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 provide comments to the Department of Infrastructure, Transport, Regional Development, Communications and the Arts (the Department) consultation on the Transport and Infrastructure Consultation Roadmap (the Roadmap).
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 Roadmap identifies a variety of pathways to decarbonising Australia’s transport and freight task. This is a complex and challenging task for which there is no one-size-fits-all solution. Multiple decarbonisation options must be pursued simultaneously. APGA is pleased to see a variety of renewable alternatives being proposed in the consultation, demonstrating that the Department has evolved beyond an attempt to “electrify everything”.
Australia’s pipeline infrastructure industry can support several identified transport and infrastructure decarbonisation pathways. Pipelines already transport energy in the form of gas and liquid fuel today. Gas pipelines do so cheaper, safer, and more efficiently than equivalent electricity infrastructure, as do liquid fuel pipelines in comparison to fuel transport by truck. Pipelines are also able to be designed to transport and store pure hydrogen at a lower cost than equivalent electricity options.
The Roadmap and Action Plan should take a holistic approach to decarbonising Australia’s transport task. APGA recommends:
Australia’s pipeline industry is here to support the future of decarbonised transport in Australia. APGA provides an example of an integrated hydrogen pipeline refuelling solution for long-distance freight transport in the Appendix.
The Roadmap identifies multiple opportunities for green hydrogen to contribute to transport decarbonisation. This includes hydrogen fuel cell electric vehicles (HFCEV), which can particularly play a valuable role in heavy vehicles for the long-distance haulage sector, as well as in aviation, rail and maritime. It is worth noting that major brands such as Toyota are also investigating hydrogen internal combustion engines (HICE).[4]
While not considered in the Roadmap, it is also worth considering hydrogen for private light vehicles alongside battery electric vehicles (BEVs). Similarly to diesel supply chains, logistics and supply chains developed for heavy hydrogen vehicles can also be used to support light vehicles. Hydrogen light vehicles may be beneficial for circumstances where BEVs are problematic and there is proximity to hydrogen refuelling infrastructure, including:
Be they HFCEV of HICE, hydrogen vehicles have several advantages over BEVs. Hydrogen vehicles are considerably lighter in weight, have greater range and faster refuelling capabilities (depending on type of battery electric vehicle). Hydrogen vehicles can support transport decarbonisation where these points matter.
The major hurdle to hydrogen vehicle uptake today is the lack of access to hydrogen refuelling. To be viable, hydrogen refuelling will require hydrogen which is affordable, reliable, and renewable. This will require efficient hydrogen supply chains.
Hydrogen refuelling will require hydrogen that is affordable, reliable, and renewable. Traditional assumptions[5] place green hydrogen production at “hubs” largely based at ports, however this model has two major implications:
This analysis reflects an electricity industry view of a future renewable gas market. Alongside the past decades of research by the renewable electricity sector, the gas infrastructure sector has also been researching how to best support the renewable energy transition. It has found the following in contradiction to the port-hub model of hydrogen production:
This all points towards producing hydrogen in proximity to renewable electricity production. Co-locating hydrogen electrolysers at the site of renewable energy generation would support lower hydrogen costs for domestic consumers by providing access to least cost large scale hydrogen production, transport and storage.
Gas and hydrogen transmission pipelines consistently cost less to deliver the same quantity of energy across the same distance in comparison to electricity transmission powerlines. Energy transport via hydrogen pipeline is 2-to-4 times cheaper than energy transport via aboveground powerlines,[10] and in the order of 6-to-24 times cheaper to build than underground powerlines.
Beyond energy transmission, gas and hydrogen pipelines have additional benefits in providing low-cost energy storage. GPA Engineering’s research also found that energy storage in pipelines can be hundreds of times cheaper than energy storage in utility scale batteries or pumped hydro, and 2-to-36 times cheaper in hydrogen pipelines.
All of this is important in the context of economics of hydrogen production, and of moving energy large distances from renewable energy zones to population centres. As noted above, hydrogen vehicles are a viable decarbonisation option for heavy vehicles and other transport sectors, including rail, if the necessary transport infrastructure and supply chains are invested in at the same time. The transmission pipeline industry can provide this support through the construction of cost-effective and efficient hydrogen transmission pipelines, co-located along major freight routes to supply HFCEV refuelling. This would also support hydrogen supply for other gas decarbonisation activities.
APGA has advocated – particularly regarding blending of renewable gases into networks for residential use – for governments to take an ‘abundance’ rather than a ‘scarcity’ mindset to renewable gases. A scarcity mindset considers that renewable gases will be a scarce resource that should be reserved for the highest-value uses. This reduces the case for broad-scale investment as the potential market and growth opportunities will necessarily be limited. An abundance mindset will instead provide strong signals for investment and growth by enabling producers to access the biggest possible market.
As regional centres develop along major road corridors and cities expand out beyond previously industrial areas, it is critical that corridors for fuel pipelines, including hydrogen pipelines, be identified and reserved early.
Grant funding programs have provided some initial development to this industry. The Hume Hydrogen Highway initiative is a joint initiative between the Victorian and NSW state governments to support the growth of both renewable hydrogen and the decarbonisation of heavy transport.[11] The program provides grants towards the development of refuelling stations along the Hume Highway, and the procurement of HFCEV long-haul heavy freight vehicles, the successful industry partner is expected to be announced in the near term.[12]
Alongside this and broader hydrogen industry development programs such as Hydrogen Headstart and the Hydrogen Production Tax Incentive, a holistic view is required. This is where the Transport and Infrastructure Action Plan can provide a tangible and coordinated plan for the transition of this industry, across both state and Federal Governments.
APGA recommends developing a roadmap for hydrogen pipeline corridors alongside major Australian freight routes, such as the Hume and Pacific Highways. An example of this is explored in APGA’s submission to the 2022 National Electric Vehicle Strategy consultation (Appendix 1).
The consultation Roadmap makes some assumptions about the decarbonisation of electricity and energy, stating that “electrification is the clear decarbonisation pathway for much of the transport sector. However, this outcome relies on the decarbonisation of the electricity grid.”
This is not a fiat accompli, as can be seen in the decarbonisation options that do not rely on the electricity grid. Hydrogen fuel cells, biodiesel and sustainable aviation fuel are all real decarbonisation options for transport and its infrastructure, which can provide a separate decarbonisation pathway that is not reliant on decarbonisation of the electricity grid.
These options can be supported by pipeline infrastructure, which delivers more energy at lower cost than electricity today. Even new hydrogen pipelines can transport and store energy for a lower cost than electricity powerlines or electricity storage. Where the final Roadmap considers transport energy decarbonisation, it should also consider leveraging the economic efficiency of gas and pipeline infrastructure.
Australia needs air transport. Whether for tourism of commerce, there is no getting away from the need to decarbonise the aviation sector. And of all the sectors requiring the energy density of liquid fuels, aviation tops the list. While hydrogen and electric-powered aircraft are under development, it is likely that aircraft will need to be fuelled with hydrocarbons for the foreseeable future.
Hence, much like the aviation fuel sector of today, a decarbonised aviation sector will need safe, reliable and affordable delivery of sustainable aviation fuel (SAF) and its feedstocks. Also like the aviation fuel sector of today, the SAF sector can leverage fuel pipelines to ensure safe, reliable and affordable transport of SAF.
SAF can be made with renewable gas. Hence, developing a cost-effective SAF industry could rely on production which is connected to a blended or pure renewable gas grid. This approach could be lower cost, more technologically ready and more sustainable on feedstock supplies than alternative SAF pathways that exist today.
This requires a fuel- and user-agnostic certification scheme and recognition through NGER. Assuming these are achieved, this can lead to the most optimal mix of infrastructure and low-carbon energy for transport through pipelines.
The concept of using dedicated open-access fuel pipelines to support refuelling of aircraft is long-established in the domestic and international aviation markets. Dedicated fuel pipelines are a common feature of established airports, with fuel trucking typically reserved for smaller airports or during early stages of operation. For airports, fuel that is transported via road is less efficient resulting in higher fuel costs and emissions, both of which the Transport Sector Plan should be conscious of avoiding.
Today, Melbourne, Sydney and Brisbane Airports are supplied through a combination of jet fuel pipelines and road tankers. Adelaide Airport currently solely on road tankers to supply daily fuel needs, but is investigating the use of a nearby existing multi-fuel pipeline for aviation fuel purposes.[13]
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Case Study: Western Sydney International Airport The Western Sydney International Airport (WSI) is a new international airport currently under construction in Sydney’s outer south western suburbs, due to open for operation in 2026. When WSI first opens its fuel supply will initially be delivered by road. Work has been underway to identify a fuel transport pipeline corridor since 2017, ideally in road reserves and using either new pipelines or a combination of new and existing pipelines.[14] Some of this delay is due to the fact that a fuel pipeline is outside the legal boundaries of the airport itself. A 2023 review of fuel options noted WSI’s owner could enhance the airport’s long-term value to future investors by investing itself in an aviation fuel supply pipeline, or incentivise a potential investor[15] - however development of the pipeline must involve government. This review recommended that the NSW Government should prioritise the immediate facilitation of an open-access pipeline corridor from potential ports to WSI before the optimal routes are compromised by competing development activity. The NSW Government and the WSI are progressing development of a fuel pipeline to WSI and surrounding precinct.[16] |
Key to these fuel and feedstock pipelines is that they directly connect producers to their airport customers. But they can also supply other customers via open access pipelines. It is this access to a broad customer base which will provide additional economic incentives to invest in both the fuel and the infrastructure.
The Transport and Infrastructure Consultation Roadmap (the Roadmap) covers both the decarbonisation pathways of transport sectors and uses, and the decarbonisation of enabling infrastructure and transport energy use. Consideration of which forms of energy to utilise should be founded upon the fact that the Electricity and Energy Sector Plan (EESP) sets out to decarbonise the production of each form of energy.
The five sectoral plans which sit alongside the EESP risk making conflicting decisions if they make electricity and energy decarbonisation recommendations without the context of the EESP. Bringing assurance that electricity, gas, hydrogen, or liquid fuel production is decarbonised into the transport (or any other) sector plan risks misalignment with approaches taken in the EESP.
The EESP sets out an all-options approach to decarbonisation, considering pathways for electricity generation and fuel production alike. The decarbonisation of fuel production, including gas, hydrogen, and liquid fuels, is set out in the Low Carbon Fuels section of the EESP consultation. This leads to four decarbonised energy options for the transport sector plan to consider:
To avoid conflict, decarbonisation of energy production is best addressed in the EESP and assumed to be addressed within this plan by other plans. The consultation Roadmap does largely leave energy decarbonisation appropriately to the EESP. However, there is risk of sector plan conflict which must be kept front of mind as the final Transport and Infrastructure Roadmap and Action Plan is developed.
Beyond agreeing with the all-options approach included in the EESP, APGA provided the following recommendations in its submission to Department of Climate Change, Energy, the Environment and Water (DCCEEW) consultation on the EESP:
These recommendations, alongside the EESP support of renewable gas, hydrogen and renewable liquid fuel supply, would support the availability of renewable fuels for a future transport sector. If supply chains for the stationary use of renewable gases and liquid fuels are designed in tandem with their use in transport, the opportunity for supply chain optimisation arises as discussed elsewhere in this submission.
Beyond decarbonising transport modes – road vehicles, trains, aircraft, ships – the Roadmap considers the decarbonisation of the infrastructure that supports those modes. This includes roads and road infrastructure, rail, ports and airports, all of which produce emissions in their construction and operation.
This is likely to be an area that will be covered in detail by the Resources and Built Environment Sector Plans. However, APGA notes that renewable gases and gas infrastructure also will have a large impact in the ‘greening’ of this sector, through supporting green metals and alloys, green concrete and other building materials and processes. APGA recently provided comments to the Department of Industry, Science and Resources consultation on green metals opportunities for Australia – noting that renewable gas will be a key input and feedstock to viable green metals production.[18]
The sustainable reuse of infrastructure also supports transport decarbonisation. While new pipelines will be required in some areas such as along freight routes, Australia’s extensive gas transmission pipeline network spans some 42,000km – many of these pipelines will able to be converted for hydrogen service.[19] Australia’s gas distribution network goes even further, and a large proportion of this network is already hydrogen-capable.
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Guiding principles
1. Do you agree with the proposed guiding principles?
2. Do you support the use of the avoid-shift-improve framework as a tool to identify opportunities for abatement? |
APGA agrees with the proposed principles where they are technologically agnostic. The development of the Action Plan should pursue all decarbonisation pathways where they result in actual emissions reduction while maximising the economic opportunity.
APGA also supports the avoid-shift-improve framework, as long as the ‘improve’ metric is technologically agnostic and does not rely on a single pathway (electrification). This is important particularly in the short term, where electrification may result in short term intensification of emissions through increased reliance on coal generation. |
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Promoting active and public transport
3. Do you agree the development of a national policy framework for active and public transport will support emissions reduction?
4. What should be included in a national policy framework for active and public transport and how should it be developed?
5. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to ensure the movement of people contributes to transport emissions reduction? |
APGA has no opinion on this. |
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Decarbonising freight and supply chains
6. The Australian Government has already engaged in consultation on the 2023 review of the National Freight and Supply Chain Strategy and those consultations will also inform the final Roadmap and Action Plan.
6.1. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to ensure that the movement of goods contributes to transport emissions reduction?
6.2. How would these actions address the identified challenges and opportunities for emissions reduction in the movement of goods? |
Australia has a range of options to decarbonise freight and supply chains. As detailed in our substantive submission, renewable gases and new and existing gas infrastructure can contribute to the decarbonisation of this sub-sector. Hydrogen fuel cell electric vehicles (HFCEVs) are a realistic option for many transport modes, including heavy vehicles, rail and possibly aircraft as well.
Governments need to take a holistic and technologically agnostic approach to considering decarbonisation options, while also considering where these options can contribute to the broader economy.
For example, to be viable HFCEVs would require access to abundant renewable hydrogen supplies at reasonable cost, and efficient supply chains. This would provide a strong signal for investment in renewable hydrogen generation, supported by new and existing gas pipeline infrastructure. This would in turn increase the supply of hydrogen for other purposes, including green metals. Hence, a mutualistic approach should be taken when considering decarbonisation options. |
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Net zero pathway for light vehicles
7. Do you agree with the proposed net zero pathway for light road vehicles? Please add details to your response.
8. The Australian Government is currently developing an Australian New Vehicle Efficiency Standard and has already begun to implement actions in the National Electric Vehicle Strategy.
8.1 What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce light vehicle emissions?
8.2. How would these actions address the identified challenges and opportunities to reduce light vehicle emissions? |
APGA notes that the same supply chains that would support heavy HFCEVs would also support hydrogen light vehicles.
While hydrogen light vehicles (both directly fuelled and using fuel cells) are currently a niche market they are available, as are refuelling stations. These could be expanded relatively easily assuming the supply chains for heavy vehicles are in place.
There are some advantages to pursuing another decarbonisation pathway for light vehicles, notably that the challenges of EVs cannot always be overcome for every consumer. |
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Net zero pathway for heavy vehicles
9. Do you agree with the proposed net zero pathway for heavy road vehicles?
10. The proposed pathway for heavy road vehicles relies on a mix of battery electric, hydrogen fuel cell and low carbon liquid fuels. Rank from 1 to 3 the order in which these should be prioritised for emissions reduction. Why did you rank them in that order?
11. What role should low carbon liquid fuels play in heavy vehicle decarbonisation?
12. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce heavy vehicle emissions?
12.1. How would these actions address the identified challenges and opportunities to reduce heavy vehicle emissions? |
See also answer to Question 6. APGA considers the proposed pathway to be sensible and appropriately technologically agnostic.
It may be inappropriate, however to rank pathways for heavy vehicles. As noted in the consultation Roadmap, different options may be suitable for different purposes. Heavy HFCEVs may be much more practical for long distance/intercity haulage, where EVs may meet the need for intracity and last mile haulage. LCLFs in heavy vehicles similarly have a part to play.
APGA has been consistent advocating for all decarbonisation pathways to be explored. Governments should consider the costs and benefits of all options when developing decarbonisation strategies. If some of these industries – particularly hydrogen for use in transport – are to be viable, strong signals are required from governments beyond subsidies.
Governments should also take an ‘abundance’ approach – assume all options are on the table, and assume that decarbonised fuels such as hydrogen and LCLFs are as abundant as renewable electricity is assumed to be. In terms of renewable hydrogen, the production of which is only limited by the production of renewable electricity, greater the demand for hydrogen will lead to greater production of hydrogen to meet this demand. APGA therefore supports all hydrogen options for decarbonising transport. |
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Net zero pathway for rail
13. Do you agree with the proposed net zero pathway for rail?
14. The proposed pathway for rail relies on a mix of battery electric, hydrogen fuel cell and low carbon liquid fuels. Rank from 1 to 3 the order in which these should be prioritised for emissions reduction. Why did you rank them in that order?
15. What role should low carbon liquid fuels play in rail decarbonisation?
16. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce rail emissions?
16.1. How would these actions address the identified challenges and opportunities to reduce rail emissions? |
See answers to Questions 9-12. |
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Net zero pathway for maritime
17. Do you agree with the proposed net zero pathway for maritime?
18. The Australian Government is engaging in consultation as part of the development of the Maritime Emissions Reduction National Action Plan and those consultations will also inform the final Roadmap and Action Plan.
18.1. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce maritime emissions?
18.2. How would these actions address the identified challenges and opportunities to reduce maritime emissions? |
See answers to Questions 9-12.
APGA notes that any potential decarbonisation requirements on international ships may put Australian ports at a comparative disadvantage. This will need to be accounted for in cost-benefit analysis of decarbonisation of ports. |
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Net zero pathway for aviation
19. Do you agree with the proposed net zero pathway for aviation?
20. The Australian Government has already engaged in consultation on aviation decarbonisation through the development of the Aviation White Paper and those consultations will also inform final Roadmap and Action Plan.
20.1. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce aviation emissions?
20.2. How would these actions address the identified challenges and opportunities to reduce aviation emissions? |
See answers to Questions 9-12.
APGA notes that SAF is likely to be the most realistic option for decarbonising aviation given the limitations of battery and HFC technologies.
Fuel pipelines which currently deliver aviation gasoline can also deliver SAF, which makes the supply challenge less complex that it otherwise would be. |
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Net zero pathway for transport infrastructure
21. Do you agree with the proposed net zero pathway for transport infrastructure?
22. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce transport infrastructure emissions and ensure that transport infrastructure is ready for and enables low-emission transport modes?
22.1. How would these actions address the identified challenges and opportunities to reduce transport infrastructure emissions? |
APGA concurs with the proposed pathway for decarbonising transport infrastructure, noting that renewable gases in the form of green hydrogen and biomethane will be a critical feedstock to green metals concrete as a source of both heat and carbon. Hence, these products are reliant on the abundance of renewable gases. |
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Transport energy use
23. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to ensure the energy mix is ready to support transport emissions reduction?
24. How should the use of low carbon liquid fuels be prioritised across different transport modes over time to achieve maximum abatement? |
APGA cautions that decarbonisation of energy use should be left to the Electricity and Energy Sector Plan. |
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Travelling in partnership
25. What are the best ways for the Australian Government to work collaboratively with industry, business, governments and communities to implement the proposed pathways?
25.1. What are good domestic or international examples of partnership and collaboration on transport and transport infrastructure emissions reduction that could inform the final Roadmap and Action Plan?
25.2. What opportunities can the government leverage to show leadership in Australia and internationally? |
A collaborative partnership is one that involves all possible stakeholders, including those not traditionally associated with the specific sector or decarbonisation pathway. APGA appreciates the opportunity to comment on the consultation Roadmap and provide perspectives that may not otherwise have been considered. |
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Measuring success
26. What measures and metrics should be used to evaluate the final Transport and Infrastructure Net Zero Roadmap and Action Plan?
26.1. What other data and evidence could governments use and how could this offer further insights on the pace, scale and location of transport emissions reduction pathways?
27. Do you have any feedback on the proposed review process?
28. Do you have any further feedback on the Consultation Roadmap and proposed pathways?
28.1. Is there anything missing? Are the sections appropriately integrated? Is the Roadmap appropriately ambitious?
29. Is there any further information or documentation that you wish to be considered with your submission? |
APGA has no views on this, other than to approve of the agnostic approach to decarbonisation taken in the consultation Roadmap. |
See APGA's submission to the National Electric Vehicle Strategy consultation.
[1] APGA, Climate Statement, available at: https://www.apga.org.au/apga-climate-statement
[2] APGA, 2020, Gas Vision 2050, https://apga.org.au/gas-vision-2050
[3] Future Fuels CRC: https://www.futurefuelscrc.com/
[4] Toyota Australia, 2023, Toyota Unveils Hydrogen Powertrain Technology for Pilot Program in Australia, https://www.toyota.com.au/news/toyota-unveils-hydrogen-powertrain-technology-for-pilot-program-in-australia
[5] Particularly AEMO, 2023, 2023 Inputs, Assumptions and Scenarios Report, https://aemo.com.au/-/media/files/major-publications/isp/2023/2023-inputs-assumptions-and-scenarios-report.pdf
[6] Nous Group, 2023, Net Zero Australia Final Modelling Results, https://www.netzeroaustralia.net.au/wp-content/uploads/2023/04/Net-Zero-Australia-final-results-launch-event-presentation-19-April-23.pdf
[7] GPA Engineering, 2022, Pipelines vs Powerlines: A Technoeconomic Analysis in the Australian Context, https://apga.org.au/research-and-other-reports/pipelines-vs-powerlines-a-technoeconomic-analysis-in-the-australian-context
[8] Ibid
[9] Nous Group, 2023, Net Zero Australia Final Modelling Results
[10] GPA Engineering, 2022, Pipelines vs Powerlines
[11] DEECA, 2024, Hume Hydrogen Highway, https://www.energy.vic.gov.au/grants/hume-hydrogen-highway
[12] DCCEEW, 2024, Hume Hydrogen Highway, https://www.energy.nsw.gov.au/business-and-industry/programs-grants-and-schemes/hydrogen-refuelling-network-funding
[13] Adelaide Airport, 2020, Adelaide Airport Master Plan, https://corporate.adelaideairport.com.au/wp-content/uploads/2020/05/Master-Plan-Chapter-8-Aviation-Development.pdf
[14] Deloitte, 2017, Western Sydney Airport Aviation Fuel Supply Corridor Options Report, https://www.westernsydneyairport.gov.au/sites/default/files/Fuel_Supply_Corridor_Options_Report_Feb2018.pdf
[15] Western Sydney Airport, 2023, Western Sydney International Airport Review of Aviation Fuel Supply Options – May 2023, https://westernsydney.com.au/sites/default/files/2023-05/WSI%20Review%20of%20Aviation%20Fuel%20Supply%20Options%202023.pdf
[16] NSW Government, 2024, Western Sydney fuel pipeline, https://www.transport.nsw.gov.au/projects/current-projects/western-sydney-fuel-pipeline
[17] ACIL Allen, 2024, Renewable Gas Target: Delivering lower cost decarbonisation for gas customers and the Australian economy, report to APGA and ENA, available at https://apga.org.au/renewable-gas-target. See Attachment 1.
[18] APGA, 2024, Submission: Unlocking green metals opportunities, https://apga.org.au/submissions/unlocking-green-metals-opportunities
[19] APA Group, 2024, Parmelia Gas Pipeline – Hydrogen Conversion Technical Feasibility Study, https://www.apa.com.au/globalassets/our-services/gas-transmission/west-coast-grid/parmelia-gas-pipeline/3419_apa_public-pipeline-conversion_v6.pdf