{"data":{"id":"sbm36fa4e3bad02d937de550","short_id":54,"created":"2025-08-01T05:58:17.773Z","space_id":"spc35f39a68c3255bca82dcb","project_id":"prj35f39a54b2b946a3ebba7","org_id":"org20ee740c8b3c21feb3566","content":{"8q21898g":["09399e"],"zovp5q48":"Origin Energy","skip-to-end-of-s_bb8651":"yes","upload-a-submiss_9dbd27":"fil3741e1600685e50e218d4"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3741e1600685e50e218d4":{"id":"fil3741e1600685e50e218d4","bucket":"files-au-climate","remote_path":"climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/250801_ORG_Sub_GO_Scheme_tranche_2_Redacted.af455678.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj35f39a54b2b946a3ebba7/submission/spc35f39a68c3255bca82dcb/250801_ORG_Sub_GO_Scheme_tranche_2_Redacted.af455678.pdf","filename":"250801 - ORG Sub GO Scheme tranche 2_Redacted.pdf","transcribed":"1 August 2025\n\nDepartment of Climate Change, Energy, the Environment and Water\n\nSubmitted via email: GuaranteeOfOrigin@dcceew.gov.au\n\nLegislative instruments that will support the Guarantee of Origin (GO) scheme – Exposure Drafts\n\nOrigin Energy Limited (Origin) welcomes the opportunity to provide comments on the Department of\nClimate Change, Energy, the Environment and Water’s (DCCEEW) exposure drafts for legislative instruments that will support the Guarantee of Origin (GO) scheme.\n\nThere has been progress on the draft rules, but more is required to advance the scheme\n\nOrigin appreciates the department’s efforts to balance ensuring the integrity of the scheme and minimising administrative burden, recognising additional reporting increases the efforts required by entities, auditors and the regulator. There have been several positive developments since the first tranche in this respect, including the stated intention to allow pathways for Product Guarantee of Origin\n(PGO) certificates to cover different fuel inputs to reduce complexity and administrative requirements.\n\nThe intention to align reporting under the GO scheme with other existing schemes, such as the National\nGreenhouse and Energy Reporting Scheme (NGERS), is encouraging. But we note the decision to remove losses from delivery in both schemes effectively results in double counting of those losses, which will reduce the value of PGO certificates. Consistency within the scheme is also required, e.g. it is not clear why Renewable Electricity Guarantee of Origin (REGO) certificates will record network connection while PGO certificates record grid connection.\n\nBut more is required to refine the scheme to ensure it operates effectively. For example, the proposal to backdate certificates from when the application is made is unlikely to mitigate the impact of delays in registration as there is a risk the regulator imposes additional conditions on production which would negate these certificates. We also reiterate the concerns we made in our submission to the first tranche, e.g. inactivity for 18 months would be a more appropriate criterion for suspension and / or cancelling accounts, as requiring reactivation after 12 months introduces an unnecessary administrative burden.\n\nThe addition of further information for PGO certificates introduces material costs and complexities for the entities, auditors and the regulator. We note the Clean Energy Regulator (CER) estimates administering PGO certificates, as they are currently designed, will result in annual costs for the regulator alone of $18.1 million compared to $3.5 million for the REGO certificates. We encourage the department to consider how these costs could be reduced further to ensure certification is not prohibitively burdensome for these nascent industries. This could include only imposing hydrogen production tax incentive reporting requirements on those receiving this government support. Restricting this reporting requirement to relevant entities would be more proportionate, as well as consistent with the decision not to mandate international requirements on domestic certificates.\n\nWe continue to advocate for ensuring that only proportionate, useful and credible information is required under the GO scheme to prevent this voluntary certification from becoming prohibitively burdensome. It\n\nPage 1 of 3\n\nOrigin Energy Limited ABN 30 000 051 696 • Level 32, Tower 1, 100 Barangaroo Avenue, Barangaroo NSW 2000\nGPO Box 5376, Barangaroo NSW 2000 • Telephone (02) 8345 5000 • Facsimile (02) 9252 9244 • www.originenergy.com.au\nis also important that information reported under these schemes is targeted to the objectives of each certificate scheme. The consultation paper reaffirms that while PGO certificates certify the embodied emissions of a product, REGO certificates will be tradeable and decoupled from the physical delivery of electricity. The proposal to add details on the physical delivery and use of REGO certificates in the register does not appear consistent with the stated objective of this program. Similarly, the proposed addition of nameplate capacity is inconsistent with this objective and risks creating unnecessary costs given the requirement to evidence and audit values provided for registration and certification.\n\nWe appreciate smoothing losses for generation, and limiting eligible amounts for storage, supports credible claims for the use of renewable electricity. But we would appreciate clarification of how this is intended to interact with REGO certification, e.g. whether this will limit the creation of REGO certificates to once a month to prevent certified volumes being adjusted after the fact. Origin also values the additional guidance on treatment of below baseline REGO certificates. This includes clarification that restrictions on the creation and use of these certificates are intended to balance the potential impact on support for new renewable generation with enabling the creation of PGO certificates. We also appreciate clarification that these restrictions are intended to be transitional and that the categorisation of ‘below baseline’ will not exist after the Renewable Energy Target (RET) framework ends in 2030.\n\nHowever, greater clarity on the intended parallel operation of REGO certificates and large-scale generation certificates (LGCs) under the RET framework is required to support voluntary participation in the REGO scheme. This includes clarification of the threshold (e.g. asset capacity) which determines when an entity creates an aggregated system REGO certificate, rather than generation or storage. We appreciate aggregated systems are complex and consultation will occur into 2026, however this distinction is required now to support engagement with storage and generation certification. We also encourage the department to consider if evidence supports pursuing the legislative instruments to enable entities currently creating small-scale technology certificates (STCs) to create REGO certificates.\n\nMore generally, as we’ve noted in our response to other papers, we encourage DCCEEW to consider the timing and sequencing of its consultation on various elements of the GO scheme. It is challenging to engage with parallel consultation on a number of related processes, particularly while the available exposure draft of rules supporting implementation of the GO scheme remain incomplete. Our ability to engage is also limited by the many parallel energy / climate policy and regulatory consultations and concurrent need to manage end of financial year reporting and disclosure obligations.\n\nThe proposed hydrogen methodology must establish precedence with a suitable framework\n\nOrigin supports the intention to standardise production pathways in a consolidated methodology determination with dedicated chapters for product specific considerations, as well as the intention to ultimately enable both transitional and clean products to receive PGO certificates. There are many other positive elements within the proposed approach, such as the commitment to align with NGERS, where possible, to help reduce complexity and enable comparison between reporting under these schemes.\n\nThe use of established emissions factors is a pragmatic approach to managing complexity and the department’s commitment to reflecting the latest available factors will support continued alignment with best practice. Efficient and proportionate reporting requirements will be supported by the proposal to establish methodologies which allow for the use of different inputs, although the inclusion of a list limiting inputs in the proposed methodology appears inconsistent with this objective. Guidance on how materiality will be assessed for other projects to ensure all benefit from the proposal relaxing of reporting requirements for emissions sources found to be immaterial, to reduce the regulatory burden is required.\n\nPage 2 of 3\nThe proposed approach to establishing a pathway for hydrogen from electrolysis may set precedent for the approach taken for other technologies in the future. From this perspective, the department should note that recognising co-products within production pathways is positive and will help to ensure industry is incentivised to efficiently harness all possible outputs and minimise administrative costs for nascent industries. Valuing the contribution of by-products, such as biofertiliser and auxiliary fuels, to emissions reductions has supported project economics and the development of Denmark’s thriving biogas industry.\nWhile it is important to ensure these co-products are used or sold to avoid the risk of unintentionally rewarding waste, we support only requiring evidence that sales are genuine when additional information is requested by the regulator, as this will assist with minimising the associated reporting burden.\n\nThe proposed charging framework is overly focused on hydrogen\n\nOrigin generally supports the proposed approach to recovering costs under the GO scheme. The proposal to recover broader operational costs through annual levies, leaving activity specific costs to be recovered through fees, is pragmatic. But we reiterate our concerns about the scale of costs to be recovered through the charging framework which reflects the proposed reporting requirements, particularly given the magnitude of estimated annual costs discussed above. Especially as these estimates do not include the additional costs from compiling, evidencing and auditing the information required to register persons, pathways and certificates that entities will incur.\n\nWe support the proposal to adopt a phased approach to implementing cost recovery to mitigate the impact on the nascent industries expected to voluntarily procure PGO certificates and manage the parallel operation of the GO scheme and RET framework for electricity. However, we would appreciate confirmation that this phased approach will be applied more broadly across PGO certificates, with the charging methodology updated in parallel to any changes to the methodology determination. At this stage guidance has only been provided for projects involving hydrogen from electrolysis.\n\nIf you wish to discuss any aspect of this submission further, please contact\n\nYours Sincerely,\n\nGroup Manager, Regulatory Policy\n\nPage 3 of 3","size":104376,"redacted":[],"meta":{"name":"250801_ORG_Sub_GO_Scheme_tranche_2_Redacted.af455678.pdf","local_path":"files/Oig22Azm_gcKqHA8zzQ9La-F.pdf"},"config":{}}}}}