{"data":{"id":"sbm37a47b3dd9449ac86aa71","short_id":81,"created":"2025-09-03T07:02:54.169Z","space_id":"spc36e573d0a3f7d764ba5a0","project_id":"prj36e56fbec442ea80abc09","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Jenny Samiec","submission_5bfc8c":"fil39549ecaef32c5054e512","name-of-organisa_9974be":"Woodside Energy"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil39549ecaef32c5054e512":{"id":"fil39549ecaef32c5054e512","bucket":"files-au-climate","remote_path":"cca/p/prj36e56fbec442ea80abc09/submission/spc36e573d0a3f7d764ba5a0/Woodside_Energy.6ac8f039.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj36e56fbec442ea80abc09/submission/spc36e573d0a3f7d764ba5a0/Woodside_Energy.6ac8f039.pdf","filename":"Woodside Energy.pdf","transcribed":"Please direct all responses/queries to:\nPeter Metcalfe\nVice President Climate, Sustainability & Energy Policy\nE:\n\nWoodside Energy Group Ltd\nACN 004 898 962\nMia Yellagonga\n11 Mount Street\nPerth WA 6000\nAustralia\nT: +61 8 9348 4000\nwww.woodside.com\n\n3 September 2025\n\nClimate Change Authority\nGPO Box 2013\nCanberra ACT 2601\nBy email: consultation@climatechangeauthority.gov.au\n\nDear Review Team\n\nWOODSIDE SUBMISSION TO CLIMATE CHANGE AUTHORITY 2025 ISSUES PAPER CONSULTATION\n\nWoodside welcomes the opportunity to comment on the Issues Paper for the 2025 Annual Progress Report and provides the following information for consideration. In addition to this submission, as a member company of the Australian Energy Producers (AEP), and the Australian Industry Greenhouse Network (AIGN), we also draw your attention to their respective submissions.\n\nAbout Woodside\nWoodside is a global energy company founded in Australia, providing reliable and affordable energy to help people lead better lives. Driven by a spirit of innovation and determination, we established the liquefied natural gas (LNG) industry in Australia 35 years ago and today supply a growing base of customers. We have reliably delivered natural gas to homes and businesses in Australia for decades, supporting the development of local industry and driving economic prosperity.\n\nWoodside’s climate strategy is integrated throughout our company strategy: to thrive through the energy transition with a low cost, lower carbon, profitable, resilient and diversified portfolio. 1 Our climate strategy has two key elements: reducing our net equity Scope 1 and 2 greenhouse gas emissions and investing in products and services for the energy transition.\n\nThe key recommendations of our submissions, detailed in Attachment 1, are that:\n\n• The energy transition must deliver energy security and affordability as well as emissions reduction.\nAchieving this requires policy settings that enable a whole-of-economy approach to investment in\nenergy supply and decarbonisation, that is technology neutral, economically efficient, and protects\nAustralia’s international competitiveness.\n\n1\nFor Woodside, a lower carbon portfolio is one from which the net equity Scope 1 and 2 greenhouse gas emissions, which includes the use of offsets, are being reduced towards targets, and into which new energy products and lower carbon services are planned to be introduced as a complement to existing and new investments in oil and gas. Our Climate Policy sets out the principles that we believe will assist us achieve this aim.\n• The roles of gas and Carbon Capture and Storage (CCS) are underrepresented in important policy\nsettings of Australia’s approach to the energy transition. The intent of the Future Gas Strategy which\naddresses the role of gas and CCS should be applied across all government policies.\n• Environmental approvals must meet expectations for rigour, be streamlined and timely, to enable the\nsignificant investment needed to deliver an energy system that is secure, lower-emissions, and\ncontributes to the nation’s ongoing prosperity.\n• The Safeguard Mechanism should remain stable and predictable, with proportional contributions\nfrom industry and flexibility to pursue least-cost abatement.\n\nWe look forward to the Annual Progress report and welcome the opportunity to meet with the CCA in the future to discuss this feedback in detail.\n\nYours sincerely,\n\nTony Cudmore\nExecutive Vice President – Sustainability, Policy & External Affairs\nAttachment 1: Issues Paper Response\n\nSupporting and enabling the transition to a net zero economy\n\nQuestion 1. How well is the Australian Government supporting the transition to net zero?\n\nQ1 Woodside supports the Australian Government’s efforts to reduce emissions in line with its\nWoodside current Nationally Determined Contribution to the Paris Agreement and acknowledges the\nResponse progress made, including reforms to the Safeguard Mechanism (SGM), development of the\nPowering the Regions Fund, and ongoing improvements to the National Greenhouse and\nEnergy Reporting Scheme (NGERS).\n\nHowever, insufficient attention has been paid over a long period of time to the importance\nof significant and timely investment in the energy supply projects needed for secure and\naffordable energy, and emissions reductions. Current policy settings do not fully\ncontemplate the positive contribution to meeting energy and decarbonisation goals that can\nbe made by fuels and technologies such as gas and CCS which have a significant amount\nto offer Australia’s and Asia's transition. Not fully including these options in policy\nconsiderations makes reaching net zero harder and more expensive.\n\nRenewables are growing, which is positive, but Australia still uses as much coal as it did in\n1989/90 (see Figure 1) because over that period there has been increased demand for\nenergy, which has absorbed additional supply. This indicates why, as renewables continue\nto increase, their impact on emissions reduction should be supported by more gas, to both\nmeet additional energy demand and substitute coal as existing coal-fired plants reach the\nend of their planned operational lives.\n\nFigure 1: Australia Electricity Generation by fuel type, physical units, financial year2\n\nAustralia’s National Electricity Market serves as an example of how higher proportions of\ngas combined with renewables can drive overall reductions in emissions intensity. The fuel\nmix in South Australian electricity generation relies on gas peaking generation for grid\nstability during periods of high renewable generation and for the reliable dispatch capacity\nit provides during periods of low renewable generation. The bar chart below demonstrates\nthe impact of a gas-renewables mix in delivering substantially lower emissions intensity (i.e.\nfewer emissions per unit of electricity generated) than coal-dominated grids, but with the\nrequirement for additional gas in order to achieve this aim.\n\n2\nAustralia Energy Statistics 2025: Table O1 Australian electricity generation, by fuel type, physical units, financial year\nFigure 2: Fuel mix and emissions intensity of select Australian states3,4,5\n\nWoodside estimates that if the emissions intensity of the other States shown in the bar chart\nmatched South Australia’s, the same amount of electricity could be generated with\napproximately ~95 MT CO2e fewer emissions. For context, Australia’s total emission in the\nyear to June 2025 were 440.2 MT CO2e, approximately 86 MT CO2e above the indicative\nvalue of Australia’s 2030 single-year point target in its Nationally Determined\nContribution 6,7.\nAustralia needs a complete approach to net zero, not one that favours certain technologies\nwhile discounting others. There is also a risk to public support for climate action when\naffordability and reliability are not sufficiently included in policy settings. The energy\ntransition must deliver secure, affordable energy alongside emissions reductions. If it fails\non any of these fronts, public trust and social consensus will erode.\n\nQuestion 2. What changes could the Australian Government make to improve the effectiveness\nof existing policies or address gaps in supporting Australia’s transition to a low-\nemissions climate resilient, and prosperous economy?\n\nQ2 Recognise the role of gas in the energy transition by applying the Future Gas\nWoodside Strategy consistently through Government policy: As indicated in the answer to\nResponse Question 1, there is significant scope to enhance the role of natural gas in supporting\nrenewables and contributing to emissions reduction in the power sector.\n\nReinstating and expediting annual offshore exploration acreage releases, alongside timely\nregulatory approvals, will help ensure future supply can be brought to market in line with\ndemand. Investment in gas-fired firming generation should be incentivised through\nmechanisms such as the Capacity Investment Scheme or the proposed Electricity Services\nEntry Mechanism (ESEM), as recommended in the NEM Review Draft Report. These\nmeasures are vital to send clear market signals and enable timely deployment.\n\n3\nAustralian Department of Climate Change, Energy, the Environment and Water, 20232024. 'Australian National Greenhouse Accounts\nFactors.'\n4\nNet Generation in GWh taken from Open Electricity: NEM for the calendar year of 2024\n5\nFuel mix percentages accessed online https://www.aemo.com.au/energy-systems/electricity/national-electricity-market-nem/data- dashboard-nem 12 months to 22 Jan 2025 and for SWIS accessed online https://opennem.org.au/\n6\nAustralian Department of Climate Change, Energy, the Environment and Water, 2025. National Greenhouse Gas Inventory Quarterly\nUpdate: March 2025.\n7\nCommonwealth of Australia 2022. Australia’s Nationally Determined Contribution Communication 2022.\nEfficient regulatory approvals: Unlocking new supply demands streamlined, effective\napprovals and regulators must make timely, sound decisions. To achieve this, Woodside\nrecommends the following actions:\n• Approval agencies should meet statutory timelines to ensure there are no\ndelays in bringing new supply to market.\n• Design EPBC Act reforms that reinforce the principle of ecologically\nsustainable development by requiring the Minister to consider both long-and\nshort-term economic, social, and environmental factors, and publish integrated\nassessments.\n• Legislate a single-agency integrated assessment model for major energy\nprojects to fast-track approvals, consistent with the Productivity Commission’s\nrecommendations.\n• Review environmental approval legislation and regulatory frameworks to\nmitigate against vexatious litigation driven by activist political agendas.\n\nPolicy support to decarbonise export industries: It is in Australia’s clear national interest\nthat its export industries thrive, both because of the jobs and export earnings, but also\nbecause these industries can help support development, prosperity and security in Asia\nand with other trading partners. To remain a reliable supplier while meeting domestic\nclimate goals, we must reconcile the remaining emissions with credible decarbonisation\npathways.\nTargeted policy support could accelerate emissions reduction in established export sectors,\nespecially given their role in global supply chains. Whilst the SGM should provide\nconfidence to our export customers that the greenhouse gas emissions from Australian\ncommodity supply have been regulated, in the absence of a clear green premium in export\nmarkets it is not certain that this attribute of Australian production will be renumerated. This\nraises the risk that the costs of decarbonisation could undermine competitiveness if not\naddressed. Mechanisms to ensure a level playing field, ensuring our exports compete fairly\nand support both climate and economic objectives, should be considered.\nSupport CCS domestically and as an export service: Carbon Capture and Storage\n(CCS) is a strategic and material investment opportunity for Australia. It offers a pathway\nto reduce emissions across hard-to-abate sectors while positioning Australia as a global\nleader in lower-carbon services. Government support is essential to unlock this potential\nboth domestically and as an export capability.\nAccelerating bilateral agreements (e.g. with Japan) for cross-border carbon dioxide\ntransport would create the opportunity for large-scale CCS facilities, delivering the\neconomies of scale needed for commercial viability. Establishing decarbonisation hubs with\nshared infrastructure and access to firmed, lower-carbon power would further reduce costs\nand deployment timelines.\nAlign energy policy and finance frameworks to support consistent investment\nsignals: The Australian Sustainable Finance Institute (ASFI) sustainable finance taxonomy\nshould be revised. It is misaligned with the Future Gas Strategy on gas and CCS and risks\ndistorting capital markets and diverting investment from otherwise sound sectors.\nDeploying renewable energy infrastructure\n\nQuestion 3. What are the main challenges to deploying the renewable energy and related\ninfrastructure needed to reach Australia’s energy targets?\n\nQ3 In Woodside’s experience there are three main challenges: the slow pace of approvals to\nWoodside deploy new energy infrastructure (refer to question 2), the requirement to address the\nResponse challenge of intermittency of renewables at high system penetration levels, and constraints\non how quickly renewable energy can be deployed.\nThe challenge of intermittency can be addressed by utilising natural gas fired generation\nas a firm source of power, enabling higher levels of renewables deployment and emissions\nreduction (in addition to storage technologies).\nEven with progress on intermittency and regulatory approvals, there are still limits on how\nquickly renewable energy can be deployed, driven by supply chain limitations, labour\navailability, and capital availability. This means that replacing the capacity from retiring\ncoal-fired power stations and expanding the grid to meet growing demand from\nelectrification, such as for data centres and electric vehicles is likely to be a continuing task\nfor the medium to long term. Australia is still a long way from deploying enough renewable\ncapacity to meet its objectives. The Climate Change Authority’s 2024 Progress Report\nunderscores this challenge, projecting an 8 GW shortfall against the additional 33 GW\nrequired to meet Australia’s 82% renewable electricity target by 2030.\nThese factors mean that natural gas will need to play a critical role in Australia’s energy mix\nfor a significant period of time, as articulated in the Future Gas Strategy. Policymakers\nshould therefore ensure gas is appropriately integrated into national planning and\ndecarbonisation policy settings.\nQuestion 4 What can the Australian Government do to address these challenges?\n\nQ4 Refer to question 2\nWoodside\nResponse\n\nThe Safeguard Mechanism\n\nQuestion 5 How effective is the Safeguard Mechanism in driving onsite emissions reductions at\nAustralia’s largest industrial facilities since its 2023 reform?\n\nQ5 When the SGM reforms were announced in 2022, Woodside described the reformed SGM\nWoodside as an ambitious yet achievable framework for driving emissions reductions at Australia’s\nResponse largest industrial facilities. In the first compliance year of the reforms, the mechanism has\ndelivered on some of its initial goals such as tightening baselines and removing excess\nheadroom.\nHowever, some elements still need refinement, including the methodology for setting\nemissions intensities for new facilities that have not been appropriately adjusted for\nAustralian circumstances (including adoption of benchmarks that are too narrow and have\ncharacteristics not replicable in Australian conditions) and limited access to decarbonisation\nsupport for emissions-intensive trade exposed facilities. We look forward to contributing to\nthe 2026–27 review and have outlined potential improvements to the mechanism in our\nresponse to Question 6.\nQuestion 6 What changes could the Australian Government make to the mechanism to help\nachieve Australia’s emissions reduction targets?\n\nQ6 Maintain proportional share: Woodside supports a whole-of-economy approach to\nWoodside emissions reduction, and it is critical that the mechanism maintains a proportional\nResponse contribution from covered facilities to Australia’s overall emissions targets, along with\nconsideration of how emissions reductions could be addressed more broadly across the\neconomy.\nImprove methods for assessing ACCU supply and demand expectations. Given the\nsize and scale of decarbonisation challenges at many industrial emitters across the\neconomy, it is likely that access to Australian Carbon Credit Units (ACCUs) will continue\nto be an important element of national decarbonisation policy for a significant period of\ntime. Assessment of ACCU supply and demand should be based on evidence from\nindustry’s actual plans rather than the extrapolation of scenario-based trendlines. An\nexample would be to establish a Carbon Credits Statement of Opportunities, modelled on\nAEMO’s equivalents for gas and electricity. This would better inform Government of the\nneed to take action to increase supply, for example by approving more ACCU methods,\nor by allowing international carbon credits to be used for SGM compliance consistent with\nArticle 6 of the Paris Agreement, which Woodside recommends the Government work\ntowards.\nNew and expanded gas projects: Revise the criteria for setting baselines for new and\nexpanded facilities to realign with the policy intent to adjust benchmarks for Australian\nconditions.\nCompliance flexibility arrangements:\n• Maintain unrestricted ACCU use under the SGM, as it provides essential flexibility\nfor facilities where decarbonisation options do not align with the legislated decline\nrate.\n• Accelerating development of new crediting methods and enabling high-integrity\ninternational credits overtime will support a deeper, more liquid offsets market.\n• Remove the 30% Australian Carbon Credit Unit baseline reporting rule.\nPolicy support for export industry competitiveness: Refer to question 2.\n\nQuestion 7 What additional incentives could help drive on-site emissions reductions?\n\nQ7 Electrification of LNG and other industrial sites is capital intensive and operationally\nWoodside complex, particularly when retrofitting existing infrastructure. To support cost-effective\nResponse emissions reduction where viable, government should amend SGM rules to incentivise\nrenewable power purchase or the import of lower-carbon electricity from external sources.\nQuestion 8 How can reporting on the Safeguard Mechanism be enhanced to build community\nconfidence and enable better oversight?\n\nQ8 As most covered facilities transition to mandatory climate-related financial disclosures,\nWoodside these disclosures will provide structured and comparable information on forward-looking\nResponse climate strategies, reducing the need for duplicative reporting requirements.\n\nQuestion 9 How could the Authority improve its approach to assessing the performance of the\nSafeguard Mechanism? (For example, the approach to estimating emissions from\nnew and expanding facilities)\n\nQ9 The CCA should strengthen its assessment of the SGM by engaging directly with industry.\nWoodside A bottom-up approach, grounded in operational data and project level insights, would\nResponse improve accuracy particularly for new and expanding facilities.","size":302104,"redacted":[],"meta":{"name":"Woodside_Energy.6ac8f039.pdf","local_path":"files/eqjXSpkLk_Iqf7dpbxJRI0-3.pdf"},"config":{}}}}}