{"data":{"id":"sbm399271aa96cc3cd328962","short_id":46,"created":"2025-12-08T05:04:51.350Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Karan Sharma","name-of-organisa_9974be":"Alinta Energy","published-upload_e99675":"fil3b792b770fa0e5c0e3dc0"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b792b770fa0e5c0e3dc0":{"id":"fil3b792b770fa0e5c0e3dc0","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/AlintaEnergy.cbc87716.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/AlintaEnergy.cbc87716.pdf","filename":"AlintaEnergy.pdf","transcribed":"8 December 2025\n\nClimate Change Authority\n\nSubmitted through the consultation hub.\n\nIssues Paper: Enhancing the ACCU Scheme to support Australia's 2035 emissions\nreduction target\n\nAlinta Energy welcomes the opportunity to provide input to the Climate Change Authority\non the Enhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nconsultation.\n\nWe are an active investor in energy markets across Australia, with an owned and contracted\ngeneration portfolio exceeding 3,300 MW and serving more than one million electricity and gas\ncustomers.\n\nAlinta Energy supports the Commonwealth Government’s target to reduce greenhouse gas\nemissions to net zero by 2050, and the Government’s development of emissions pathways for\nall sectors to achieve the target.\n\nHowever, a significant increase in renewable generation, particularly wind, will be required for\nAustralia to meet its renewable energy and emissions reduction targets. Wind generation is\nalso essential for diversification as solar output approaches curtailment levels and as location\nbased constraints limit further expansion.\n\nMeeting national renewable energy targets is likely to be challenging under current settings.\nWith the Renewable Energy Target effectively met and approaching expiry in 2030, and with\nboth large-scale generation certificate prices and wholesale prices remaining relatively low,\ninvestment conditions for new projects are proving difficult. Government initiatives have\nsupported some developments, but progressing projects to final investment decision remains\nconstrained in the current environment.\n\nWhile the Renewable Energy Guarantee of Origin (REGO) scheme will provide transparency\non renewable energy attributes, they are designed to certify renewable generation, not to\ndeliver compliance-grade offsets or integrate with Australia’s carbon credit market. Importantly,\nREGOs will be voluntary and, based on current market signals, forward price expectations\nthrough to the 2050s are likely to remain very low. This means REGOs, combined with other\ngovernment initiatives, will not provide the financial incentive required to accelerate investment\nin large-scale renewables.\n\nThe Emissions Reduction Fund (ERF) has no method to recognise the emissions reductions\ndelivered by grid connected renewable projects. This gap prohibits renewable generation from\ncompeting on equal terms with other abatement options and excludes one of Australia’s most\nimportant tools for meeting its emissions targets. Without an ERF method for grid-connected\nrenewables, these projects remain excluded from the ACCU Scheme, limiting their ability to\ncontribute to national emissions targets and reducing investment incentives.\n\nClassification: INTERNAL\nAlinta Energy recommends that DCCEEW and the Clean Energy Regulator develop an\nERF method to accredit grid connected renewable energy projects. Such a method would\nincentivise investment and unlock the emissions abatement opportunities renewable\ngenerators provide. This may also reduce abatement costs for facilities covered under the\nsafeguard mechanism.\n\nEstablished techniques already exist to quantify the emissions reductions enabled by grid\nconnected renewable projects. The World Resources Institute’s Greenhouse Gas Protocol\nincludes specific guidelines1 for project developers and policy makers on estimating emissions\nreductions from electricity supplied to the grid or from activities that reduce consumption of grid\nelectricity.\n\nThank you for considering our submission. If you want to discuss this further, please contact\nKaran Sharma, Manager Public Policy, at\n\nYours sincerely\n\nGraeme Hamilton\nGeneral Manager, Government & Regulatory Affairs\n\n1https://ghgprotocol.org/sites/default/files/standards_supporting/Guidelines%20for%20Grid-\nConnected%20Electricity%20Projects.pdf\n\nClassification: INTERNAL","size":176950,"redacted":[],"meta":{"name":"AlintaEnergy.cbc87716.pdf","mime_type":"application/pdf","local_path":"files/wg4Xo5neKs6drItDasaCQMBj.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil3992714abce50744ed142":{"id":"fil3992714abce50744ed142","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/251208_CCA_Enhancing_the_ACCU_Scheme_to_support_Australia_s_2035_emissions_reduction_target.d4f3e941.pdf","filename":"251208-CCA-Enhancing the ACCU Scheme to support Australia's 2035 emissions reduction target.pdf","transcribed":null,"size":181445,"redacted":[],"config":{}}}}}