{"data":{"id":"sbm379a27cc7f44cac2e64e6","short_id":56,"created":"2025-09-01T06:55:33.503Z","space_id":"spc36e573d0a3f7d764ba5a0","project_id":"prj36e56fbec442ea80abc09","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Pauline Kennedy","submission_5bfc8c":"fil379a2783ae4436242848d","name-of-organisa_9974be":"bp Australia"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil379a2783ae4436242848d":{"id":"fil379a2783ae4436242848d","bucket":"files-au-climate","remote_path":"cca/p/prj36e56fbec442ea80abc09/submission/spc36e573d0a3f7d764ba5a0/2025_09_01_bp_2025_issues_paper_final.23443c1d.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj36e56fbec442ea80abc09/submission/spc36e573d0a3f7d764ba5a0/2025_09_01_bp_2025_issues_paper_final.23443c1d.pdf","filename":"2025 09 01 bp 2025 issues paper - final.pdf","transcribed":"bp Australia Pty Ltd\nA.B.N. 53 004 085 616\n717 Bourke Street\nDocklands, Victoria 3008\nAustralia\n\n1 September 2025\n\nbp Australia’s submission to the Climate Change Authority’s 4th Annual Review bp Australia welcomes the opportunity to provide our views to inform the Climate Change\nAuthority’s 4th Annual Review.\n\nAbout bp bp’s purpose is to deliver energy to the world, today and tomorrow.\n\nWe are an integrated energy company, serving customers across all sectors, from light vehicles to heavy transport, rail, aviation, and maritime. Our history in Australia spans more than a century, and our customers are at the heart of our operations across all states and territories. Through our growing network of over 1,400 retail sites and bp pulse charging stations, we provide the convenience, mobility, and energy solutions they rely on.\n\nWe’re also integrating our natural gas capabilities with power trading and growth in low-carbon markets, including wind, solar, hydrogen, and carbon capture and storage. Our business model and service offerings continue to evolve with our customers’ needs, today and into the future.\n\nGlobally, bp aims to be net zero across our operations (scope 1 & 2), and in the energy products we sell (life-cycle emissions intensity) by 2050 or sooner. You can read more about our net zero plans in our most recent sustainability report here.\n\nAdditional policy is needed to drive emissions reduction across the whole economy\n\nAustralia has advanced some important policy in support of its transition to net zero. For example, bp welcomed the passage of The Climate Change Act and the Future Made in\nAustralia Act. Policies such as the reformed safeguard mechanism, the capacity investment scheme, the Rewiring the Nations funding, new vehicle emissions standard, the Hydrogen\nHeadstart and hydrogen tax credits are supporting planned investments aligned with Australia’s energy transition.\n\nTo achieve net-zero, all sectors of the economy will need to contribute and will require some form of emissions reduction policy to drive the sectoral pathways assessed by the CCA, and as\n\nPage 1 of 5\npart of the forthcoming sector decarbonization plans. We encourage the CCA to provide advice to Government in its annual report on some of the remaining gaps in the policy suite. We provide additional detail on these specific gaps below.\n\nFurther, we encourage the CCA and Australian Government to leverage the experience of other countries in designing additional policies. We believe stable policies that provide an explicit or implicit price on emissions should be prioritized. We also believe the transition will require the uptake of a range of different abatement solutions and technologies and encourage policy to reflect this; there is no one-size-fits-all solution. Energy users will deploy different solutions depending on their specific circumstances and energy needs. It is important that\nAustralia’s policy in support of the energy transition remains open to all options and does not unduly disadvantage any viable options. bp prefers market-based policies that allow different abatement solutions to compete, with incentives aligned to emission reduction outcomes.\n\nUrgent policy is needed to encourage the uptake of low carbon liquid fuels\n\nWe see a significant role for low carbon liquid fuels (LCLFs) in reducing Australia’s emissions.\nLiquid fuels are a significant part of Australia’s overall energy use. We expect demand for liquid fuels to remain high in the medium to long-term, despite the welcome current policies designed to encourage the replacement of smaller vehicles with lower emissions intensive alternatives. Some of Australia’s liquid fuel use is not easily electrified (e.g., aviation, marine, some long-distance heavy road transport and rail) or will take some time to electrify (e.g., mining and construction). LCLFs are available today and can be used in today’s vehicle and equipment fleet and supplied using existing infrastructure. This makes policy to drive the uptake of these fuels an important near-term option for achieving Australia’s emission reduction targets.\n\nIt is bp’s view that some form of regulated demand either via a low carbon fuel standard or a blending mandate is necessary to drive the uptake of LCLFs and give the domestic industry the certainty it needs to invest. It also provides fuels users with more certainty on the policy settings they will face in planning their decarbonization. We believe that taking a fuel system wide approach is preferable – given the integrated nature of the supply system (i.e. it is difficult to design and implement policies targeting certain end consumers, for example in the diesel supply chain). We also believe that for liquid fuels, emission reduction incentives need to align with the lifecycle emissions of different fuels to avoid unintended emissions outcomes upstream from combustion.\n\nAustralia has all the ingredients to be a globally competitive producer of LCLFs – abundant feedstocks, existing capability and knowhow, and persistent demand as the economy moves to net zero. With the right policy settings, a domestic industry can create regional jobs, improve\n\nPage 2 of 5\nsovereign capability and fuel security, as well as support emission reduction. But LCLFs and the feedstocks needed to produce them will be traded on global markets. Other countries are moving forward with policies and supporting investment in new production capacity. The window for Australia to act is now, otherwise Australia is likely to remain an exporter of its feedstocks and import the finished LCLFs it needs to reach net zero. bp welcomed Government’s commitment in 2024, that it would assess design options for a regulated demand mechanism to drive the uptake of emissions reductions across the liquid fuel system. We encourage this work to progress at pace.\n\nThere is a continued role for gas in the transition bp welcomed the Australian Government’s Future Gas Strategy that clearly recognizes the critical role natural gas will play in Australia’s energy transition. Natural gas has a key role to play – now and for decades to come – in supplying the energy the world needs to enable an orderly transition to net zero and contributing to improvements in local air quality.\n\nIn an Australian context, we welcome the Government’s ongoing efforts to implement recommendations of the Future Gas Strategy in consultation with industry to help ensure principled ambitions are matched with practical and achievable implementation. Natural gas will have a role to play in firming renewables, displacing coal generation and as industry feedstock in Australia and the region. It is important therefore that climate policy recognise the role of gas in the transition, does not unduly prevent necessary investments, provides incentives to reduce emissions from the production and use of gas in a consistent way to other emissions sources, and includes the sector in programs designed to facilitate more rapid emissions reductions as are provided to other technologies and sectors.\n\nCCUS is a critical technology and needs more attention from policy makers\nThe CCA identified CCUS as an important abatement technology for many of Australia’s industries in its sector pathways review, as well as identified some current barriers to its adoption. bp agrees that CCUS can play a vital role in limiting GHG emissions and supporting global efforts to meet the goals of the Paris Agreement. It can help manage GHG emissions in parts of the economy where full electrification is technically or economically infeasible.\n\nCCS is a proven technology with storage deployed since the 1970s. However, supportive government policies are needed to make projects commercial, enabling deployment at scale and supporting cost reduction.\n\nThe CCA also rightly identified storage of carbon dioxide as a potential new low emissions export opportunity for Australia. We would like to see policy mechanisms in support of CCUS akin to support provided for other technologies and economic opportunities like renewable electricity, renewable hydrogen and green iron. Australia can leverage the experience of other\n\nPage 3 of 5\ncountries who are implementing effective policy. For example, other countries are supporting the development of CCS hubs, providing financial support like contracts-for-difference and underwriting some of the project-on-project risks to align investments in capture, transport and storage operations.\n\nRenewable electricity adoption is more than the NEM.\nThe CCA has consistently advised that decarbonizing Australia’s electricity and supporting the electrification across the economy is key to Australia’s net zero transition.\n\nUnderstandably the CCAs advice to date and Government’s policy has focused mostly on decarbonizing Australia’s main electricity grids. However, a large part of Australia’s energy demand is outside of the main electricity grids. This energy demand will also need to electrify and require substantial additional renewable electricity capacity to be built.\n\nThese investments will face many of the same barriers as grid-connected investments, but in addition, will often need to be built in remote locations, depend on entirely new transmission infrastructure, and address the project-on-project risks that arise because there is no regulated market structure to leverage. Overcoming these challenges will require tailored policy solutions. bp encourages the CCA to build on its previous advice and provide specific recommendations to government on policy that can support the decarbonization of electricity and the electrification outside of the NEM.\n\nNeed to accelerate regional and mix-use EV charging infrastructure. bp agrees with the CCAs assessment that investment in charging infrastructure will need to stay ahead of the adoption of electric vehicles. But developing charging (and enabling) infrastructure ahead of the market is not always commercial.\n\nTo continue improving the availability and accessibility of fast-charging EV infrastructure, especially in regional locations at peak seasonal times (i.e. summer holidays in coastal towns), we recommend ongoing EV infrastructure grants in these locations.\n\nPrioritising funding in this manner supports a more comprehensive build-out of charging infrastructure. It ensures regional tourism may prosper and city-based motorists (the largest group of early EV adopters) are reassured of destination-charging options. Lastly, it supports an equitable energy transition where all parts of the community participate.\n\nWe also encourage government investment in multi-use charging infrastructure that can accommodate both passenger and heavy vehicles. This would allow a network in support of heavy vehicle electrification to be built out ahead of when it would otherwise, with the charging infrastructure leveraged in the short-term by passenger vehicles.\n\nPage 4 of 5\nConclusion\nWe acknowledge the significant amount of advice the CCA has prepared over the past year and the forthcoming release of the Government’s 2035 emissions reduction target, net zero and sector plans. We are hopeful the CCAs 2025 annual advice can usefully focus on remaining gaps – some of which we have identified in this submission. We are happy to provide further briefing as useful on matters set out in our submission and look forward to working with CCA as it finalizes its advice to Government.\n\nPage 5 of 5","size":98140,"redacted":[],"meta":{"name":"2025_09_01_bp_2025_issues_paper_final.23443c1d.pdf","local_path":"files/zfsZWuDzNZxfMaPdWD3MFjzU.pdf"},"config":{}}}}}