific standards and/or frameworks for how these additional attributes would be determined within the GO will be necessary and likely for these claims to also be subjected to third-party audit/assurance.\n\nSection 24: certificate post-production information.\n\nAgain further consideration needed to avoid the different treatment of product that are delivered by shared infrastructure and product delivered by dedicated pipeline/transport etc.\nWe also think that it would be too difficult with a delivery system such as liquid fuels that involves multiple pathways to customers, for each entity within that delivery system to have a separate profile and for the producer to then ensure they are all matching with date with the production data.\n\nFurther consideration maybe needed with regard to the interaction with SMCs, as the use of these for compliance toward the Safeguard mechanism may also be reported as part of mandatory climate financial reporting and reflected in entities transition planning etc. Since\nPGOs will also potentially be used to make claims as part of these disclosures suggest worth additional consideration on the interaction between SMCs and PGOs to ensure no double claiming of the same emissions reductions.\n\nSection 26: addition of consumption information. Group consumption profiles.\n\nFor liquid fuels it may not be possible to determine the number of consumers. That’s not how the fuel supply system is measured/monitored, rather based on volumes.\n\nAnnual reconciliation checks.\n\nIt will be important the guidelines from the Regulator on the supporting documentation are made available well in advance. Systems will need to be developed to ensure this is evidence is collected. bp hopes the Regulator may be able to leverage international certification systems such as ISCC to evidence claims for inputs etc.\n\nPart 7 – Audits.\n\nBp anticipates that scheduled audits for some PGOs will need to be more frequent than others.\nFor example, the supply chain and production of hydrogen will typically be much shorter and\n\nPage 3 of 5\nmore stable over time than a supply chain for LCLFs. For LCLFs, supply chains are longer, likely include imports, are more diverse, can change frequently even within a year, and the delivery method may also change even within a year.\n\nAudit team leader.\n\nConsideration should be given to how the PGO audit system will audit international supply chains. We recommend some consideration be given to leverage existing international certification providers and considering how the PGO auditors could use those certifications as evidence within the audit approach in Australia.\n\nRecord keeping.\n\nAgain consideration should be given to the types of records needed for international supply chains. These may not always be in English. And would the producer be required to keep direct evidence of its supply chain or could it rely on an international certification system, which collects and audits evidence along the supply chain.\n\nFeedback on the draft methodology\nMateriality of emissions.\n\nFor some PGOs (LCLFs, renewable gases) materiality will be a consideration for emissions associated with supplied inputs. We suggest that producers are provided an opportunity to either use default values OR calculate their own emissions based on agreed model/methodology for inputs. This would require that materiality is addressed within the approach for setting defaults as well as the agreed model/methodology.\n\nSection4: definitions.\n\nInput. For other types of PGO the definition will need to be amended.\n\nSection 7: missing parameters.\n\nWe recommend that work is undertaken urgently to address the gap in the NGAF on biofuels and other novel alternative fuels as these will be central to the LCLFs stream, and encourage use of LCLFs within supply chains of other PGOs. This would hopefully reduce the reliance on the missing parameters approach.\n\nSection 10/11. Input-source specific emission factors. bp assumes the methodology will set out how the emissions data from the supplier is to be estimated and the evidence/information that would be needed to demonstrate its accuracy. bp assume it would be consistent with NGER determination. Further consideration may be needed for input related emissions sources that are not covered by NGER determination for example, those that occur outside of Australia. Also, since LCLFs and renewable gases may\n\nPage 4 of 5\nhave longer supply chain further consideration may be need on how this would work if there was more than one supplier along the input supply chain.\n\nSection 13: Dedicated pipeline.\n\nIt would be good to understand how the emissions would be calculated for hydrogen (or other products) that are delivered via a shared pipeline. bp assumes the GO system would ensure the carbon intensity of hydrogen provided as an input into other GO processes has an equivalent treatment when delivered by a dedicated pipeline and when delivered in a shared pipeline say via a gas pipeline. With the different definition of the consumption gate, it seems possible that the emissions associated with running a dedicated pipeline are included while share of emissions from running a shard pipeline are not.\n\nSection 15: Storage vessel.\n\nIt would be good to clarify treatment of storage of GO product that has been blended before it reaches the production gate. LCLFs will often be blended and then stored at the refinery, but not exclusively as blending could occur during delivery.\n\nDefault emissions factors. Part 1 – Default vehicle emissions factors.\n\nIdeally the methodology would set out how these can be adjusted if the vehicle is using a LCLF with an associated GO or if it is electric.\n\nConclusion bp is encouraged by the proposed workplan to build out the GO system. We welcome further engagement with you on the matters raised here and as the other streams of work progress.\n\nPage 5 of 5","size":130702,"redacted":[],"meta":{"name":"2025_July_bp_submission_to_draft_GO_rules_and_methodology.0163099a.pdf","local_path":"files/uw9gl6o_svRX0lNyBnDJK1qI.pdf"},"config":{}},"fil36f568914c4d7f5fafa0d":{"id":"fil36f568914c4d7f5fafa0d","bucket":"files-au-climate","remote_path":"climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/2025_July_bp_submission_to_draft_GO_rules_and_methodology.fd5f6fa5.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/2025_July_bp_submission_to_draft_GO_rules_and_methodology.fd5f6fa5.pdf","filename":"2025 July bp submission to draft GO rules and methodology.pdf","transcribed":"bp Australia Pty Ltd\nA.B.N. 53 004 085 616\n717 Bourke Street\nDocklands, Victoria 3008\nAustralia\n\n1 August 2025 bp Australia submission to the Draft rules and methodology for the Guarantee of Origin bp Australia welcomes the opportunity to review and provide feedback on the draft rules and methodology for the Guarantee of Origin (GO). We acknowledge that the initial focus of the GO is on setting the overarching framework and the estimation of emissions for the hydrogen PGO and REGO. bp has an interest in arrangements for both the REGOs and hydrogen PGO, but has also reviewed the drafts for applicability for the proposed future PGOs for LCLFs.\nAbout bp bp has been in Australia for over 100 years with operations in every state and territory including:\n• Fuels to consumers and on-road / offroad business fleets, via a network of import\ninfrastructure, terminals and retail network (with convenience offering).\n• EV charging available at select sites in Queensland, New South Wales, Victoria, Tasmania,\nWestern Australia and the ACT.\n• Aviation and marine fuel supply across air and marine ports.\n• Supply of lubricants (Castrol)\n• Lightsource bp (LSbp) - a major developer and operator of commercial scale solar farms\n• Gas interests in Western Australia as a foundation partner of the Woodside-operated\nNorthwest Shelf Joint Venture (JV) and are developing the Browse project with our JV\npartners. We’re working on ways to decarbonise these operations to provide domestic and\nexport natural gas.\n• Working with partners exploring the possibility of a Carbon Capture and Storage (CCS) hub,\nAngel, off the coast of Western Australia.\n• Progressing plans for an energy hub in Kwinana to potentially produce green hydrogen and\nrenewable fuels (SAF and renewable diesel).\nDetailed feedback on the draft rules\nPart 1 section 5: Approved auditors.\n\nConsideration should be given to how this would work for auditing data on supply chains outside of Australia – important for LCLFs. We think consideration could be given to leveraging\n\nPage 1 of 5\ninternational certification systems to support claims under the GO. GO Audits could then focus on whether those certification systems align with GO and that the producer has the certificate from that system to support claims.\n\nPart 1 section 6: related schemes.\n\nWe understand that as the PGO for LCLFs is developed additional international schemes will be added, for example, international schemes like CORSIA and other countries LCLF mandates?\n\nSection 16: Delivery profile.\n\nFurther consideration/clarification is needed to understand how the GO will avoid different treatment of delivery emissions between dedicated pipeline all the way to the customer and just to the entry point of shared pipeline infrastructure. This is important where a PGO is used in the supply chain of another PGO. bp assumes the intention would be to have an equivalent basis for carbon intensity regardless of how a product is delivered. This will be important particularly when different suppliers of the same product are competing based on carbon intensity. The GO should avoid advantaging one over another just because of the emissions accounting approach to delivery emissions.\n\nFurther consideration and clarity is need to understand how delivery emissions might be apportioned for products that are blended, noting LCLFs will likely be supplied blended.\nBlending can occur at the refinery or further down the supply chain. An equivalent approach will be needed for dealing with these emissions.\n\nA producer won’t always know how the product will be delivered to the end consumer for liquid fuels. For example, fuel could enter a shared pipelines and then be transported by vehicle or direct via pipeline to end consumer.\n\nSection 18. Consumption profile application.\n\nSustainable aviation fuel is by definition a blend of SPK and jet fuel to a maximum of 50% blend. Since proposal is to issue GO only for the SPK will always be a blend when consumed.\nNote the SPK will enter the shared supply infrastructure well before the airport tank.\n\nSection 23. Paragraph 23(1)(e) &(f).\n\nIt would be good for the rules to set out how a grid will be defined. It would also be good to be clearer that this is demonstrated/evidenced by the associated REGO. Also, it would be good for the legislative instrument for the HPTI grid matching arrangements to also be made.\n\nParagraph 23(g) additional attributes.\n\nPage 2 of 5\nIt would be preferable to have greater clarity on the definition of “types of water” in the schedule. Also, since the policy intention is to support claims about the sustainability of the water used, additional guidance/frameworks on what constitutes a “sustainable” water source would be needed. bp anticipates for LCLFs this will be a very important aspect of the GO framework. We believe that other environmental and social sustainability attributes will need to be demonstrated if the industry is to maintain its integrity and social license. bp sees many of these other criteria being defined in related international arrangements. bp believes that specific standards and/or frameworks for how these additional attributes would be determined within the GO will be necessary and likely for these claims to also be subjected to third-party audit/assurance.\n\nSection 24: certificate post-production information.\n\nAgain further consideration needed to avoid the different treatment of product that are delivered by shared infrastructure and product delivered by dedicated pipeline/transport etc.\nWe also think that it would be too difficult with a delivery system such as liquid fuels that involves multiple pathways to customers, for each entity within that delivery system to have a separate profile and for the producer to then ensure they are all matching with date with the production data.\n\nFurther consideration maybe needed with regard to the interaction with SMCs, as the use of these for compliance toward the Safeguard mechanism may also be reported as part of mandatory climate financial reporting and reflected in entities transition planning etc. Since\nPGOs will also potentially be used to make claims as part of these disclosures suggest worth additional consideration on the interaction between SMCs and PGOs to ensure no double claiming of the same emissions reductions.\n\nSection 26: addition of consumption information. Group consumption profiles.\n\nFor liquid fuels it may not be possible to determine the number of consumers. That’s not how the fuel supply system is measured/monitored, rather based on volumes.\n\nAnnual reconciliation checks.\n\nIt will be important the guidelines from the Regulator on the supporting documentation are made available well in advance. Systems will need to be developed to ensure this is evidence is collected. bp hopes the Regulator may be able to leverage international certification systems such as ISCC to evidence claims for inputs etc.\n\nPart 7 – Audits.\n\nBp anticipates that scheduled audits for some PGOs will need to be more frequent than others.\nFor example, the supply chain and production of hydrogen will typically be much shorter and\n\nPage 3 of 5\nmore stable over time than a supply chain for LCLFs. For LCLFs, supply chains are longer, likely include imports, are more diverse, can change frequently even within a year, and the delivery method may also change even within a year.\n\nAudit team leader.\n\nConsideration should be given to how the PGO audit system will audit international supply chains. We recommend some consideration be given to leverage existing international certification providers and considering how the PGO auditors could use those certifications as evidence within the audit approach in Australia.\n\nRecord keeping.\n\nAgain consideration should be given to the types of records needed for international supply chains. These may not always be in English. And would the producer be required to keep direct evidence of its supply chain or could it rely on an international certification system, which collects and audits evidence along the supply chain.\n\nFeedback on the draft methodology\nMateriality of emissions.\n\nFor some PGOs (LCLFs, renewable gases) materiality will be a consideration for emissions associated with supplied inputs. We suggest that producers are provided an opportunity to either use default values OR calculate their own emissions based on agreed model/methodology for inputs. This would require that materiality is addressed within the approach for setting defaults as well as the agreed model/methodology.\n\nSection4: definitions.\n\nInput. For other types of PGO the definition will need to be amended.\n\nSection 7: missing parameters.\n\nWe recommend that work is undertaken urgently to address the gap in the NGAF on biofuels and other novel alternative fuels as these will be central to the LCLFs stream, and encourage use of LCLFs within supply chains of other PGOs. This would hopefully reduce the reliance on the missing parameters approach.\n\nSection 10/11. Input-source specific emission factors. bp assumes the methodology will set out how the emissions data from the supplier is to be estimated and the evidence/information that would be needed to demonstrate its accuracy. bp assume it would be consistent with NGER determination. Further consideration may be needed for input related emissions sources that are not covered by NGER determination for example, those that occur outside of Australia. Also, since LCLFs and renewable gases may\n\nPage 4 of 5\nhave longer supply chain further consideration may be need on how this would work if there was more than one supplier along the input supply chain.\n\nSection 13: Dedicated pipeline.\n\nIt would be good to understand how the emissions would be calculated for hydrogen (or other products) that are delivered via a shared pipeline. bp assumes the GO system would ensure the carbon intensity of hydrogen provided as an input into other GO processes has an equivalent treatment when delivered by a dedicated pipeline and when delivered in a shared pipeline say via a gas pipeline. With the different definition of the consumption gate, it seems possible that the emissions associated with running a dedicated pipeline are included while share of emissions from running a shard pipeline are not.\n\nSection 15: Storage vessel.\n\nIt would be good to clarify treatment of storage of GO product that has been blended before it reaches the production gate. LCLFs will often be blended and then stored at the refinery, but not exclusively as blending could occur during delivery.\n\nDefault emissions factors. Part 1 – Default vehicle emissions factors.\n\nIdeally the methodology would set out how these can be adjusted if the vehicle is using a LCLF with an associated GO or if it is electric.\n\nConclusion bp is encouraged by the proposed workplan to build out the GO system. We welcome further engagement with you on the matters raised here and as the other streams of work progress.\n\nPage 5 of 5","size":130702,"redacted":[],"meta":{"name":"2025_July_bp_submission_to_draft_GO_rules_and_methodology.fd5f6fa5.pdf","local_path":"files/chT4kqLkwDmHOTTDJ0EJVdP8.pdf"},"config":{}}}}}