Sequencing national renewable gas policy

The official consultation question

Q53 · §4.8(a) · paper page 35

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.

Shelby’s response

Having observed first-hand the development of the biogas and biomethane industry in France and Europe, we launched Shelby Australia in 2021 where our early work lacked practical information required to move from resource potential to investable projects: regional feedstock and demand mapping, realistic electricity and logistics costs, technology integration, approvals, certification, customer qualification and routes to market. Access to information have improved since then; we are now building a commercial viability model and a comprehensive feasibility tools to encourage small and medium projects across Australia. Recent initiatives such as The national Guarantee of Origin scheme, NSW’s Renewable Gas Production Program supports and the NSW Renewable Fuel Scheme create useful momentum. The next step is to translate policy, certification and resource potential into repeatable operating projects and investable business models.

We’d recommend the following sequence:

- First, establish the commercial conditions for investment and activate existing facilities. Publish dependable long-term purchasing or equivalent revenue-support arrangements, with approximately 15 years used as a starting point for testing against financing needs rather than as a fixed rule. Pricing, indexation, eligibility and certificate treatment should be clear before major development expenditure. Combine revenue certainty with targeted development and capital assistance for existing anaerobic-digestion facilities, modular upgrades and new regional plants. Feedstock, electricity, approvals, delivery and certification must be assessed together.

Co-product commercialisation should begin at the same stage, not after the gas project is built. Biomethane upgrading, BioCO2 recovery and appropriate digestate-processing systems can increase saleable output and diversify revenue, but only where a credible customer and positive netback exist after purification, liquefaction or processing, quality assurance, storage and delivery. Smaller regional producers should be able to share logistics, storage, laboratory services, maintenance and commercialisation where this lowers cost. This model can also support Australian fabrication, assembly and service capability as deployment grows.

- Second, replicate successful projects and expand shared infrastructure only where operating evidence justifies it. Standardise technical documentation, contracts and approval processes; build local commissioning and maintenance capability; and develop hubs, network reinforcement, reverse-flow capacity, shared CO2 logistics or other common infrastructure where credible production and customer demand support the investment. Infrastructure should follow demonstrated commercial need rather than precede it by default.

- Third, broaden deployment as markets mature. Maintain development pathways for bioLPG, renewable hydrogen, e-methane and other renewable gases from the outset, then expand commercial support as technical and market evidence strengthens. Export opportunities should be assessed where they enable additional Australian production and investment without undermining domestic objectives. Policy reviews should improve arrangements for future projects while preserving commitments on which existing investments were financed.

Sequencing should follow the barriers preventing FID, the additional useful output achievable, and the readiness of producers and customers. Delivered cost, sustainable feedstock, utilisation, verified emissions performance, community acceptance and infrastructure requirements should guide decisions. Revenue certainty, approvals and co-product market access therefore need to progress in parallel. The objective should be operating regional businesses that create the performance data, skills, supply chains and investor confidence required for wider national growth. Thank you

Frequently asked questions

What is Shelby’s position on sequencing national renewable gas policy?

Commercial conditions and co-product markets should develop together before wider expansion. Shelby recommends activating facilities, replicating proven projects and broadening deployment as evidence strengthens, with infrastructure following demonstrated demand and existing investment commitments protected.

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.