{"data":{"id":"sbm37cc6790a4f94db71ab80","short_id":1,"created":"2025-09-11T01:06:13.284Z","space_id":"spc371dd6189245721ef262d","project_id":"prj371d9917e945ee21fe3f9","org_id":"org20ee740c8b3c21feb3566","content":{"8q21898g":["09399e"],"zovp5q48":"ENGIE","skip-to-end-of-s_bb8651":"yes","upload-a-submiss_9dbd27":"fil389f4e4886552e23aefd0"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil389f4e4886552e23aefd0":{"id":"fil389f4e4886552e23aefd0","bucket":"files-au-climate","remote_path":"climate-au/p/prj371d9917e945ee21fe3f9/submission/spc371dd6189245721ef262d/ENGIE.d6384857.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj371d9917e945ee21fe3f9/submission/spc371dd6189245721ef262d/ENGIE.d6384857.pdf","filename":"ENGIE.pdf","transcribed":"Add\n\nRenewable Electricity Guarantee of Origin section\nDepartment of Climate Change, Energy, the Environment and Water\nGPO Box 3090\nCanberra ACT 2601\n\n11 September 2025\n\nTo Renewable Electricity Guarantee of Origin section,\n\nGO scheme Exposure Draft legislative instruments specific to renewable electricity\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 Guarantee of\nOrigin (GO) scheme exposure drafts specific to Renewable Electricity Guarantee of Origin (REGO) certificates.\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\nENGIE is supportive of the development of the GO scheme and appreciates the Department’s ongoing engagement with stakeholders on the policy positions underpinning the scheme. ENGIE is particularly interested in the rules relating to energy storage systems, as these will be an important contributor to\nAustralia’s energy transition and have the capability to provide time-shifting of renewable energy production attributes and support Australian companies to demonstrate their renewable energy use claims.\n\nThe inclusion of energy storage systems in the GO scheme would 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.1 While it may be prudent to initially adopt a simple approach to enable the\nRules for energy storage systems to be ready for the GO scheme commencement, as noted in ENGIE’s submission to the concept paper, the Department should commit to future work programs to investigate options to align with ongoing international developments.2\n\n1\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/\n2\nENGIE 2025, Submission to Exposure Drafts of the legislative instruments that will support the GO scheme, 23 July, p. 3. Page 1\nIn the remainder of this submission, ENGIE provides feedback on the application of the Future Made in\nAustralia (Guarantee of Origin) Rules 2025 (Rules) to energy storage systems.\n\nThe time period of imported electricity should relate to the discharge from energy storage\n\nThe proposed formula for ‘demonstrated renewable electricity’ in subsection 46B(3) of the Rules does not appear to require the retired REGO certificates or surrendered LGCs to match the time period for the dispatched electricity (for example, an hour). Instead, the Rules allow the energy storage system operator to retire a REGO certificate for any eligible time period (i.e. an hour, a calendar day, a calendar month, or a calendar year) to demonstrate the electricity it has dispatched is renewable.\n\nAs stated in ENGIE’s feedback to the concept paper, the Rules should require energy storage systems to retire certificates that match the time period of the dispatched electricity.3 For example, the creation of hourly time-stamped REGO certificates based on imported electricity should require the retirement of hourly time-stamped REGO certificates. There may be unintended consequences of not requiring energy storage systems to match the time periods of retired and created REGO certificates. For example, solar generation facilities that are not co-located with energy storage systems 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. This may impact on the liquidity of hourly time-stamped REGO certificates.\n\nThere should not be misalignment in rule application between charging sources\n\nENGIE contends the Rules should treat the electricity sources for an energy storage system consistently, rather than introducing different rule application for electricity imported from the grid and direct supply electricity.\n\nIn relation to the eligible amounts of electricity imported from the grid, the Rules propose to allow a REGO certificate of any vintage (up to the 24-month expiry date) to be retired in the creation of REGO certificates from energy storage systems. In contrast, the Rules propose a shorter time period for direct supply electricity to be an eligible source for the creation of REGO certificates from energy storage systems (i.e. a month for hourly, daily or monthly certificates and a year for yearly certificates).4\n\nWhile ENGIE agrees that a 24-month ‘bankable’ period for direct supply electricity would not best reflect the practical operation of energy storage systems, a similar logic could be applied to the use of REGO certificates or LGCs. From the perspective of an energy storage system operator, the accounting methodologies should be the same regardless of the source of the electricity.\n\n3\nIbid, p. 4.\n4\nDepartment of Climate Change, Energy, the Environment and Water 2025, Consultation Paper – Future Made in Australia (Guarantee of Origin)\nExposure draft (Tranche 3), September, p. 19 Page 2\nREGO certificates from discharge should be able to retain attributes from retired REGO certificates\n\nENGIE considers that REGO certificates created from energy storage systems should retain traceability with the underlying renewable energy sources, whether that is from grid-supplied electricity or direct supply. To improve the traceability of renewable electricity dispatched from energy storage systems, the Department should update subsection 48 of the Rules to allow a REGO certificate created in respect of an energy storage system to optionally list facility-specific information from retired REGO certificates.\n\nThis change would allow energy storage system operators the option to list information such as the name and location of facilities from retired REGO certificates. The inclusion of this type of information would provide more transparency and support investors and end-users that seek to purchase REGO certificates associated with renewable electricity generated from a specific source. Some end-users, such as data centres, may want to understand the underlying source of the renewable electricity input and the additionality of the original generation facility.\n\nENGIE considers that not permitting the retention of attributes from retired REGO certificates may have other unintended consequences, such as in relation to First Nations attributes. As highlighted in the\nDepartment’s concept paper for First Nations attributes on REGO certificates, there are likely to be investors and end-users seeking to support renewable electricity projects that contribute to First Nations outcomes.5 However, energy storage system operators may be less willing to pay a premium for REGO certificates with these attributes if the attributes are not able to be carried through to the REGO certificates created from the discharge of an energy storage system. As part of its current review into proposed optional First Nations attributes, the Department should consider how these attributes can interact with the Rules for energy storage systems and increase transparency for investors and end-users.\n\nThe Rules should clarify the treatment of residual amounts for energy storage systems\n\nThe creation of certificates for shorter time periods may accumulate significant residual amounts\n\nENGIE considers the current REGO certificate size of 1 MWh may impact energy storage system operators that intend to create hourly time-stamped REGO certificates. The creation of hourly time-stamped REGO certificates will likely result in the accrual of residual amounts during most hours each day, which may lead to a significant residual amount balance accumulated at the end of every calendar month. While the monthly residual amount balance can be used to create REGO certificates6, a monthly time-stamped residual REGO certificate is likely to be less valuable than an hourly time-stamped REGO certificate, particularly in relation to electricity discharge associated with peak demand hours.\n\n5\nDepartment of Climate Change, Energy, the Environment and Water 2025, First Nations Attributes on Guarantee of Origin Certificates – Concept\nPaper, 3 September, p. 4.\n6\nFuture Made in Australia (Guarantee of Origin) Act 2024, section 92. Page 3\nTo address this concern, the Department should consider enabling the creation of fractional REGO certificates in a future iteration of the Rules. For reference, the European Union’s Renewable Energy\nDirective III of October 2023 permitted a guarantee of origin to be divided into fractions of 1 MWh.7\n\nThe Rules do not provide certainty on the treatment of residual amounts from imported electricity\n\nWhile the Future Made in Australia (Guarantee of Origin) Act 2024 (Act) is clear about the treatment of residual amounts arising from renewable electricity generation, the Act is not clear about how residual amounts should be treated when REGO certificates are retired for the purpose of creating REGO certificates from the discharge of an energy storage system.\n\nDue to losses that will occur between the charge and discharge of the storage system (as represented through the efficiency factors and auxiliary factors), there will not be a direct match between the imported electricity and the discharged electricity eligible for the creation of REGO certificates. Without a corresponding methodology to manage residual amounts arising from the import of electricity into an energy storage system and associated REGO certificate retirements, there is a risk that energy storage system operators will need to retire more REGO certificates than otherwise required each calendar month.\nSimilar to the comments raised above, creating hourly time-stamped REGO certificates will likely compound the accrual of residual amounts and increase the divergence between the actual electricity imported into the storage system and the number of REGO certificates retired at the end of every calendar month.\n\nENGIE asks the Department to update subsection 46B of the Rules to provide certainty for participants on the treatment of residual amounts that may arise from the import of electricity into energy storage systems and associated retirement of REGO certificates to demonstrate the amount of renewable electricity.\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\n7\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 4","size":190241,"redacted":[],"meta":{"name":"ENGIE.d6384857.pdf","local_path":"files/Cdd4NkrExofZl9v1Zl5-jrGt.pdf"},"config":{}}}}}