{"data":{"id":"sbm37d2cba71ca3560c0a646","short_id":5,"created":"2025-09-12T06:53:15.932Z","space_id":"spc371dd6189245721ef262d","project_id":"prj371d9917e945ee21fe3f9","org_id":"org20ee740c8b3c21feb3566","content":{"8q21898g":["09399e"],"zovp5q48":"Origin Energy","skip-to-end-of-s_bb8651":"yes","upload-a-submiss_9dbd27":"fil389f4fb532f906e7936ed"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil389f4fb532f906e7936ed":{"id":"fil389f4fb532f906e7936ed","bucket":"files-au-climate","remote_path":"climate-au/p/prj371d9917e945ee21fe3f9/submission/spc371dd6189245721ef262d/Origin_Energy.59612db7.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj371d9917e945ee21fe3f9/submission/spc371dd6189245721ef262d/Origin_Energy.59612db7.pdf","filename":"Origin Energy.pdf","transcribed":"12 September 2025\n\nRenewable Electricity Guarantee of Origin section\nDepartment of Climate Change, Energy, the Environment and Water\n\nSubmitted online: https://consult.dcceew.gov.au/\n\nGuarantee of Origin (GO) scheme Exposure Draft legislative instruments specific to renewable electricity – Consultation paper\n\nOrigin Energy Limited (Origin) welcomes the opportunity to provide comments on the legislative instruments specific to renewable electricity under the Guarantee of Origin (GO) scheme.\n\nWe are broadly supportive of the approach proposed by the department to:\n\n▪ align this scheme with existing frameworks where possible, such as the Renewable Energy Target\n(RET) framework and requirements under the National Electricity Rules (NER);\n\n▪ apply this certificate scheme to storage to recognise the important role it can play in shifting\nrenewable generation to when it is of most value to consumers;\n\n▪ explore opportunities to provide a proportionate and flexible approach where possible, including\nmethodologies for metering and certifying the source of energy for storage;\n\n▪ engage with technical working groups to discuss concepts such as the need to recognise potential\nchanges in water flows for pumped hydro separate to the provision of energy services;\n\n▪ recognise REGO certificates in the National Greenhouse and Energy Reporting Scheme\n(NGERS), noting Product Guarantee of Origin (PGO) certificates are already recognised; and\n\n▪ delay consequential changes to related frameworks till sufficient evidence is available to inform\nany potential modification, such as calculation of the RET renewable power percentage.\n\nGiven the limited time available we are unable to provide more detailed comments on the technical detail contained in this consultation. We are concerned that this material was provided with insufficient time to engage more meaningfully and note the department intends to implement the GO scheme before providing stakeholders with visibility of the full legislative documents. It is challenging to comment on paragraphs and concepts in isolation when the scheme is designed based on the interactions between the different legislative instruments.\n\nWe understand the Clean Energy Regulator intends to provide further guidance to help stakeholders navigate these instruments in collaboration with the department. We would welcome the chance to identify areas requiring further clarity within the framework. For example, how certificates deemed to be improperly created will be managed to ensure the consequences are faced by the entity that created them, such as requiring the surrender of equivalent certificates, which is a feature in similar schemes. It would be inappropriate to simply cancel these certificates once a buyer has purchased in good faith, particularly as this risk could act as a further deterrent to voluntary purchase of these certificates.\n\nPage 1 of 2\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\nGoing forward, we strongly encourage the department to take a more sequenced and strategic approach to consultation on future amendments to the legislative instruments implementing the GO scheme, such as additional methods for PGO certificates and recognition of aggregated systems through REGO certificates. Particularly given the complexity of these schemes and interactions with other related processes, such as the Consumer Energy Roadmap which will inform the operation of aggregated systems.\n\nIf you wish to discuss any aspect of this submission further, please contact at\n\nYours Sincerely,\n\nPage 2 of 2","size":102528,"redacted":[],"meta":{"name":"Origin_Energy.59612db7.pdf","local_path":"files/-rJMmB8CHiqToxnfLHF8NcsE.pdf"},"config":{}}}}}