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National Reconstruction Fund Taskforce
Department of Industry, Science and Resources
Industry House, 10 Binara Street
CANBERRA ACT 2600
7 February 2023
Submission – National Reconstruction Fund consultation paper
A proud Australian company, Fortescue Metals Group (FMG) is the fourth largest producer of iron ore in the world, exporting over 185 million tonnes of iron ore annually through our integrated mining, rail, and shipping network in the Pilbara.
Through our iron ore business, FMG is a reporting entity under the National Greenhouse and Energy
Reporting Act 2007 (NGER Act). FMG has a strong focus on decarbonisation, evidenced by our industry leading target to eliminate carbon emissions by 2030, and net-zero Scope 3 emissions by
2040.
Through our subsidiary, Fortescue Future Industries (FFI), we are establishing an Australian and global portfolio of green hydrogen production and manufacturing projects and operations that positions us at the forefront of the global green hydrogen industry.
FMG and FFI (Fortescue) welcomes the opportunity to provide a joint submission on the National
Reconstruction Fund (NRF) consultation paper (paper) and focusses its feedback on how the NRF could support a green hydrogen value chain being created this decade, resulting in significant manufacturing benefits upstream and downstream of green hydrogen production.
Focusing on a green hydrogen value chain
Fortescue believes that creating a green hydrogen production industry as fast as possible and at a scale geared to early export offtake demand, will provide significant upstream and downstream manufacturing industry growth opportunities, provide clean fuel at a price that domestic users can afford and provide fuel and energy security that is clean and affordable while directly reducing and not just offsetting carbon emissions.
Green hydrogen is widely considered critical for Australia’s transition from a fossil-fuel based resource economy to a clean energy superpower. This is because hydrogen has cross-cutting potential to decarbonise multiple end industries, like renewable energy. Australia stands on the precipice of unlocking a virtuous feedback loop of clean energy manufacturing, enabled by hydrogen, where regional communities will be the primary beneficiaries of value-added economic activity, jobs, and emissions reduction. Yet crossing this tipping point is proving challenging and the clock is ticking.
This decade, the global hydrogen market is expected to deliver significant and persistent first mover advantages and positive economic spillover effects driven by long term off-take contracts. As recognised in numerous studies, including Australia’s National Hydrogen Strategy, Australia has significant comparative advantage in the development of a globally scaled hydrogen industry.
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However, it is Fortescue’s view, supported by analysis it commissioned Deloitte Access Economics to conduct, that three factors are eroding Australia’s hydrogen competitiveness:
1. persistently high prices for renewable energy,
2. misaligned decarbonisation incentives for domestic hydrogen users, and
3. assertive policy interventions by export competitors, such as the US Inflation Reduction
Act 2022 (US IRA), Canada’s Clean Hydrogen Investment Tax Credit, Europe’s proposed Net-
Zero Industry Act and Gulf Sovereign Wealth Funds.
These challenges are impacting the investment environment for Australian hydrogen projects today.
Crucially, they are acting to delay Australian projects securing offtake agreements during the formative development period of a global market where incremental delay forecloses market share.
In turn, this will slow the decarbonisation of Australia’s industrial base, inhibit momentum for regional economic diversification, and delay development of a new tax base.
Much like carbon, there is a time value of hydrogen policy linked to industry policy. There is a short window for Australia to act and ensure its competitiveness and lay the foundations for a significant new industry which will support current Australian domestic and export industries and catalyse the growth of other industries, particularly in manufacturing. The competition will continue to increase, but without intervention, Australia risks a smaller industry that does not live up to public promises, fails to deliver for regions in transition, and fails to provide an export revenue stream to replace the future decline in fossil fuels. The NRF has a part to play in targeting the green hydrogen industry value chain.
Australia’s green hydrogen ambitions and why this decade matters
The emerging market structure for green hydrogen appears likely to be a race to scale and offtake where first movers can expect to lock in significant and persistent advantages. There are several reasons to expect these first mover advantages, including:
1. Trajectory of similar industries: Early years of Australia’s Liquid Natural Gas (LNG) industry
(e.g., North West Shelf) were dominated by projects with 20-year offtake agreements to the
Japanese market – and Australia’s first mover advantage here has persisted to greater market
share today. Similar trajectories are observable in China’s dominance of the solar photovoltaic
(PV) & lithium-ion value chains, Europe’s outsized role in wind turbine manufacturing and
offshore wind services, US shale gas and the UK’s shipbuilding industry in the early 20th
century.
2. Intellectual property development: First movers will develop intellectual property and
control processes specific to at-scale hydrogen production – for example systems to optimise
production with mixed solar and wind resources. These intangible assets will enhance the
productivity of first movers and take time to diffuse to the wider market.
3. Colocation of the value chain: Many hydrogen industry players are vertically integrated and
early development of hydrogen production facilities is likely to be associated with early
development of other parts of the hydrogen value chain. This will support reinforcing
agglomeration effects across the value chain, with benefits for innovation and labour
productivity.
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As Figure 1 - an extrapolation of LNG’s development applied to hydrogen – shows, offtake agreements struck by 2030 represent the dominant share of the early market. By reaching scale early and locking users into long term supply contracts, first movers can strengthen their client relationships, build a brand and track record of delivery, and credibility with investors. This will position them to capture post-2030 offtake agreements as demand starts to scale more substantially.
By contrast, those who fail to move early will have to develop differentiated capabilities to challenge incumbent advantages and will be locked out of a significant share of the market. For comparison, it has taken 35 years for the share of seaborne LNG traded on long-term contracts to fall to 60% of the total market.
Figure 1: Expected Hydrogen Market Structure under 15-year offtake agreements
300 100%
90%
Annual New H2 Demand (Mt)
250
Offtake Share of Market
80%
70%
200
60%
150 50%
40%
100
30%
20%
50
10%
0 0%
2023 2026 2029 2032 2035 2038 2041 2044 2047 2050
Pre-2035 Offtake Post-2035 Offtake Spot
Proportion of mkt with long term contract
offtake
Key challenges for scaling Australia’s hydrogen manufacturing base
Australia is well positioned as a prospective global hydrogen exporter. We have world class renewable energy potential, ranking in the top two globally for onshore wind capacity and utility-scale solar PV capacity. Significant tracts of uncontested land also lower the risk that land-intensive renewables for hydrogen production will conflict with other uses. Finally, proximity to Asia provides a natural advantage exporting seaborne green hydrogen to Asia relative to other prospective exporters – effectively lower shipping costs.
However, Australia’s success is not pre-ordained, and the costs of complacency are high. In the near term, no country has comparative advantage in green hydrogen production – power prices are the key driver of cost variability. This is because original equipment manufacturers (OEMs) sell electrolysers on a global market, and capacity factors are in equivalence as developers will each select the best sites in each country for their first projects and each aspirational exporting market has some sites with high-capacity factors.
Three challenges are emerging which are undercutting Australia’s green hydrogen competitiveness in the near term:
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1. First, Australia’s high electricity prices are delivering unworkable hydrogen
economics. As Figure 2 shows, Australian power prices are 1.5 to 2 times higher than
export competitors. This is occurring for a range of reasons, including short term demand
for renewables, supply chain constraints, and approvals timetables delaying new
renewable energy supply coming online. Australia will not be able to compete to produce
green hydrogen at today’s renewable power prices. Moreover, hydrogen proponents who
aspire to vertical integration will still need to strike internal power purchase agreements
(PPAs) between their renewable assets and their hydrogen production facilities. This will
risk an opportunity cost to the extent there is a material gap between prevailing market
PPA prices and the cost of building, owning, and operating a renewable asset for hydrogen
production.
Figure 2: Comparative renewable electricity prices & impact on LCOH (on a $/kg basis)
5
4.5
FOR ILLUSTRATIVE
4 PURPOSES ONLY
3.5
LCOH $/kg
3
2.5
2
1.5
1
0.5
0
Australia US (pre-IRA) US (IRA power Saudi Arabia Chile
subsidy only)
2. Second, domestic hydrogen users face misaligned decarbonisation incentives
which impact the cost competitiveness of green hydrogen. As Error! Reference s
ource not found. shows, like all emerging technologies, green hydrogen faces a
commercialisation gap relative to incumbent technologies such as grey hydrogen and
natural gas. This commercialisation gap closes over time due to three factors: (1) learning-
by-doing reduces renewable hydrogen production costs; (2) rising carbon costs increase
user willingness to pay, and (3) technology cost reductions. While many Australian
industrial operators have made decarbonisation commitments, how they will deliver
emissions reduction is still being determined. Recent market developments suggest that
in the short-term industrial players are considering purchasing carbon offsets and
continuing with current production processes rather than switching to green hydrogen. A
low cost of carbon in Australia under the Safeguard Mechanism or reliance on low-cost
voluntary carbon offset units reduces the willingness to pay and therefore the likelihood of
domestic offtake agreements for green hydrogen. This may also incentivise hard to abate
industries to defer emissions reduction action in the short term, putting trade flows at risk
given rapid introduction of carbon border adjustment mechanisms.
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Figure 3: Australian Renewable Hydrogen LCOH vs Alternatives
FOR ILLUSTRATIVE
PURPOSES ONLY
3. Third, competitors are closing their hydrogen competitiveness gap through policy
intervention. This is most clearly seen through the compounding support offered in the US IRA.
The US IRA provides a renewable electricity production tax credit which lowers power prices by
USD$15/MW for ten years. A 30% investment tax credit for US-made renewable components,
which can increase to 50% depending on the location of the facilities and local content provisions
in production, could further lower costs per megawatt. In addition, the US IRA provides up to a
USD$3/kg hydrogen production credit. Together, these measures make US green hydrogen the
cheapest hydrogen worldwide – eliminating the commercialisation gap from commencement.
Preliminary modelling analysis undertaken by Deloitte Access Economics suggests that while the
US IRA is in effect, Australian hydrogen will only be exported to Japan and Korea in very limited
quantities (assuming the US has an export policy). Other hydrogen exporters are already
responding to the US IRA or scaling their industrial policies to close the hydrogen
commercialisation gap. For example, Canada’s carbon pricing regime increases domestic
willingness to pay for hydrogen, closing the commercialisation gap. In addition, Canada has
already responded to the US IRA’s hydrogen support measures announcing investment tax
credits and a co-investment vehicle to de-risk projects. Similarly, prospective producers in Gulf
States are benefiting from significant investments from Sovereign Wealth Funds with very long-
term return horizons and government-owned infrastructure (e.g., transmission, ports). These
investments are facilitating very low renewable electricity prices which significantly lowers the
levelized cost of hydrogen (LCOH) produced.
These challenges are impacting the investment environment for Australian green hydrogen projects today. Crucially, they are acting to delay Australian projects securing offtake agreements during the formative development period of the global market where incremental delay forecloses market share.
In turn, this will slow the decarbonisation of Australia’s industrial base, inhibit momentum for regional economic diversification, and postpone development of a new tax base.
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Priority areas of the NRF
Noting these opportunities and challenges that Australia has in creating a green hydrogen industry and the purpose of the NRF which is to support, diversify and transform Australia's industry and economy to help create secure, well-paid jobs, secure future prosperity, and drive sustainable economic growth, Fortescue strongly supports the NRF focussing on renewables and low-emission technologies, transport, defence capability and the value-add in agriculture, forestry and fisheries and resources sectors as priority areas.
What types of projects or investments should the Government direct the NRF to focus on, or not invest in, how much detail should be provided on each of the priority areas, and how should greater detail and the need for flexibility be balanced?:
Fortescue agrees with the amount of detail that the NRF currently states for priority areas.
Noting that new technologies will develop, these areas should be broad, and flexibility provided.
As a set of principles guiding the broad definition of priority areas and flexibility, the NRF should only support:
• projects which prioritise new industries and technologies, which enable the decarbonisation of
heavy industries without creating additional fossil fuel extraction (i.e., the NRF should not support
Carbon Capture and hydrogen gas produced from fossil fuels (e.g., blue and grey hydrogen).).
• projects that eliminate the use of fossil fuels and should not support projects that enable fossil fuel
extraction or use, such as carbon capture or fossil fuel-based hydrogen.
• projects that enable new industries to scale up, to reduce costs and generate export and job
opportunities.
How should industry ‘transformation’ and ‘diversification’ be defined and measured for each of the seven priority areas, and how should ‘value add’ be defined and measured in relation to relevant priority areas?:
Transformation and diversification and value adding of priority areas should include a measure of how the project supports a new green hydrogen industry in terms that it:
• targets the growth of green hydrogen for sectors of comparative advantage across the energy-
industrial base. Targeting should focus on leveraging domestic demand and Australia’s advanced
position in the energy transition to create economically sophisticated, co-located, and long-term
export industries in regional Australia, such as green steel.
• accelerates the deployment of scaled renewables to increase availability of renewable energy
supply and drives down electricity costs.
• ensures green hydrogen components are built in Australia.
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Investment mandate of the NRF
Investment needs and opportunities
What are the manufacturing capabilities needed to support the renewables and low-emission technologies priority area?
• Electrolysers and fuel cells
• Wind turbine blades and towers
• Batteries
• Solar photovoltaic assemblies
What are the manufacturing capabilities needed to support the transport and resources value- add priority areas?
• Fast chargers for train rolling stock and trucks
• Batteries for Offboard Power Units (OPUs), trucks and train rolling stock
• Train rolling stock – including locomotives and wagons
• Ammonia engines (including conversion kits) for ships and trains
• Ammonia storage and transport
• Ammonia to Hydrogen conversion
• Liquid Hydrogen technologies – including Gaseous/Liquid hydrogen storage and transport.
• Hydrogen to Ammonia conversion
• Batteries for train rolling stock, OPUs and trucks
• Battery Control Systems for train rolling stock, OPUs and trucks
• Fuel Cells for electrified drills and excavators, OPUs and trucks
• Green iron and green steel manufacturing components
What are other capabilities needed to support and what are the strategic priorities for supply chains / enabling inputs?
• Electrical Transmission and Storage
o High Voltage Direct Current cables
o High Voltage Alternating Current
o Surface cables
o Submarine cables
o Batteries
• Electrolysers and fuel cells
o Including electrode and membrane manufacturing, onsite recycling
• Batteries – cathode and anode production
• Wind energy – turbines and nacelles
What are the gaps in or barriers to private sector investment in each of the priority areas?
• High upfront costs: Private sector investments are often deterred in investing in renewable energy
projects due to the need for substantial upfront capital investment
• Uncertain returns: Because of the rapidly evolving nature of the renewable energy industry, it can
be challenging for private investors to predict returns on investment with any degree of accuracy
• Lack of grid infrastructure: In many areas, the inability of the grid to support the integration of
renewable energy can act as a deterrent to private sector investment
• Regulatory ambiguity: Renewable energy regulations and policies are constantly evolving and
occasionally at odds with one another, which can lead to ambiguity and discourage private sector
investment
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• Competition with established energy sources: Renewable energy may find it challenging to
compete and draw in private investment due to competition with established energy sources like
fossil fuels, which may receive government subsidies and other forms of support
• Technical and operational issues: Issues with renewable energy projects' technical and
operational operations, like intermittency, may prevent the private sector from investing in them
• Access to financing can be a major deterrent to private sector investment in the renewable energy
sector, particularly for small and medium-sized businesses.
How can the NRF help build or encourage stronger pathways for Australian developed innovation and research, and encourage additional private investment in priority areas?
• Supporting research and development: The NRF could provide funding and support for research
and development in the priority areas, which can help draw in private sector investment and
promote innovation
• Infrastructure development: The NRF could provide funding for the creation of infrastructure that
is essential for the expansion of priority industries like advanced manufacturing and renewable
energy
• Offering financial incentives: To encourage private sector investment in priority areas, the NRF
could provide financial incentives like grants, tax credits, and loans
• Creating partnerships: The NRF could collaborate with the private sector to create partnerships
and alliances that can support the expansion and development of priority industries and promote
private investment
• Fostering economic growth: By funding initiatives that generate employment, boost economic
activity, and foster innovation, the NRF could foster economic growth in priority areas
• Commercialisation support: The NRF may provide commercialization support for new
technologies and innovations created in priority areas, which can aid in luring private investment.
How could the NRF consider Government policy priorities in performing its investment function?
• Investments that are in line with government policy include renewable energy, advanced
manufacturing, and technological advancement. The NRF could make sure that its investments
are in line with these and other government policy priorities
• Working with government organisations: The NRF could work with the appropriate government
organisations to make sure that its investments support and enhance government initiatives and
policies
• Monitoring shifts in government priorities: The NRF could keep an eye out for shifts in government
priorities and adjust its investments accordingly
• Consultation on policy: To better understand government policy priorities and make sure that its
investments support these priorities, the NRF could consult with relevant government agencies
and stakeholders
• To make sure that its investments support the priorities of the government, the NRF could
incorporate policy evaluation criteria into its decision-making process.
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Returns, financial instruments and working with other investors
What factors and considerations should inform the portfolio rate of return for the NRF?
The risk profile of the group of investments needs to be considered when setting an appropriate margin above the bond rate. A lower margin will contribute to crowd-in and support more projects, but this needs to be balanced with the risk profile of the investments and ensuring investments are being made with an expectation of them being repaid. The rate of return should be medium to long term focused.
What factors and considerations should inform the setting of acceptable but not excessive level of risk? Should the acceptable level of risk differ between priority areas?
Investments need to be viewed in the context of a portfolio of assets that in aggregate have an acceptable but not excessive level of risk. There will be a varying level of risk between priority areas, and it would therefore be appropriate for the risk criteria to be specific to each priority area and the quantum of investment.
What types of concessional offerings would be preferred if these were offered (for example, lower interest rates) and why?
Concessions on interest rates, debt tenor, subordinated facilities and guarantees are debt-like mechanisms that would support investment. In addition, non-debt at risk equity to cover un-allocated risk of a new industry would be beneficial. These offerings would support the overarching commercial viability of the project and allow crowd-in from other debt and equity investors.
What factors drive or constrain co-investment (for example, by industry, financial sector or domestic or offshore investors) and how should these be taken into account?
The risk allocation of each investment is fundamental for assessing co-investment either through debt or equity investment. Ultimately the risk allocation will drive the returns required by co-investors. In nascent industries including those that the NRF will support their can be a mismatch between risk and return, with government support key to bridging this gap. The technical and commercial feasibility of the project and the competitive environment of businesses seeking to deploy the technology will be key factors in the risk/return analysis for co-investment.
What are the mechanisms and types of finance which will best attract co-investment from the private sector? How can the NRF best crowd-in investment?
As discussed above, concessional debt and equity-like funding from the NRF will assist in attracting co-investment from the private sector. The NRF can support crowd-in by taking on a higher risk profile relative to return expectations to ensure the overall commercial viability of the investment is maintained.
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Complementary reforms
What are the non-financial barriers preventing businesses from making the most of opportunities for value-add, growth and diversification in the priority areas?
• Lack of willingness from Universities and Research Support Programs (RSP) to negotiate contract
and partnership arrangements with regards to intellectual property (IP) ownership. Universities
and RSPs have limited ability commercialise but want to retain IP.
• The lack of a patent box for manufacturing initiatives.
• Lack of IP in Australia in the areas of battery, fuel cell, electrification, wind technologies.
• Lacking advanced manufacturing battery, fuel cell expertise. There is a lack of battery technology
and expertise available in Australia based (Future Charge Cooperative Research Centre [CRC]
Reports).
• Lack of readily available land zoned/flagged for large manufacturing operations by local
councils/state government
• Lack of expertise in Australia. There is no readily available pool of professionals that a company
could tap into to fill the required job positions
o Tertiary education targets are needed to fill the gap
o Skilled migration policies needed to facilitate filing the gap in the meantime
• Australia’s low Economic Complexity Index results in supply chain issues?
• The scale of policy measures and funding by other governments.
• Global competition, and
• The remoteness of Australia to consumer markets
Are there non-financial mechanisms that could support priority areas and the objectives of the
NRF? How could the NRF work alongside other complementary reforms to best deliver on the
Government’s policy priorities?
• Rapid deployment of scaled renewables would deliver economy-wide benefits. Furthermore,
additional renewable energy generation delivers benefits independent of the success of the green
hydrogen industry as renewable generation brought forward by hydrogen developers can be
redeployed to other consumers, with a positive impact on electricity pricing.
• Federal and State Governments have already developed a sophisticated response to Australia’s
renewable energy deployment challenges. These include the National Energy Transformation
Partnership and the Rewiring the Nation fund, which sets out a series of priorities including
accelerating transmission projects and addressing enabling environment issues, such as supply
chain constraints.
• Fortescue recognises that renewable energy projects are already commercially viable. However,
renewable energy deployment and cost is also affected by lengthy approval processes and
component prices. This has resulted in a significant mismatch between supply and demand which
drives renewable prices higher, in turn impacting input costs for green hydrogen production. It is
this logic which underpins the renewable energy production tax credit in the US IRA which
recognises that low-cost renewables are an enabler of manufacturing across the economy.
• Based on Fortescue’s experience and expectations of Australia’s renewable energy market, high
prices are unlikely to abate in the near term without further government intervention.
• Fortescue recommends that National Energy Ministers consider additional measures to
accelerate approvals, measures to lower installed costs, and to ensure community benefit
and participation.
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To what extent are other levers required to support the objectives of the NRF (for example, skills, trade, supply chains)? How does the NRF, with other private and Government settings, drive the right ecosystems for sustainable industry growth?
• There are two drivers of the green hydrogen commercialisation gap: technology immaturity
and the cost of carbon. Separate actions can address each of these and restore Australia’s
hydrogen advantage, delivering significant and persistent first mover advantages for Australian
regions and positive economic spillovers.
• Support for early-stage industries is a traditional role for governments and has a long history in
Australia:
1. Estimates from the Australia Institute found that State Governments supported the resources
sector with $17.6 billion between 2009 and 2014.1 Similar estimates for the federal government
suggest $4 billion in support was provided to the mining industry in 2015, with half of this
contributed by the fuel tax credit.2
2. Estimates from the OECD suggest that Australia provided $10.6 billion in fossil fuel subsidies
in 2020.3
3. Estimates from the development of Western Australia’s North West Shelf LNG industry show
the Western Australia and Commonwealth governments providing at least $3.6 billion for the
development of gas fields through infrastructure development and royalty rate concessions;
before consideration of sizable investment tax concessions.4 In 2016 the Australian National
Audit Office estimated North West Shelf gas producers claimed $5 billion in tax deductions in
the 18 months to December 2015.5
• Fortescue recommends early state support for green hydrogen would be most efficiently
delivered as a green hydrogen production credit
• Such a credit would need to consider the magnitude of support; timing and duration of support;
and eligibility criteria. These factors would need to deliver a scale of production necessary to
unlock cost-competitive production and a regional productivity advantage that enables Australian
producers to retain a competitive advantage when support is ultimately removed.
• Based on preliminary modelling undertaken by Deloitte Access Economics, a production credit
would significantly enhance Australia’s ability to capture first mover advantages in the Asian
hydrogen market. A production credit is a preferred support instrument for the hydrogen industry
for three reasons:
1. It is lower risk than a capital grants-based approach because the credit is dependent on actual
hydrogen production, rather than construction of a project which may run at variable capacity
depending on prevailing economic conditions.
2. Preliminary modelling suggests a production credit is more efficient at boosting Australian
green hydrogen exports relative to investment tax credits or capital grants.
3. It is lower cost and simpler for government to implement and industry to engage in.
1
Peel, M., Campbell, R., Denniss, R. (2014), “Mining the age of entitlement: State government assistance to the minerals and fossil fuels sector”, Australia Institute
2
Australia Institute Brief (2016) “Mining subsidies vs public services”
3
OECD (2021) Fossil Fuel Support – AUS, https://stats.oecd.org/Index.aspx?DataSetCode=FFS_AUS
4
Gardner, R (1989), The North West Shelf Natural Gas Project: An Analysis of Critical Events
5
Australian National Audit Office (2016) Collection of North West Shelf Royalty Revenue
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• Fortescue recognises that support measures for green hydrogen production would need to
balance the upfront cost to government with benefits to the economy as a whole. These are likely
to include regional economic development and job creation, development of a new economic
sector and associated taxation revenue, and acceleration of domestic decarbonisation with
benefits for greener trade. Further analysis will be required to determine these costs and benefits.
• However, realising a benefit for Australia’s manufacturing industries and supporting further
downstream manufacturing opportunities such as green steel will also require government to
tackle misaligned decarbonisation incentives in hard to abate sectors.
• Fortescue recommends factoring in the trade-offs between accelerating the adoption of
low carbon technologies and demand for carbon offsets into a revised Safeguard
Mechanism.
Conclusion
Fortescue is moving at speed to transition into a global green metals, minerals, energy and technology company, capable of delivering green iron ore as well as the minerals, knowledge and technology critical to the energy transition. We appreciate the Taskforce in considering our submission which we believe can help the NRF to deliver on its purpose and take advantage of the enormous economic growth potential a green hydrogen value chain can bring to Australia.
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