**Published name**
Below baseline: Power stations that have Renewable Energy Target baselines are proposed to be eligible to create REGO certificates for ‘below baseline’ generation.
Supportive of proposed approach.
How does the govt propose to adjust/re-baseline historical RMFs such that below-baseline generation is reflected in the historical figures? Given that corporate and government emissions reduction commitments are generally anchored on historical base years, a large change to the reporting basis of future RMFs without adjusting the premise of historical RMFs artificially skews emissions reduction performance.
Small scale systems: Power stations, including small-scale system owners, are proposed to be able to assign the right to create REGO certificates to another person or entity by written notice and in accordance with regulations. The regulations are proposed to include requirements for REGO scheme participants who have been assigned the right to create REGO certificates on behalf of another person, such as information that must be collected and maintained, metering arrangements, and certificate creation processes.
We support this approach and acknowledge the importance of DER systems in the energy transition. Require clarity on how the RMF going to be calculated if DER is included?
Electricity storage: Electricity storage is proposed to be eligible to create REGO certificates where it can be demonstrated that renewable electricity has been stored, with detailed arrangements to be outlined in regulations. The approach paper provides details of a proposed method for electricity storage facilities to prove they have stored renewable electricity in Section 1.3.
Agree with the proposed approach
Surrender restrictions: The REGO scheme legislation is proposed to include a provision allowing regulations to be made that could limit the surrender of REGO certificates for ‘below baseline’ generation prior to 2030.
We believe this introduces significant uncertainty to users of REGOs, particularly those contemplating long-term PPAs. Such uncertainty must be avoided e.g. if a non- EITE business enters into long-term PPA contracts evidenced by below-baseline REGOs, could such an entity be unable to use its purchased REGOs to reduce its Scope 2 emissions, if the govt exercises the intervention provision?
It's preferable to establish a framework with certainty from inception e.g. have two categories of REGOs: below baseline REGOs for all generation which is existing at REGO scheme commencements, and other REGOs for all new generation.
Businesses existing at scheme commencement can use any category of REGO. New businesses cannot use the below baseline REGOs.
Below-baseline status: Below-baseline REGO certificates are proposed to be clearly differentiated from other certificates. Stakeholder views are invited on how this should be implemented.
We support the proposed approach.
REGOs must compulsorily disclose the renewable energy source or storage technology, time of dispatch, location of power station or storage facility, age of power station or storage facility, storage status and export status.
Time stamping: REGO certificates are proposed to include a time stamp only where 1 MWh is generated within an hour. A procedure for time stamping certificates will be outlined in regulations.
Agree
Emissions intensity data: REGO certificates are not proposed to include any data on emissions intensity when the scheme commences. However, this data could be added to REGO certificates in the future subject to rigorous and accurate data being available for all generation nation-wide.
We support the govt’s preference not to publish any emission intensity information on REGO certificates as such an approach would contradict the NGER Scope 2 market-based approach. If in the future Scope 2 emissions reporting evolves to include temporal RMFs, then market participants would be able to utilise this temporal RMF themselves.
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