Shelby Bioenergy · October 2026 · Australia
Certification gaps and practical market access
Certification should clarify purchasing claims, emissions reporting and funding eligibility without duplicate audits or double counting. Shelby recommends coverage for direct use, direct supply and injection, with separate verification for co-product origin, quality and environmental benefits.
Shelby’s position, not adopted government policy or confirmation of lodgement. Historical evidence and policy-modelling assumptions are distinguished in the response.

The official consultation question
Q26 · §4.2(a) · paper page 26
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.
Shelby’s response
The frameworks provide a useful foundation, but practical gaps remain. Shelby recommends clear guidance on how PGO and RGGO certificates support purchasing, emissions reporting and funding eligibility, including transitional arrangements. Coordinate verification requirements to minimise duplicate audits and prevent double counting, with proportionate costs for smaller regional plants and existing facilities adding modular upgrades. Coverage should accommodate direct-use biogas, direct-supply biomethane and network injection, clearly distinguishing renewable origin, lifecycle emissions intensity and the claims buyers may make.
As the industry develops, establish complementary pathways for co-products such as recovered biogenic CO₂ and pursue overseas recognition where it enables market access. Co-product origin, quality and environmental benefits require separate verification. Certification should help producers secure customers and commercialise output, supported by dependable long-term purchasing and revenue arrangements that make investment possible.
Frequently asked questions
What is Shelby’s position on certification gaps and practical market access?
Certification should clarify purchasing claims, emissions reporting and funding eligibility without duplicate audits or double counting. Shelby recommends coverage for direct use, direct supply and injection, with separate verification for co-product origin, quality and environmental benefits.
What should a project team read alongside this answer?
Read the linked commercial guides and original question. Separate the response’s recommendations and illustrative assumptions from source-reported operating evidence.
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.