3 May 2023
The Australian Pipelines and Gas Association (APGA) represents the owners, operators, designers, constructors and service providers of Australia’s pipeline infrastructure, connecting natural and renewable gas production to demand centres in cities and other locations across Australia. Offering a wide range of services to gas users, retailers and producers, APGA members ensure the safe and reliable delivery of 28 per cent of the end-use energy consumed in Australia and are at the forefront of Australia’s renewable gas industry, helping achieve net-zero as quickly and affordably as possible.
APGA welcomes the opportunity to contribute to the Standards Australia consultation on amending AS/NZS 4564:2020 - General-purpose natural gas (the Standard). APGA supports Standards Australia commencing an amendment process for the Standard and recommends commencing a process considering new research outcomes alongside industry cost and risk factors preventing renewable gas blending today.
APGA supports a net zero emission future for Australia by 2050[1]. Renewable gases represent a real, technically viable approach to lowest-cost energy decarbonisation in Australia. As set out in Gas Vision 2050[2], 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[3], which has over 80 research projects dedicated to leveraging the value of Australia’s gas infrastructure to deliver decarbonised energy to homes, businesses, and industry throughout Australia.
The renewable gas industry has the potential to play a significant role in decarbonising Australia's energy sector. However, aspects of the Standard create compliance risk and introduce cost to enable the injection and blending of renewable gases into the gas infrastructure. A revision of AS4564 has the potential to unlock the opportunity of low-cost gas blending in Australia where it the research shows that it is safe to do so.
The current contents of AS4564 poses challenges for hydrogen blending. In particular, some APGA members have received legal advice indicating that phrasing within AS4564 combined with a lack of a specified allowable hydrogen range creates regulatory risk for service providers which allow hydrogen blends within its infrastructure.
There is a view that the absence of a hydrogen limit does not prevent hydrogen blending under the Standard, and only the Wobbe Index limit constrains hydrogen blending. Future Fuels CRC research finds that this would be a reasonable way for the Standard to function.
However, APGA members flag other statements within the Standard imply an unspecified limit on hydrogen uptake. This is leading to gas infrastructure service providers being reluctant to take on the risk of introducing hydrogen if the Standard could be read in such a way that limits hydrogen.
APGA recommends that any Standards Australia review of AS4564 include engagement with its members to understand the risk that regulatory legal advice has highlighted, to ensure that phrases within the standard to not unintendedly impede hydrogen blending – in particular where this is not the intention of the Standard.
One of the more costly components of biogas composition which needs to be removed to produce biomethane is oxygen. While biogas typically contains around 1 per cent oxygen content, the Standard requires under 0.2 per cent. It is not impossible to achieve oxygen reduction to this level, but the cost of doing so is very high – some proponents suggest that oxygen removal can add in the order of $4 to $8 per gigajoule to biomethane cost.
If it is safe for infrastructure and appliances to transport and consume AS4564 compliant gas with 1 per cent oxygen content, then maintaining the 0.2 per cent limit in light of these cost estimates seems unnecessarily impeditive to biomethane industry uptake.
Future Fuels CRC research in the Australian context indicates that infrastructure and appliances can safely operate with an oxygen level of up to 1 per cent. This research also proposes industry endorsed phrasing to amend the Standard to achieve this end. APGA recommends that Standards Australia consider an amendment to oxygen limits in the Standard in line with Future Fuels CRC research and proposed phrasing.
Please note the following Future Fuels CRC research and their associated delivery dates in considering the timing and framing of amending the Standard:
[1] APGA, Climate Statement, available at: https://www.apga.org.au/apga-climate-statement
[2] APGA, 2020, Gas Vision 2050, https://www.apga.org.au/sites/default/files/uploaded-content/website-content/gasinnovation_04.pdf
[3] Future Fuels CRC: https://www.futurefuelscrc.com/