Consultation for the Corporate Emissions Reduction Transparency report

Written by APGA | Nov 1, 2021 2:07:00 AM

The Australian Pipelines and Gas Association (APGA) represents the owners, operators, designers, constructors and service providers of Australia’s pipeline infrastructure, with a focus on high-pressure gas transmission. APGA’s members build, own and operate the gas transmission infrastructure connecting the disparate gas supply basins and demand centres of Australia, offering a wide range of services to gas producers, retailers and users.

APGA welcomes the opportunity to contribute to the Clean Energy Regulator (CER) Consultation for the Corporate Emissions Reduction Transparency (CERT) report (the Consultation).

APGA encourages the CER to consider the full spectrum of renewable and decarbonised energy options in the development of the CERT, including the use of renewable and decarbonised gases.

As set out in Gas Vision 2050[1], APGA sees renewable gases such as hydrogen and biomethane playing a critical role in decarbonising gas use for both wholesale and retail customers. APGA is the largest industry contributor to the Future Fuels CRC[2], which has over 80 research projects dedicated to leveraging the value of Australia’s gas infrastructure to deliver decarbonised energy.

As per Section 1.2 Purpose of the CERT in the Consultation paper, the purpose of the CERT is to provide a framework to:

Help companies present progress towards their emissions reduction and renewable electricity consumption commitments in a consistent and clear way;
Support company claims about reducing emissions, using renewable electricity and surrendering eligible units; and
Support voluntary participation in Australia’s carbon markets.

APGA recommend that the CER adopt a technology agnostic approach to emissions reduction throughout its design and implementation of the CERT, beginning with the replacement of references to renewable electricity in the CERT purpose with references to renewable energy.

While the Consultation paper specifically identifies renewable electricity, APGA note that other forms of renewable energy, including renewable gases, can also facilitate emission reduction. To this point, APGA notes the following ongoing changes impacting the future of gas supply:

Customers can purchase decarbonised gas today through offset regimes such as those provided by Origin Energy[3] and AGL[4];
The combined DISER, AEMC and AEMO consultations on extending gas market regulation to include hydrogen and other renewable gases[5];
Recent state-based strategies and analysis of renewable gas use including the NSW Hydrogen Strategy[6] and Victorian Gas Substitution Roadmap[7];
Some Adelaide residents are already using renewable gases through a pilot project developed by AGIG[8], with more to come across coming months[9]^,[10] and years[11];
The further development of a renewable gas industry in Australia is expected to make large-scale retail purchase of renewable gases a reality in the years to come; and
Decarbonisation of gas infrastructure is likely to be achievable at half the cost of electrification based on research conducted by the gas industry[12].

Ensuring that the CERT is able to consider the use of renewable and decarbonised gases will help facilitate the growth of this new renewable energy industry. By recognising the emissions reduction outcomes achieved by customers who purchase renewable gases in the CERT, these customers can be incentivised through recognition of their carbon neutral choices.

For more information on the future of renewable gases, please take the opportunity to read Gas Vision 2050 and visit the Future Fuels CRC website[13].

To discuss any of the above feedback further, please contact me on +61 422 057 856 or jmccollum@apga.org.au.

Yours Sincerely,

JORDAN MCCOLLUM

National Policy Manager

Australian Pipelines and Gas Association

[1] Gas Vision 2050, APGA

https://www.apga.org.au/sites/default/files/uploaded-content/website-content/gasinnovation_04.pdf

[2] Future Fuels CRC Website
https://www.futurefuelscrc.com/

[3] Green Gas, Origin Energy
https://www.originenergy.com.au/electricity-gas/green/

[4] Carbon Neutral Energy, AGL
https://www.agl.com.au/residential/carbon-neutral

[5] Extending the national gas regulatory framework to hydrogen blends and renewable gases, DISER

https://www.energy.gov.au/government-priorities/energy-ministers/priorities/gas/gas-regulatory-framework-hydrogen-renewable-gases