Shelby Bioenergy · October 2026 · Australia

National Renewable Gas Policy 2026

Shelby Bioenergy’s October 2026 response addresses 53 questions on Australia’s National Renewable Gas Policy. It recommends coordinated revenue certainty, practical approvals, regional deployment and co-product markets. The collection separates official questions, Shelby’s proposals and illustrative modelling, for Australian production and customers. Publication does not establish government endorsement or lodgement.

Shelby’s position, not adopted government policy or confirmation of lodgement. Historical evidence and policy-modelling assumptions are distinguished in the response.

Regional bioenergy facilities and review documents for the 2026 renewable gas consultation
Conceptual illustration · not a project photograph or engineering design

Question-by-question responses

  • Q01 · Role of renewable gas in the energy transition

    §2(a) · Given that some sectors are expected to maintain reliance on gaseous fuels until alternatives are developed and deployed, should certain sectors (e.g. hard-to-abate industries) be given a higher priority or focus of a national renewable gas policy? If so, which sectors and why?

  • Q02 · Biomethane and renewable hydrogen pathways

    §2.4(a) · Should the work on a national renewable gas policy focus on biomethane, or should other renewable gases, such as bioLPG, biogas and renewable hydrogen, be included? Please explain your reasoning.

  • Q03 · Why Australia needs national renewable gas policy

    §2.5(a) · Does Australia need a national renewable gas policy? Why or why not? If you think it is needed, what are the most pressing issues or barriers it should address to support industry development?

  • Q04 · Six measures for a coordinated gas industry

    §2.5(b) · What policy mechanisms or levers do you think are necessary to enable a nationally coordinated renewable gas industry? Please outline approaches, tools, and mechanisms you consider most important and why. In your response please be as detailed as possible about how these actions would support the industry, and/or address issues you are encountering with specific projects.

  • Q05 · Revenue certainty for final investment decisions

    §2.5(c) · What minimum level of policy certainty (e.g. duration, support mechanism) is needed to reach final investment decisions for projects?

  • Q06 · Renewable gas premium and additional production

    §2.6(a) · Do you support the use of a renewable gas premium (multiplier) within the DSO framework to encourage investment in renewable gas production? Why or why not?

  • Q07 · Protecting physical domestic gas supply

    §2.6(b) · How could a renewable gas premium be designed to support investment in renewable gas production while maintaining the domestic gas supply objectives of the DSO?

  • Q08 · Setting a renewable gas multiplier

    §2.6(c) · What factors would need to be considered to determine an appropriate multiplier level over time?

  • Q09 · Renewable origin and gas quality certification

    §2.6(d) · Should Product Guarantee of Origin (PGO) certificates, GreenPower Renewable Gas Guarantee of Origin (RGGO) certificates, or any other certification scheme, be required to verify renewable gas production and use in Australia?

  • Q10 · Premium implementation and compliance rules

    §2.6(e) · Are there any other design, implementation or compliance issues that would need to be considered?

  • Q11 · Commercial viability and circular economy objectives

    §3.1(a) · Do you agree with the objectives outlined above? Are there any important objectives missing or any that should not be included? Please provide detailed reasoning in your response.

  • Q12 · Primary and enabling renewable gas objectives

    §3.1(b) · Should any objectives be treated as primary, with others viewed as secondary or enabling? If so, which ones and why?

  • Q13 · Near-term renewable gas priorities to 2030

    §3.1(c) · Are there objectives that should explicitly take precedence in the near term (e.g. to 2030), even if this requires trade-offs with other objectives? Please explain your reasoning.

  • Q14 · Policy trade-offs and public value

    §3.1(d) · Where do stakeholders see the most significant trade-offs between objectives (e.g. domestic affordability or domestic decarbonisation versus export potential)? How could a national policy help manage or resolve these tensions?

  • Q15 · Biomethane and future gas supply shortfalls

    §3.1(e) · What role could biomethane play in addressing risks of future natural gas supply shortfalls? Based on your experience or projections, what do you consider is a realistic timeframe for industry to develop and operate commercially in the context of risks of future shortfalls?

  • Q16 · Production targets and delivered biomethane

    §3.1(f) · Would an aspirational production target be appropriate to measure growth of the biomethane industry? If so, what form could a target take, and how might it be used?

  • Q17 · Exports and additional Australian production

    §3.1(g) · Should exports be a consideration for developing a renewable gas industry? Please provide detailed reasoning in your response.

  • Q18 · Testing export premiums and net revenue

    §3.1(h) · If exports should be considered, what sort of premium is the export market prepared to pay? Please include the basis of any data you provide.

  • Q19 · Commercial readiness by renewable gas pathway

    §3.2(a) · Which renewable gases do you consider are commercially deployable at scale today in Australia, and which technologies or pathways remain pre-commercial or only suited to niche applications?

  • Q20 · Biogas and biomethane deployment priorities

    §3.2(b) · Should there be a priority on particular renewable gases over others? If so, which ones, and why? Please provide detailed reasoning, including any considerations related to commercial readiness, emissions impact, regional opportunities, or market demand.

  • Q21 · Biomethane production costs and cost drivers

    §4.1(a) · What are your current and projected levelised costs (A$ per GJ) over the next 5–10 years, broken down by technology type and scale? Please describe the key cost drivers behind these estimates, including any assumptions or factors that may influence future cost trajectories.

  • Q22 · Modular learning and project reference scales

    §4.1(b) · What economies of scale or learning effects are you anticipating over the next 5-10 years, and what levels of production would be required to realise these benefits?

  • Q23 · Customer willingness to pay a green premium

    §4.1(c) · Are you aware of what customers are willing to pay as a green premium for biomethane or other renewable gases? If so, please provide details between the levelised cost of production and customer willingness to pay.

  • Q24 · Policy-sensitive project cost components

    §4.1(d) · Which cost components are most sensitive to policy settings in your experience. For example, factors such as availability of and access to feedstock, approval timeframes, revenue streams from co-products? Please outline any specific sensitivities relevant to your project or business model.

  • Q25 · Closing the renewable gas cost gap

    §4.1(e) · What types of policies or mechanisms across the renewable gas value chain might best address the cost gap between renewable gases and natural gas? In your response, please describe how these measures would help improve cost competitiveness and support market development.

  • Q26 · Certification gaps and practical market access

    §4.2(a) · Do the current and announced certification frameworks and certification products for renewable gases (including those in Appendix A) adequately support near-term, medium-term and long-term industry development? If not, please outline any critical gaps or limitations that need to be addressed.

  • Q27 · Network connection and delivery impediments

    §4.3(a) · Are there any impediments to accessing the distribution network or other renewable gas infrastructure, such as required for production facilities?

  • Q28 · Shared gas infrastructure and cost allocation

    §4.3(b) · How do you view the current arrangements under the National Gas Law and National Gas Rules for new or expanded infrastructure in relation to emerging biomethane projects?

  • Q29 · Off-grid renewable gas infrastructure

    §4.3(c) · What role can non-natural gas infrastructure, such micro-LPG networks, play in supporting renewable gas development and decarbonisation? Are there impediments to accessing this infrastructure?

  • Q30 · Regional workforce and specialist skills

    §4.4(a) · Are stakeholders concerned about attracting a qualified and skilled workforce to support renewable gas projects? If so, what are the reasons for this and what actions could help address them?

  • Q31 · Graduate recruitment and career pathways

    §4.4(b) · Do you think involvement in renewable gas projects improves the industry’s ability to attract newly qualified applicants? Please explain any evidence or experience that informs your view.

  • Q32 · Renewable gas reputation and employment

    §4.4(c) · Are there any reputational or perception-related issues that affect interest from qualified applicants to the gas industry? If so, how would greater awareness or visibility of renewable gas projects help address these issues?

  • Q33 · Regional opportunities and project constraints

    §4.4(d) · How do regional factors influence the development of the renewable gas industry? What opportunities or challenges do you see in regional areas that may affect the development of the renewable gas industry?

  • Q34 · Feedstock processing and state regulations

    §4.5(a) · What challenges have stakeholders encountered or are anticipating regarding the regulations that govern the treatment of feedstocks? Please provide detailed examples of the specific regulations.

  • Q35 · Feedstock rules and investment barriers

    §4.5(b) · Are current feedstock regulations preventing the development of biomethane projects? If so, what changes are needed? Please provide specific examples.

  • Q36 · Inputs for other renewable gas pathways

    §4.5(c) · Are there other feedstock sources or issues relating to access and management that need to be addressed for other renewable gases (e.g. bioLPG)?

  • Q37 · Securing dependable biomethane feedstock

    §4.5(d) · What are the issues affecting access to and availability of feedstock for biomethane production?

  • Q38 · Imported feedstocks and local alternatives

    §4.5(e) · Are stakeholders exploring importing feedstocks for biomethane production? If yes, which feedstocks, from which regions, and for what strategic or economic benefits?

  • Q39 · Prioritising feedstock and waste reforms

    §4.5(f) · Should the regulations affecting the treatment of feedstocks and waste streams be prioritised in a national policy?

  • Q40 · Co-product markets and retrofit opportunities

    §4.6(a) · Is facilitating the development of markets for biomethane co-products critical for the growth and long-term sustainability of the industry? What is the potential size and value of these markets? Should this be a priority in a national policy?

  • Q41 · Commercialising digestate and biogenic CO2

    §4.6(b) · What are the key barriers to commercialising co-products, including the use of digestate as biofertilisers, and how do these barriers affect project viability or scale-up pathways?

  • Q42 · Co-product certification and CO2 netback

    §4.6(c) · Noting GreenPower’s announcement about developing a biogenic CO2 certification, subject to recognition in broader frameworks (e.g. NGERs) are there gaps in national certification or standards for this or other co-products?

  • Q43 · International co-product practice examples

    §4.6(d) · Are there best international practice examples that could inform future work on co-products? In the absence of relevant standards, what other approaches could help harmonise the treatment of co-products across projects, jurisdictions and markets?

  • Q44 · Approvals for complete commercial operations

    §4.7(a) · Are there specific regulatory issues stakeholders have encountered or are anticipating that will impact their projects? Please be detailed in your response.

  • Q45 · Overlapping approvals and shared evidence

    §4.7(b) · Are there areas where overlapping approvals, duplicative processes or regulatory gaps create undue complexity or delay? If so, what are they? Please be detailed in your response.

  • Q46 · International permitting and product frameworks

    §4.7(c) · Do you know of any international best practice regulatory approaches that should be considered?

  • Q47 · Project timelines and approval efficiencies

    §4.7(d) · Which regulatory processes most affect project timelines, and where could efficiencies realistically be achieved?

  • Q48 · Digestate waste-to-product pathways

    §4.7.1(a) · To what extent does the classification of digestate as a “waste” create barriers to its commercial use, transport, or sale?

  • Q49 · Consistent co-product rules across states

    §4.7.1(b) · Do inconsistencies in digestate or biogenic CO₂ regulation across states or territories affect the scalability and investment feasibility of biomethane projects?

  • Q50 · Building confidence in digestate fertiliser

    §4.7.1(c) · What regulatory or policy changes would most strengthen market confidence in digestate as a fertiliser or soil amendment?

  • Q51 · Biogenic CO2 customer qualification

    §4.7.1(d) · Are there regulatory barriers preventing biogenic CO₂ from being sold into food, beverage or industrial markets?

  • Q52 · Digestate certification and agricultural trust

    §4.7.1(e) · Would a regulatory or certification framework help build trust and acceptance of digestate products among agricultural users?

  • Q53 · Sequencing national renewable gas policy

    §4.8(a) · Given the range of issues canvassed in this section of the paper, is there a need to sequence or stage areas of focus within a national renewable gas policy? If so, which areas should be prioritised early, which should follow later, and what factors should guide the sequencing? Please provide detailed reasoning in your response.

Frequently asked questions

Is this adopted Australian Government policy?

No. These pages reproduce Shelby Bioenergy’s October 2026 consultation response. The government’s August 2026 paper is the source of the questions. Shelby’s recommendations, proposed support ranges and modelling assumptions are not adopted policy or guaranteed payments.

Does publication confirm that Shelby’s response was lodged?

No. Publication of the supplied response does not establish submission or government endorsement. Refer to DCCEEW for the official consultation process and subsequent policy decisions.

Can the figures be used as project prices or forecasts?

No. Read each figure’s stated basis. Historical counts, cited study estimates, policy-testing ranges and illustrative project sensitivities answer different questions. A project needs current quotations, qualified engineering advice, contracted demand and location-specific approvals.

Sources & References

  • Department of Climate Change, Energy, the Environment and Water, National Renewable Gas Policy consultation

    Publication: Date not verified

    Observation period: Not recorded

    Relevant page / section: Claim-level locator not yet verified

    Last link / title verification: 2026-10-11

    Publisher link checked; individual claims, costs and regulatory applicability still require review.

    Check scope and current applicability before relying on this reference.

  • Department of Climate Change, Energy, the Environment and Water, National Renewable Gas Policy consultation paper

    Publication: 2026-08

    Observation period: Australia; 2026 consultation

    Relevant page / section: Consultation questions; use answer-specific paper page and question reference

    Last link / title verification: 2026-10-11

    Publisher link checked; individual claims, costs and regulatory applicability still require review.

    Source for questions/context, not proof of an implemented support mechanism. Question text attribution: Commonwealth, CC BY 4.0, as noted in Shelby’s supplied consultation response.

  • Creative Commons, Attribution 4.0 International

    Publication: Date not verified

    Observation period: Not recorded

    Relevant page / section: Claim-level locator not yet verified

    Last link / title verification: 2026-10-11

    Publisher link checked; individual claims, costs and regulatory applicability still require review.

    Check scope and current applicability before relying on this reference.