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.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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.
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).
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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
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
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.
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.
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.
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
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
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
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
GreenPower Program Review (September 2022)
BA thanks the GreenPower team for consulting the industry on their program review. We agree that energy markets are experiencing a rapid transition, rendering this review of GreenPower highly relevant and timely. BA are particularly encouraged by GreenPower’s work in a biomethane certification trial, specifically the Sydney Water Malabar Waste Water Treatment Plant.
Extension of the Source Separated Organic Waste ERF Method (July 2022)
Bioenergy Australia thanks the Emissions Reduction Assurance Committee (ERAC) for the opportunity to comment on the proposed SSOW biomethane ERF method and are encouraged by the progress of this method. After review we have identified numerous amendments that should be made to better encourage greater participation from the waste industry, support investment in projects and avoid uninetended policy outcomes.
Renewable Energy and Agriculture in NSW (May 2022)
Bioenergy Australia appreciate the opportunity to respond to the NSW Government’s review of the adequacy of existing frameworks regarding renewable energy and agriculture in NSW by the NSW Agriculture Commissioner Daryl Quinliven. This review will assess the frameworks’ abilities to manage issues and opportunities from the forecast growth in the renewable energy and agriculture sector in NSW. BA emphasise the importance of facilitating integration of bioenergy production facilities within the agriculture sector.
AEMC Draft Recommendations for extending the regulatory frameworks to hydrogen and renewable gases (May 2022)
Bioenergy Australia broadly supports the draft recommendations made by the Australian Energy Market Commission’s (AEMC) on the Review into extending the regulatory frameworks to hydrogen and renewable gases. The AEMC has identified a strong model of initially including biomethane, synthetic methane and hydrogen within the scope of the national gas regulatory framework to act as the basis for later inclusions of hydrogen blends alongside other renewable methane blends.
Review of the NSW Resource Recovery Framework (May 2022)
Bioenergy Australia appreciates the opportunity to provide feedback on the review into teh NSW Resource Recovery Framework. The NSW Environmental Protection Authority (EPA) committed to 'review and optimise measures to facilitate feasibility and viability testing of innovative business models, technologies or processes for resource recovery'. The resource recovery framework aims to divert waste from landfill and minimise the risks to human health.
National Greenhouse and Energy Reporting (NGER) Scheme: Proposed Updates (May 2022)
Bioenergy Australia welcomes the Department of Industry, Science, Energy and Resources (DISER) consideration of creating a new biomethane fuel type and the reporting of blended gaseous fuels. These considerations bring up crucially important aspects of NGER reporting that require urgent change to enable a successful biomethane market to develop in Australia.BA therefore welcomes the Department of Industry, Science, Energy and Resources (DISER) consideration of creating a new biomethane fuel type and the reporting of blended gaseous fuels. These considerations bring up crucially important aspects of NGER reporting that require urgent change to enable a successful biomethane market to develop in Australia.
Carbon Credits (Carbon Farming Initiative-Alternative Waste Treatment) Methodology Determination Variation 2022 (April 2022)
Bioenergy Australia thanks the Clean Energy Regulator (CER) for its engagement on the development and implementation of the biomethane method, its ongoing consideration of other biomethane inclusion issues and for this opportunity to provide input on this method variation relating to biomethane under the Emissions Reduction Fund (ERF).
GreenPower Renewable Gas Pilot consultation paper (March 2022)
Bioenergy Australia welcomes the opportunity to provide feedback to the GreenPower Renewable Gas Certification Pilot consultation paper and is encouraged by the exciting and significant bioenergyrelated market development opportunities that can be enabled by this GreenPower’s leadership in this area.
Draft End of Waste Code Anaerobic Digestion Digestate
Queensland (February 2022)
BA thanks the QLD Department of Environment and Science (QDES) for the opportunity to make a submission on the Draft End of Waste Code – Anaerobic Digestion Digestate.
This is an area of strong interest for BA. Our members consistently provide feedback that overregulation of digestate is a prohibitive factor for them in taking biomethane projects to market, limiting expansion of Australia’s biomethane production and all the associated benefits. Internationally, digestate is a highly valued by-product of AD. We are keen to ensure that any regulation of digestate in Australia successfully balances the risks and benefits and enables use of digestate where appropriate. In this submission we will address:
• The biomethane opportunity
• The digestate opportunity
• Feedback on the QLD Draft End of Waste Code – AD Digestate
Draft Bioenergy Vision for Tasmania - Consultation Paper
(February 2022)
Bionergy Australia (BA) congratulates the Tasmanian government on the creation of a Draft Bioenergy Vision for Tasmania.BA feel that the draft Bioenergy Vison does a good job of capturing the issues and opportunities presented for Tasmania by bioenergy. We feel the Vision could benefit by being more specific about the kinds of policy interventions which would support development of a bioenergy industry in Tasmania. This will be our focus as we address each of the questions in the consultation document.
Low Emissions Technology Statement 2022 (February 2022)
Bioenergy Australia (BA) thanks the Department of Industry, Science, Energy and Resources (DISER) for the opportunity to make a submission on the Low Emissions Technology Statement (LETS) for 2022. BA recommends including sustainable aviation fuel (SAF) and biomethane injection as priority low emissions technologies in 2022. We will address these technologies individually, demonstrating the significant impacts investing in these technologies will have for Australia.
2021
AEMO procedure review extending the national gas regulatory
framework to hydrogen and renewable
gasses (December 2021)
Bioenergy Australia (BA) is pleased that procedures are being reviewed to extend the national gas regulatory framework to hydrogen and renewable gases. BA has prepared a response which is supportive of changes to enable injection of hydrogen and renewable gases but wish to emphasise the importance of developing a regulatory environment that is supportive of new project development, and not so restrictive that it stifles industry growth.
Review into extending the regulatory frameworks to hydrogen and
renewable gases (December 2021)
Bioenergy Australia (BA) is pleased that the national gas regulatory framework is being reviewed to extend to hydrogen and renewable gases. BA has prepared a response which is supportive of changes to enable injection of hydrogen and renewable gases but wish to emphasise the importance of developing a regulatory environment that is flexible and supportive of new project development, and not so restrictive that it stifles industry growth.
Singapore Australia Green Economy Agreement (November 2021)
BA and the SAFAANZ thank the Department of Foreign Affairs and Trade for the opportunity to contribute ideas on a Singapore-Australia Green Economy Agreement to facilitate trade and investment in environmental goods and services, strengthen environmental governance, and contribute efforts to build global capacity to address climate change.
Draft biomethane method package relating to biomethane under
the Emissions Reduction Fund (ERF)
(November 2021)
Bioenergy Australia (BA), having reviewed the proposed biomethane method package,seeks the following additions and amendments:
- Expand the package to include the alternative waste treatment method and source separated organic waste method as a matter of urgency
- Expand the package to include an agricultural waste method
- Extend the crediting period to support greater participation in the method
- Accelerate credits in line with the King Review
- Incorporate additional carbon abatement activity
- Improve consistency in the calculation of losses between generation, biomethane and pipeline infrastructure
- Be wary of unintended consequences caused by the ‘newness test’
- Remove requirement for natural gas to be combusted in Australia
- Clarify credit creation for biomethane used in power generation
- Consider credit ownership of post-diversion treatment for animal effluent
- Reconsider the restriction of generation of electricity and biomethane from biogas after 7 years
- Formula update required to consider impact of upgrading to biomethane
- Electricity use should be offset via voluntary purchasing of LGCs
- Clean Energy Regulator to develop method specific calculators
The officials’ consultation paper on Extending the national gas
regulatory framework to hydrogen blends and renewable gases
(November 2021) 
Bioenergy Australia (BA) has prepared a response which supports the approach to make amendments that futureproof the NGL and NERL to support OG products over time whilst minimising unintended consequences. BA agree that there is currently ambiguity in the NGL regarding the definition of natural gas and its application to biomethane and support amendments that enable the development of projects injecting biomethane into the grid. BA is keen to see a regulatory environment developed that is supportive of new project development, and not so restrictive that it stifles industry growth.
Corporate Emissions Reduction Transparency report draft guidelines
(November 2021)
Bioenergy Australia (BA) has prepared a response to highlight that Biomethane has a substantial role to play in the decarbonisation of Australia’s gas network and will be of particular value to industries that currently rely heavily on natural gas for heating, reforming, refining and conventional gas-fired power generation. BA commend the Clean Energy Regulator on the development of the Corporate Emissions Reduction Transparency (CERT) report and see this as an important mechanism for businesses to report their emissions reductions in a transparent and uniform way.
Queensland Draft Organics Strategy survey (November 2021)
Bioenergy Australias has prepared a response, highlighting that for the draft framework to successfully divert organic waste from landfill, there needs to be policy support and incentives to create market for the organic waste.
Queensland Renewable Energy Zones (QREZ) (September 2021)
Bioenergy Australia has prepared a response to highlight the substantial role bioenergy can play in Queensland’s efforts to transition towards 50 per cent renewable energy by 2030 and to explore the policy instruments required to activate bioenergy as part of Queensland’s renewable electricity and renewable transport fuel solution, including through contribution to the QREZ.
Streamlining excise administration for fuel and alcohol (September 2021) 
Bioenergy Australia has prepared a response and thanks the Department of Premier and Cabinet for the opportunity to provide feedback on the deregulation agenda to streamline
excise administration for fuel and alcohol.
Northern Queensland Renewable Energy Zone (August 2021) 
The Queensland Government has committed $145 million to establish three Queensland renewable energy zones (QREZ) – the Northern, Central, and Southern QREZ. Powerlink welcomes submissions in relation to the proposed augmentation to develop a Renewable Energy Zone in North Queensland and to seek feedback on whether there are any other
matters which could reasonably be considered as part of the development of the Northern QREZ. Bioenergy Australia has prepared a response highlighting the substantial role bioenergy can play in Queensland’s efforts to transition towards 50% renewable energy by 2030 and to explore the policy instruments required to activate bioenergy as part of Queensland’s renewable electricity solution, including through
contribution to the NQRZE.
Hydrogen Guarantee of Origin Scheme (July 2021)
The Department of Industry, Science, Energy and Resources has been working both domestically and internationally on the establishment of a Hydrogen Guarantee of Origin (HGO), or certification scheme, a priority action under Australia’s National Hydrogen Strategy. This scheme will be vital to give purchasers transparency as Australia and the world looks to facilitate clean hydrogen trade. Bioenergy Australia has prepared a response to provide comment on the proposed HGO encouraging expansion to include all forms of renewable gas.
Victoria’s Gas Substitution Roadmap (July 2021)
The Victorian Government is developing a Gas Substitution Roadmap throughout 2021 to provide a strategic framework for decarbonising natural gas in Victoria. The roadmap will detail transition pathways and identify policy mechanisms to achieve Victoria’s emissions reduction targets through reduced fugitive emissions, more efficient use of gas, electrification and increased use of sustainable gases such as hydrogen and biogas. Bioenergy Australia has prepared a response to highlight the substantial role biogas and biomethane can play in Victoria’s efforts to transition towards a net zero emissions economy and the policy instruments required to activate a renewable gas industry in Victoria.
Carbon Credits (Carbon Farming Initiative—Electricity Generation from Landfill Gas) Methodology Determination 2021 (June 2021)
The Emissions Reduction Assurance Committee is seeking feedback on the Carbon Credits (Carbon Farming Initiative—Electricity Generation from Landfill Gas) Methodology Determination 2021. The proposed Landfill gas (generation) method credits emissions reductions achieved through the destruction of methane from decomposing waste at a landfill site where the landfill operator intends to generate electricity. Bioenergy Australia has prepared a response to support the methodology determination and the decision to increase the crediting period for landfill gas electricity generation projects from seven to twelve years.
Queensland Energy from Waste Policy Guideline (June 2021)
Following the release of the QLD Energy from Waste (EfW) Policy on 4 June 2020, the Department of Environment and Science has sought feedback on their draft guideline in support of the Policy. Bioenergy Australia has prepared a response to congratulate the QLD Government for the development of a strong and effective EfW policy and to support the development of the guideline, which should focus on mitigating the risk, but also on promoting the uptake of technologies.
IPART draft report - Approach to determining wholesale ethanol prices (May 2021)
IPART has sought feedback on their Draft Report on how they determine the wholesale price of ethanol. Bioenergy Australia has prepared a response to provide feedback on IPART’s approach to determine ethanol prices and to support the NSW Biofuels Act 2007 and its goal of encouraging the use of sustainably produced ethanol in NSW.
Inquiry into Renewable Energy Innovation in the ACT (May 2021)
The Standing Committee on Environment, Climate Change and Biodiversity has inquired into matters relating to renewable energy innovation in the ACT and the opportunities and challenges to establish the ACT as a national hub for renewable energy innovation. Bioenergy Australia has prepared a response to present how bioenergy technologies can play a key role in driving renewable energy innovation in the ACT.
Following our submission to the Inquiry into Renewable Energy Innovation in the ACT, Bioenergy Australia was invited to appear at a hearing for this inquiry. In this occasion, we were asked to provide supplementary information on the comparison between gas and electricity for residential heat usage.
Read our supplementary information here.
Inquiry into Dispatchable Energy Generation and Storage Capability in Australia (May 2020)
The House Standing Committee on the Environment and Energy has been asked to inquire and report on the current circumstances, and the future need and potential for dispatchable energy generation and storage capability in Australia. Bioenergy Australia has prepared a response to highlight the key role of bioenergy technologies in securing dispatchable energy generation and storage capability in Australia.
Queensland Biofutures 10-Year Roadmap and Action Plan - Refresh (May 2021)
In 2016, the Queensland Biofutures 10-Year Roadmap and Action Plan (Roadmap) was launched to set out a vision to create a sustainable and export-oriented industrial biotechnology and bioproducts sector. The Queensland Government is now in the process of refreshing the Roadmap and has souught feedback to consider future directions including new opportunities and challenges. Bioenergy Australia has prepared a response to present key opportunities for the Queensland Government to show strategic leadership and vision in driving forward its bioeconomy, while supporting industry development, job creation and economic growth.
NSW Energy from Waste Policy Statement (April 2021)
The NSW EPA has sought feedback on proposed changes to the NSW Energy from Waste Policy Statement recommended by the NSW Chief Scientist and Engineer. Bioenergy Australia has prepared a response to encourage NSW EPA to support energy from waste practices as part of the overarching principles to waste avoidance and recovery highlighted in the policy statement.
Draft NSW Clean Air Strategy (April 2021)
The NSW Government has released the draft NSW Clean Air Strategy for community and stakeholder consultation. The draft strategy presents the whole of NSW Government approach to improving air quality and protecting communities. The draft Strategy aims to support liveable communities, healthy environments and the NSW economy by reducing the adverse effects of air pollution on human health. Bioenergy Australia has prepared a response to highlight the role of a strong bioeconomy in achieving some of the outcomes listed in the strategy, including the transition to cleaner industry, transport, engines and fuels.
Victoria's gas infrastructure (April 2021)
Infrastructure Victoria has been asked to provide the Victorian Government with advice relating to Victoria’s gas transmission and distribution networks under a range of net zero emission 2050 energy sector scenarios and Bioenergy Australia was encouraged to provide comments. We have prepared a response for Infrastructure Victoria to highlight the opportunities of renewable gas in the decarbonisation of the gas network.
RGA submissions to the CER to assist with the development of a Biomethane ERF method (April 2021)
Bioenergy Australia’s Renewable Gas Alliance (RGA) is working closely with the Clean Energy Regulator (CER) on the co-design process for the creation of a biomethane ERF method. The RGA is keen to ensure creation of a meaningful ERF methodology for biomethane that will support industry growth and emissions reductions in Australia. The RGA has submitted two letters to the CER. One providing feedback on the initial method consultation, and a second letter answering specific questions relating to the inclusion of agricultural waste in the method, in particular addressing co-benefits, emissions reduction and investment potential of including agricultural waste in the method.
Read our letters here and here.
Future Fuels Strategy (April 2021)
The Government has released a discussion paper to further inform the development of Australia’s Future Fuels Strategy. The discussion paper outlines the Government’s vision to create an environment that enables consumer choice, stimulates industry development, and reduces emissions in the road transport sector. The paper considers the role of a mix of technologies, including traditional fuel, hybrid, hydrogen fuel cell, battery electric and bio-fuelled vehicles. Bioenergy Australia has responded with a submission to highlight the role of bio and renewable fuels, including bio and renewable diesel, ethanol and biomethane, in enabling the private sector to commercially deploy low emissions road transport technologies at scale.
Vulnerable Supply Chains (April 2021)
The Government has asked the Productivity Commission to examine the nature and source of risks to global supply chains. The Commission will develop a framework for identifying supply chains that are vulnerable to disruption, identify imports of goods that might be vulnerable, and identify possible strategies to manage supply chains risks. Bioenergy Australia has responded with a submission to highlight how the development of a bio-economy could support Australia’s resilience to global supply chain disruptions.
Corporate Emissions Reduction Transparency report Consultation Paper (March 2021)
The Clean Energy Regulator has sought feedback on the design of a new Corporate Emissions Reduction Transparency (CERT) report that will help National Greenhouse and Energy Reporting (NGER) reporters show how they are meeting their emissions reduction goals. Bioenergy Australia has responded with a submission to support the development of this new instrument, as it is a useful exercise to improve transparency around actions to meet voluntary commitments.
Proposed Waste and Resource Recovery Determinations Discussion Paper (March 2021)
The Victorian State Governement and the Environment
Protection Authority (EPA) have sought feedback on a series of legislative instruments called determinations which operate in the same way as standards. Determinations set specifications and conditions for the receipt of industrial waste which, when met, will enable the lawful use of these recovered materials without any further self-assessment or EPA approval. EPA has developed these determinations to reduce regulatory burden for those using four relatively low-risk wastes — processed organic wastes, manures (including animal wastewater and effluent), fill material and
aggregates. Bioenergy Australia has responded with a submission.
ACOLA Australian Energy Transition Research Plan (March 2021)
The Australian Council of Learned Academies (ACOLA)
is testing initial energy research priorities for the Australian Energy Transition Research Plan. They are asking, do the three themes of research priorities, and underpinning eight streams, provide an appropriate framework for the Research Plan, and are there areas for improvement? Do the indicative research questions identify the most critical research gaps (are some already being adequately addressed; have any been missed)? Bioenergy Australia has responded with a submission, encouraging the inclusion of Bioenergy as a technology to be researched.
Light Vehicle Emissions Standards for Cleaner Air (February 2021)
Australia currently mandates the Euro 5 noxious
emissions standards for newly approved models first manufactured from 1 November 2013, and for all light vehicles manufactured from 1 November 2016. A Draft Regulation Impact Statement (draft RIS) has been released for further targeted consultation with key stakeholders. It evaluates whether the Australian Government should mandate more stringent standards to reduce noxious emissions from light road
vehicles. Bioenergy Australia has responded with a submission.
Gas Fired Recovery Plan (February 2021)
The Australian Government’s vision for a
gas-fired recovery for Australia’s economy will be delivered through a number of measures across 3 key action areas:
- unlocking supply
- efficient transportation
- empowering consumers
The Department of Industry, Science, Energy and Resources is currently developing measures to address these key areas and Bioenergy Australia has responded with a submission.
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BIOENERGY AUSTRALIA The Commonwealth Government will be releasing the first Bioenergy Roadmap in the coming months. This will identify key sectors and target areas, such as bio-based hydrogen, that Australia should pursue and will also identify the job and economic development potential of Australia’s future bioeconomy. Concurrently, the Roadmap will detail barriers for development of Australia’s bioenergy industry and possible ways these barriers can be overcome. |
2020
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Options for a prospective national gas reservation scheme (November 2020) Submission (November 2020) The Australian Government is committed to exploring options for a prospective national gas reservation policy. This aims to ensure Australian gas users get the energy they need at a reasonable price. The gas reservation issues paper, to which Bioenergy Australia has made a submission, addresses: |
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Climate Change (National Framework for Adaptation and Mitigation) Bill 2020 and (Consequential and Transitional Provisions) Bill 2020: Committee Inquiry Submission (November 2020) The purpose of this submission from Bioenergy Australia is to offer its support of the Climate Change (National Framework for Adaptation and Mitigation) Bill 2020 and Climate Change (National Framework for Adaptation and Mitigation) (Consequential and Transitional Provisions) Bill 2020 (‘the Climate Change Bills’). Read submission here |
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Sustainable Aviation Fuel Alliance of Australia and New Zealand the Future of Australia's Aviation Sector Submission (November 2020) The Sustainable Aviation Fuel Alliance of Australia and New Zealand (SAFAANZ) is a working group developed by Bioenergy Australia to provide a collaborative environment to advance sustainable aviation fuel production, policy, education and marketing in Australia and New Zealand. Bioenergy is a cross-sector solution, which can support the country in facing environmental and socio-economic challenges. Read Submission Here |
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Hume Regional Climate Change Adaptation Strategy Submission (November 2020) The Victorian Government is partnering with communities to address impacts resulting from the changing climate. Climate Ready Hume is a two-year program developing a Hume Regional Climate Change Adaptation Strategy (Strategy), whilst supporting local projects, education and awareness on climate change adaptation. Climate Ready Hume is sponsored by Supporting our Regions to Adapt, a $9.3 million program funded through the Sustainability Fund. here. |
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Energy Security Board - Post 2025 Market Design Submission (October 2020) The Council tasked the ESB with developing advice on a long-term, fit-for-purpose market framework to support reliability that could apply from the mid-2020's. By the end of 2020, the ESB needs to recommend any changes to the existing market design or recommend an alternative market design to enable the provision of the full range of services to customers necessary to deliver a secure, reliable and lower emissions electricity system at least-cost. here. |
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VRET II Market Sounding Submission (October 2020) In September 2020, the Victorian Minister for Energy, Environment and Climate Change announced a market sounding process that will test industry interest and capacity for new renewable energy projects. The market sounding process is an important step towards supporting investment in new renewable generation to create jobs, support the state’s economic recovery from the COVID-19 pandemic, and contribute to the achievement of Victoria’s renewable energy targets. Bioenergy Australia congratulates the Victorian Government for supporting the ongoing development and review of VRET and would like to reinforce the opportunity for Bioenergy across VRET II. Read our submission here. Wagga Wagga Special Activation Precinct (September 2020) Set to be a world-class business precinct, the Wagga Wagga Special Activation Precinct will capitalise on its location to create opportunities across a range of industries to benefit the region. The SAP has a strong focus on sustainability, seeking to minimise carbon emissions and environmental impact and maximise use of renewable energy. Bioenergy Australia has contributed feedback, viewable here. |
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Queensland’s Biofuture to Drive Australia’s Economic Recovery (September 2020) In the lead up to the Queensland election, Bioenergy Australia is calling for bipartisan backing for Queenland’s biofuture, proposing a suite of initiatives that will support the industry development, job creation and economic growth that is going to be vital to Queensland, and indeed Australia’s, recovery from this devastating pandemic. Read the full proposal here.
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Draft Tasmanian Renewable Energy Action Plan Submission (September 2020) The Tasmanian Government has identified renewable energy as a key economic driver as they rebuild a stronger Tasmania. The Tasmanian Government has released the draft Renewable Energy Action Plan which outlines their vision and suite of actions to develop renewable energy generation in Tasmania over the coming 20 years. Bioenergy Australia has contributed feedback on the draft Plan, viewable here.
Opportunities to increase Australia's domestic fuel storage capacity (July 2020) On 22 April 2020, the Minister for Energy and Emissions Reduction, the Hon Angus Taylor MP announced the Australian Government is taking steps to boost the nation’s long-term fuel security. As the next step, on 15 June 2020, the Government opened a non-binding Request for Interest (RFI) process to better understand the opportunities to increase domestic liquid fuel storage. Bioenergy Australia prepared a response to highlight the role of biofuels in this space. Read our submission here. |
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The NSW Government released a consultation paper to seek feedback on the implementation of the Strategy’s Energy Security Target (EST) and the Energy Security Safeguard (the Safeguard). The aim of these initiatives is to set high targets for reliability while delivering affordable and sustainable energy for the people of New South Wales. Bioenergy Australia supports the inclusion of bioenergy technologies in the scheme as part of the expansion to fuel switching activities that reduce demand on electricity and gas networks. Read our submission here. |
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The Minister for Energy and Emissions Reduction has commissioned the development of a Technology Investment Roadmap, which will help inform Australia’s first Low Emissions Technology Statement and will be a critical input to Australia’s Long Term Emissions Reduction Strategy. Bioenergy Australia congratulates the Federal Government for supporting the development of the Roadmap and reinforces the inclusion of the ARENA Bioenergy Roadmap in its development and findings. Bioenergy Australia has developed a general submission to provide overarching feedback on the roadmap, but more detailed information can be found in the individual submissions prepared by Bioenergy Australia working groups. Read our submissions below. Bioenergy Australia Submission Cleaner Fuels Alliance Submission Heat & Power Committee Submission Renewable Gas Alliance Submission Sustainable Aviation Fuel Alliance of Australia and New Zealand Submission |
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At the request of the Government, the Australian Renewable Energy Agency (ARENA) has started to develop a Bioenergy Roadmap and has called for public submissions on how Australia can build its bioenergy sector and strengthen the country’s energy security. Bioenergy Australia welcomes the develo |
Energy Security Target and Safeguard (June 2020)
Technology Investment Roadmap (June 2020)
Bioenergy Roadmap (June 2020)