Submissions

We regularly make submissions in response to government and government-led bodies on issues affecting our members and the bioenergy industry in general. Read our submissions below.


 

2024

Cleaner, Cheaper to Run Cars: The Australian New Vehicle Efficiency Standard (February 2024)

Bioenergy Australia submitted to the consultation paper on the Australian New Vehicle Efficiency Standard on behalf of the Cleaner Fuels Alliance (CFA). We strongly recommend the Government supports the development and adoption of renewable liquid fuels in Australia alongside the NVES.

Read our submission here

 

 

Enabling Supply of Renewable Diesel in Australia Consultation (February 2024)

Bioenergy Australia submitted to the consultation paper on an Australian paraffinic diesel fuel quality standard on behalf of the Cleaner Fuels Alliance (CFA), supporting the need for policy that encourages investment, innovation and deployment of renwable diesel.

Read our submission here

 

 

MERNAP Issues Paper - Energy Sources and Technologies (February 2024)

Bioenergy Australia submitted to the MERNAP Issues Paper - Energy Sources and Technologies consultation on behalf of the Cleaner Fuels Alliance (CFA), supporting the role that biofuels, or renewable liquid fuels, will play  in decarbonising the maritime industry.

Read our submission here

 

Victoria's Waste to Energy Scheme (February 2024)

Bioenergy Australia submitted to Victoria's Waste to Energy Scheme consultation on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA), highlighting that the use of waste feedstock to produce domestic bioenergy opportunities supports Victoria’s circular economy and waste-to-energy policy objectives. 

Read our submission here

 

NSW Renewable Fuel Scheme: Draft Rules (February 2024)

Bioenergy Australia submitted to the NSW Renewable Fuel Scheme: Draft Rules consultation on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA). This submission reinforced our support for the expansion of the NSW RFS Scheme to include renewable liquid fuels and biomethane. 

Read our submission here

 

2024–25 Federal Budget Submission (RGA)  (January 2024)

Bioenergy Australia submitted to the 2024–25 Federal Budget consultation on behalf of the Renewable Gas Alliance (RGA), advocating for the acceleration of biomethane certification within the GO Scheme, the adoption of a market-based accounting approach within the NGER Scheme, and the inclusion of agricultural residues in the ACCU Scheme.

Read our submission here

 

2024–25 Federal Budget Submission (CFA/SAFAANZ)  (January 2024)

Bioenergy Australia submitted to the 2024–25 Federal Budget consultation on behalf of the Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA). The submission emphasises the need for support across a range of policy opportunities to advance the development, deployment, and adoption of renewable liquid fuels in Australia.

Read our submission here

 

Safegaurd Mechanism Implementation (January 2024)

Bioenergy Australia submitted to the Safeguard Mechanism Implementation consultation on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA).

Read our submission here

 

 

Agriculture and Land Sectoral Plan (January 2024)

Bioenergy Australia submitted to the Agriculture and Land Sectoral Plan on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA). This submission urges the Government to be ambitious in the development of this plan whilst noting the key role of the renewable liquid fuels and biomethane industries – industries that will both bolster the agricultural sector and rely on its support.

Read our submission here

 

2023

Transport and Infrastructure Net Zero Roadmap and Action Plan Survey (December 2023)

Bioenergy Australia submitted to the Transport and Infrastructure Net Zero Roadmap and Action Plan Survey on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA). This submission highlighted the significance of renewable liquid fuels and renewable gas in the decarbonisation of transport technologies and infrastructure.

Read our submission here

 

Aviation Green Paper (December 2023)

Bioenergy Australia submitted to the 2023 Aviation Green Paper on behalf of the Sustainable Aviation Fuel Alliance Australia and New Zealand (SAFAANZ), providing recommendations on how to maximise aviation’s contribution to net zero through the development and deployment of SAF.

Read our submission here

 

 

NSW Renewable Fuels Scheme Expansion (December 2023)

Bioenergy Australia submitted to the NSW Renewable Fuels Scheme: Discussion paper on scheme expansion on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA). This submission strongly supports the proposed expansion of the RFS to include renewable liquid fuels and biomethane.

Read our submission here

 

Future Gas Strategy (November 2023)

Bioenergy Australia submitted to the Department of Industry, Science and Resources’ Future Gas Strategy on behalf of the Renewable Gas Alliance (RGA) highlighting the pivotal role biomethane can play in Australia’s long term strategic approach to decarbonisation.

Read our submission here

 

Guarantee of Origin Scheme Product expansion and prioritisation - RGA (November 2023)

Bioenergy Australia submitted to the GO Scheme Product expansion and prioritisation on behalf of the Renewable Gas Alliance (RGA), recommending biomethane to be included in the GO Scheme.

Read our submission here

 

Guarantee of Origin Scheme Product expansion and prioritisation – SAFAANZ & CFA (November 2023)

Bioenergy Australia submitted to the GO Scheme Product expansion and prioritisation on behalf of the Sustainable Aviation Fuel Alliance Australia and New Zealand (SAFAANZ) and Cleaner Fuels Alliance (CFA), recommending Sustainable Aviation Fuel and Renewable Diesel to be included in the GO Scheme.

Read our submission here

 

Guarantee of Origin scheme design paper (October 2023)

Bioenergy Australia submitted to the Guarantee of Origin scheme design paper on behalf of the Renewable Gas Alliance (RGA) recommending the scheme be designed to support inclusion of biomethane.

Read our submission here

 

 

Victoria’s Renewable Gas Consultation (October 2023)

Bioenergy Australia submitted to Victoria’s Renewable Gas Consultation on behalf of the Renewable Gas Alliance (RGA) highlighting the pivotal role biomethane plays in shaping Victoria's strategic approach to decarbonisation.

Read our submission here

 

AEMO: Amendments to Victorian Declared Wholesale Gas Market and Retail Market consultation (October 2023)

Bioenergy Australia submitted to AEMO’s consultation on Amendments to Victorian Declared Wholesale Gas Market and Retail Market on behalf of the Renewable Gas Alliance (RGA).

Read our submission here

 

 

MERNAP Issues Paper: Regulation and Standards (September 2023)

Bioenergy Australia submitted to the MERNAP Issues Paper: Regulation and Standards on behalf of the Cleaner Fuels Alliance (CFA) recommending key regulatory and standards arrangements that support the deployment of renewable liquid fuels as a means to decarbonise the maritime sector.

Read our submission here

 

 

ACCC: Environmental and sustainability claims - Draft guidance for business (September 2023)

Bioenergy Australia submitted to the ACCC: Environmental and sustainability claims - Draft guidance for business recommending transparency, clarity and collaboration when developing an approach so that industry can express environmental or sustainability claims clearly and accurately.

Read our submission here

 

VIC Zero Emission Bus Transition (September 2023)

Bioenergy Australia submitted to Victoria’s Zero Emission Bus Transition consultation paper on behalf of the Cleaner Fuels Alliance (CFA) outlining the opportunities available by incorporating renewable liquid fuels within this plan.

Read our submission here

 

 

South Australia's Green Paper on the energy transition (August 2023)

Bioenergy Australia submitted to South Australia's Green Paper on the Energy Transition on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA).

Read our submission here

 

 

 

QLD Sustainable liquid fuels strategy - options and opportunities paper (August 2023) 

Bioenergy Australia submitted to the QLD Sustainable liquid fuels strategy - options and opportunities paper on behalf of the Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ), the Cleaner Fuels Alliance (CFA) and the Renewable Gas Alliance (RGA). This submission discusses the renewable liquid fuels opportunities available to Queensland and its role as a leading player in the development of this industry.

Read our submission here

 

 

WA Domestic Gas Policy (August 2023) 

Bioenergy Australia submitted to the Inquiry into the WA Domestic Gas Policy on behalf of the Renewable Gas Alliance (RGA). This submission recommends that the Committee considers the significant opportunities offered by the development of a domestic biomethane industry—an industry that provides critical security, reliability, and decarbonisation opportunities.

Read our submission here

 

 

Safeguard Mechanism: additional prescribed production variables (August 2023)

Bioenergy Australia submitted to the Safeguard Mechanism: additional prescribed production variables update on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA). This submission commends the Department’s efforts to encourage low emissions production and urges it keeps Australia’s renewable gas and renewable liquid fuels potential front of mind when reviewing the Safeguard Mechanism.

Read our submission here

 

Industry Growth Program (July 2023) 

Bioenergy Australia submitted to the Industry Growth Program: discussion paper survey on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA). The submissions highlighted the barriers to entry and investment for renewable liquid fuels and biomethane and outlined the significant future growth and market impact that can be capitalised upon through their deployment.

 

Reliability and Supply Framework for the east coast gas market (July 2023)

Bioenergy Australia submitted to the Reliability and Supply Adequacy Framework for the east coast gas market on behalf of the Renewable Gas Alliance and encouraged the Department to consider the biomethane opportunities when developing this framework.

Read our submission here

 

Climate Change Authority Review (June 2023)

Bioenergy Australia submitted to the Climate Change Authority Review on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA), urging the Authority to prioritise renewable gas and renewable liquid fuels opportunities throughout their upcoming projects.

Read our submission here

 

 

ALP Draft National Platform consultation (June 2023)

Bioenergy Australia submitted to the ALP Draft National Platform on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA), recommending that all policy and funding opportunities should support Australia’s renewable gas and renewable liquid fuels potential.

Read our submission here

 

 

SA Hydrogen and Renewable Energy Act - Draft Bill (June 2023)

Bioenergy Australia submitted to the SA Hydrogen and Renewable Energy Act – Draft Bill on behalf of the Renewable Gas Alliance and encouraged government to support every opportunity on the pathway to decarbonisation and not obstruct the development of biomethane.

Read our submission here

 

 

 

Victoria’s 30-year infrastructure strategy (June 2023)

Bioenergy Australia submitted to Victoria's 30-year infrastructure strategy on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA), recommending a strategy that leverages existing infrastructure to support the development of renewable gas and renewable liquid fuels.  

Read our submission here

 


 

Queensland Waste Management and Resource Recovery Strategy (May 2023)

Bioenergy Australia submitted to the Queensland Government’s Waste Management and Resource Recovery Strategy on behalf of the Renewable Gas Alliance (RGA), urging the recognition bioenergy as essential to building a circular economy.

Read our submission here

 

 

 

ARENA: Sustainable Aviation Fuel Funding Initiative Survey (April 2023) 

Bioenergy Australia submitted to the ARENA: Sustainable Aviation Fuel Funding Initiative Survey on behalf of the Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) to support the development, uptake and progression of SAF in the region and investment towards an emerging domestic SAF industry.

 

 

 

Standards Australia - Amendment to AS/NZS 4564:2020 General-purpose natural gas (April 2023) 

Bioenergy Australia has submitted to the Standards Australia - Amendment to AS/NZS 4564:2020 General-purpose natural gas on behalf of the Renewable Gas Alliance, supporting its revision so that the standard and its limits could facilitate the injection of biomethane into gas distribution networks.

Read our submission here

 

 

2023 National Greenhouse and Energy Reporting (NGER) Scheme updates (April 2023)

Bioenergy Australia submitted to the 2023 National Greenhouse and Energy Reporting (NGER) Scheme updates on behalf of the Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA) to welcome the inclusion of Renewable Paraffinic Diesel (RPD) and Renewable Paraffinic Kerosene (RPK) as fuel types and the addition of Renewable Fuel Oil in the NGER Regulations, and urge the DCCEEW to adopt a market-based accounting process.

Read our submission here

 

 

Victorian Digestate Consultation (April 2023)

Bioenergy Australia submitted to the EPA Victoria's Digestate Consultation on behalf of the Renewable Gas Alliance (RGA),  the alliance it founded to accelerate decarbonisation of Australia’s gas network through increased deployment of biomethane, welcoming the EPA's proposed amendments to pasteurisation and use conditions specifications.

Read our submission here

 

 

 

Aviation White Paper (March 2023)

Bioenergy Australia submitted to the 2023 Aviation White Paper on behalf of the Sustainable Aviation Fuel Alliance Australia and New Zealand (SAFAANZ), the alliance it founded to fast-track the development, uptake and progression of SAF in the region, with recomendations for the government to take actions to support the creation of a domestic SAF industry.

Read our submission here

 

 

 

Powering the Regions Fund (February 2023)

Bioenergy Australia submitted to the Powering the Regions Fund on behalf of the Renewable Gas Alliance (RGA), Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) and the Cleaner Fuels Alliance (CFA), to accelerate the development and deployment of Renewable Liquid Fuels and Biomethane for deployment in Australia. 

Read our submission here

 

 

 

National Reconstruction Fund (February 2023)

Bioenergy Australia has submitted to the National Reconstruction Fund on behalf of the Renewable Gas Alliance, Sustainable Aviation Fuel Alliance of Australia and New Zealand and the Cleaner Fuels Alliance recommending inclusion of sustainable aviation fuel (SAF) and biomethane capture as priority opportunities

Read our submission here

 

 

 

Australia’s Guarantee of Origin Consultation (February 2023) 

Bioenergy Australia on behalf of the Renewable Gas Alliance has provided a submission to Australia’s Hydrogen Guarantee of Origin Consultation with the aim to create an even playing field for gas and electricity to decarbonise, and urgently progress certification of biomethane

Read our submission here

 

 

 

SA Renewable Energy and Hydrogen Act (February 2023) 

Bioenergy Australia on behalf of the Renewable Gas Alliance has provided a submission to the SA Renewable Energy and Hydrogen Act to encourage the production and development of biomethane.

Read our submission here

 

 

 

 

2023/2024 Federal Budget Submission for RGA (January 2023)

Bioenergy Australia on behalf of the Renewable Gas Alliance provided a submission to the 2023/2024 Federal Budget to encourage the uptake and progression of biomethane in the region.

Read our submission here

 

 

 

2023/2024 Federal Budget Submission for SAFAANZ (January 2023)

Bioenergy Australia on behalf of the Sustainable Aviation Fuel Alliance of Australia and New Zealand provided a submission to the 2023/2024 Federal Budget to encourage the development, uptake and progression of SAF in the region.

Read our submission here

 

 

 

Renewable Fuel Scheme (January 2023) 

Bioenergy Australia on behalf of the Renewable Gas Alliance has provided a submission to the NSW Office of Energy and Climate Change's Renewable Fuel Scheme to encourage the production and development of biomethane and biofuels

Read our submission here

 

 

 

Future Gas Strategy for Tasmania (January 2023)

Bioenergy Australia on behalf of the Renewable Gas Alliance has provided a submission to the Future Gas Strategy for Tasmania to accelerate decarbonisation of Australia’s gas network through increased deployment of biomethane

Read our submission here

 

 

2022

Safe use of digestate (December 2022)

Bioenergy Australia on behalf of the Renewable Gas Alliance has provided a submission to the recent Victorian Governments consultation on the Safe use of Digestate

Read our submission here

 

 

 

Bioenergy Australia & The Renewable Gas Alliance Submission – Domestic Gas Price Cap Consultation (Biomethane Exemption) (December 2022)

Bioenergy Australia on behalf of the Renewable Gas Alliance has provided a submission to the recent Domestic Gas Price Gap Consultation.

Read our submission here

 

 

 

 

Energy Savings Scheme 2022 Rule Change (November 2022)

Bioenergy Australia thank the NSW Office of Energy and Climate Change for the opportunity to provide feedback on the proposed rule change for the Energy Savings Scheme. We are highly supportive of the inclusion of new definitions for biofuels, biogas and biomass and have responded to the relevant consultation questions.

Read our submission here

 

 

NSW EPA Draft Climate Change Policy and Action Plan 2022-2025 (November 2022)

Bioenergy Australia thank the NSW EPA for the opportunity to comment on their Draft Climate Change Policy and Action Plan 2022-2025. BA broadly support the initiatives included in the documents, however, include below key recommendations to improve the state of bioenergy projects in NSW.

  • Expand consultation processes included in New Action 2a to service providers and land owners.
  • Balance incentives and regulations for optimal growth of the bioenergy sector.

Read our submission here

 

 

Safeguard Mechanism Reform Consultaion on Draft Legislation (November 2022)

Bioenergy Australia thanks the Department of Climate Change, Energy, the Environment, and Water for the opportunity to inform the 2022 Safeguard Mechanism Reform Consultation on Draft Legislation. We continue to support the Department’s interest in reducing baselines to allow the Safeguard Mechanism to see large emitters contribute a share of the 2030 target on a trajectory to net zero by 2050.  We appreciate the time the Department took to release the draft legislation to enable reforms to the Safeguard Mechanism based on previous consultations. Prior to detailing the importance of including biomethane, liquid fuels and sustainable aviation fuel under the Safeguard Mechanism, BA note the following concerns:

  • BA is concerned about the implications of Safeguard Mechanism Credit Units on the existing Australia Carbon Credit Units (ACCU).
  • BA does not support tailored treatment for emissions-intensive, trade-exposed (EITE) facilities.

Read our submission here

 

 

National Electric Vehicle Strategy (October 2022)

Bioenergy Australia thank the Department of Climate Change, Energy, the Environment and Water for the opportunity to comment on the National Electric Vehicle Strategy. We would like to provide information in response to the following question to ensure DCCEW understand the opportunities presented by biofuels and renewable fuels to decarbonise transport in Australia.

Read our submission here

 

 

Native Forest Wood Waste in the Renewable Energy Target (October 2022)

Bioenergy Australia thank the Department of Climate Change, Energy, the Environment and Water for the opportunity to provide feedback on the proposed amendments to the eligibility of electricity generated from native forest wood waste (native forest biomass),  a subset of all wood waste and biomass, in the Renewable Energy Target (RET). We strongly encourage the inclusion of native forest biomass “waste”, i.e. residues from sustainable forest management activities, as an eligible feedstock in the RET. 

Read our submission here

 

 

List of critical technologies in the national interest: 2022 update (September 2022)

 

Bioenergy Australia thanks the Critical Technologies Policy Coordination Office for the opportunity to provide feedback on the 2022 list of critical technologies in the national interest. We are encouraged by the inclusion of biofuels in the 2021 critical technologies list and support its continued inclusion. To expand this focus on renewable energy, BA encourage the addition of biomethane and sustainable aviation fuel.

 

Read our submission here

 

 

 

2023 Corporate Emissions Reduction Transparency Report (September 2022)

Bioenergy Australia thank the Clean Energy Regulator for an opportunity to provide input into the development of the 2023 Corporate Emission Reduction Transparency (CERT) report. We are confident that the extensive industry consultation undertaken by the CER will result in the improvement of an important mechanism for businesses to report their emissions reductions in a transparent and uniform way.

Read our submission here.

 

 

 

Independent Review of Australian Carbon Credit Units 2022 (September 2022)

Bioenergy Australia thanks the independent expert panel members reviewing the integrity of Australian Carbon Credit Units (ACCUs) for the opportunity to comment on the governance arrangements and broader impacts of activities incentivised under the ACCU arrangements. BA support the undertaking of this review and are confident that the ACCU arrangement will benefit from industry consultation.

Read our submission here.

 

 

 

Safeguard Mechanism Reform (September 2022)

Bioenergy Australia thanks the Department of Climate Change, Energy, the Environment, and Water for the opportunity to inform the 2022 Safeguard Mechanism Reform Consultation. We support the Department’s interest in reducing baselines to allow the Safeguard Mechanism to see large emitters contribute a share of the 2030 target on a trajectory to net zero by 2050. This submission provides commentary and recommendations across three key opportunity areas for the Safeguard Mechanism;
biomethane, liquid fuels, and sustainable aviation fuel.

Read our submission here.

 

 

 

GreenPower Program Review (September 2022)