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The Australian Hydrogen Council (AHC) is extremely supportive of the Australian Government’s policy developments in support of the hydrogen industry and the energy transition as a whole. We now urge the government to consider further initiatives in this Budget to fill some of the remaining commercial and policy gaps, focusing on deployment.
The AHC is the peak body for the hydrogen industry and our membership includes companies from across the hydrogen value chain. Our members are at the forefront of Australia’s hydrogen industry, developing the technology, skills and partnerships necessary to ensure that hydrogen and its derivatives (such as ammonia and methanol) play a meaningful role in decarbonising Australian industry.
The upcoming year contains pivotal local, regional and international climate policy opportunities for the Australian Government, including the Safeguard Mechanism Review (and possible introduction of a carbon border adjustment), the vote on the International Maritime Organization’s Net Zero Framework, and Australia’s role as lead negotiator at COP31. This is an ideal juncture to adjust and fine-tune our policy environment and communicate Australia’s role and leadership in the energy transition.
The current policy environment in Australia is increasingly favourable for hydrogen and decarbonisation. However, we are not seeing the pace of deployment that would be expected. This has been caused by a variety of reasons, some of which are addressable by the Australian Government. For the purpose of this pre-budget submission, the AHC would like to focus on a selection of obstacles to emerging industries (such as hydrogen and its derivatives). This will cover:
- Efficient government policy, where the Australian Government needs to deliver reliable access to hydrogen demand, energy inputs, common user infrastructure, and reform inefficient policy.
- The investment ecosystem, which requires government action to prioritise and address barriers to Australian Government allocated public funding being deployed in industry.
Recommendation 1: Policy to kickstart key markets
Consistent with its FMIA and NHS agenda, the Australian Government should prioritise and fund the following demand side policies for the 2026-27 Budget:
• Public procurement of green metals; at least an initial assessment of options and mapping major opportunities against timelines for construction, facility development, and procurement.
• A consumption target for low to zero carbon ammonia for miners to use in explosives.
• A mandate or demand mechanism for low carbon liquid fuels, especially SAF (including blends), that is tailored to Australia’s market and national security interests.
Recommendation 2: Support the delivery of common user industrial infrastructure.
To avoid each proponent needing to self-fund and duplicate infrastructure, and to avoid excessive risk for first movers, the Australian Government could:
• Establish special-purpose vehicles (SPVs) at the precinct to plan and own shared transmission, water and port assets, under published access and tariff rules.
• Pre-plan and co-develop minimum shared infrastructure (berths, desalination, pipelines) to serve both new industries and existing users.
• Support precinct CfDs/production credits targeted to high-temperature/hard-to-abate uses (green ammonia feedstock; DRI). Pair with government offtake or guarantees where possible.
• For each anchor facility, negotiate facility-specific decarbonisation compacts tying public infrastructure milestones (water/port/transmission) to private FIDs (calciner retrofits, feedstock switches, DRI pilots). This can also be supported with financing instruments such as mezzanine finance or subordinated equity to bridge the gap between government infrastructure delivery and private FID.
• Work to lead nationally harmonised ammonia/methanol bunkering codes, and pre-permit generic safety designs (berths, bunkering pipelines) to allow proponents to focus approvals on their plants, not the whole chain.
Recommendation 3: Review existing funding that is inconsistent with decarbonisation.
Audit and reform any conflicting policies that could undermine decarbonisation progress and public funds. This could start with modifying the fuel tax credit to exclude very large volumes of on-land diesel use, to reflect modern decarbonisation needs and encourage private investment.
Recommendation 4: Reform the investment ecosystem to maximise the impact of public funding.
The Australian Government should conduct a targeted audit of the clean technologies and renewable energy programs and specialist investment vehicles to identify inefficiencies and duplication, and opportunities for a wrap around, case management approach that stewards applicants through the funding ecosystem.
Recommendation 5: Ensure compliance with the Community Benefit Principles is not unreasonably complex.
To maximise the participation in FMIA industries, Treasury should ensure that the design of the Community Benefits Principles is not unnecessarily complicated or costly to comply with.
Designing efficient policy architecture
In order to maximise the impact of public funds, the Future Made in Australia (FMIA) agenda will need to address gaps in the policy architecture. For the hydrogen industry, this is most notably in access to demand, energy inputs, and common user infrastructure. This federal budget is also an opportunity to review ongoing funding that no longer aligns with the Australian Government’s strategic decarbonisation objectives.
There is limited certainty without demand drivers
IRENA has referred to the ‘green hydrogen deadlock’ where potential off-takers (consumers) and suppliers are unable to move forward without further information – such as about prices and commitments – and potential suppliers are hesitant to build and deploy without firm offtake agreements. [1] This seems an apt characterisation of much of the hydrogen conversation these days. First-of-a-kind projects are uncertain and risky, with a strong need for information for both supply and demand sides.
It is unhelpful that many places, including Australia, lack meaningful (economy-wide) carbon pricing. This is the key solution for a society that needs to transition and runs a market economy; price is the signal of value for all things. However, cost of living pressures make regulatory ‘sticks’ like broad carbon pricing unattractive politically.
To date, Australian Government support for the hydrogen industry has been in the form of project-specific grants and concessions, and has been weighted to the supply side. This appeared logical in the context of a pre-commercial – that is, pre-market – environment with a dynamic and flexible view on potential uses, but it was perhaps too optimistic given demand pressures are not present.
The HPTI takes a different approach; while it is supply focussed, it is market wide. Now we need to pair this with market demand signals and infrastructure measures, and support early users to see their path forward in the meantime.
Demand side measures are the missing pieces for the industry, and especially when we have not internalised the cost of carbon in the economy, and fossil fuel prices remain the ones to beat. In the absence of an external force, such as a mandate to buy greener products, it is difficult for even the most climate-aware business to always choose a less known technology or more expensive product. Boards need to demonstrate their fiduciary duty to maximise profits has been met, within the law, and business decision-making is often risk averse.
It is therefore in the public interest for governments to depend less on soft ESG measures to see corporate change and to instead mandate the outcomes they want to see, or at least phased pathways to get there.
Using the priority areas of the FMIA and the NHS, the 2026-27 Budget should include measures for demand side market mechanisms for:
- Green metals. Last year saw the announcement of a variety of incentives in the green metals space, largely addressing the innovation and production side, such as under the Net Zero Fund, Innovation Fund, Green Iron Investment Fund and Green Aluminium Production Credit. However, as the green metals industries begin to form, demand side support such as public procurement, will vastly improve the business case for decarbonising iron and alumina production. These are fundamental measures to pave the way for a new and lucrative export market for Australia.
In 2024, Climate Energy Finance (CEF) undertook extensive analysis of the green iron and steel opportunity for Australia, recommending that, among other things, there should be a clear focus on demand-side policies and incentives including the fundamental measures above.[2] CEF also proposed a new Trilateral Clean Commodities Trading Company (Australia, South Korea and Japan), as well as an Australasian Green Iron Corporation JV between Australia and key trade partners. - Ammonia. Demand mechanisms could cover all uses of ammonia, or only some uses. For example, we note that IEEFA has suggested that mining companies could shift to green explosives (which are made with ammonia) with the right incentives.[3] With miners consuming about half of Australia’s ammonia through explosives, they could be a driver for cleaner ammonia (and hydrogen as the input to ammonia), at minimal incremental cost: in 2024, IEEFA found that a switch to 20 per cent green ammonia by 2025 would have increased mining operating costs by less than 0.1 per cent, and a full switch to 100 per cent green ammonia would increase mining operating costs by up to 0.4 per cent.
This change is likely to require a government mandate, and we support further Australian Government consideration of the possibility, noting it would have little to no effect on the 2026-27 Budget. - Low carbon liquid fuels. We note the Cleaner Fuels Program is proposed as a central incentive for low carbon liquid fuels, which only finalised consultation in December 2025. However, this Program does not currently consider a demand side mechanism.[4]
For long-term, demand side supports, our primary focus is on aviation and maritime.
For maritime, the primary target for a demand mechanism is the International Maritime Organization’s (IMO) Net Zero Framework. The AHC once again urges the Australian Government to support, and vote in favour of, the adoption of this policy at the next meeting of the IMO’s Marine Environment Protection Committee (MEPC) in 2026. This would deliver local, regional and international decarbonisation benefits, as well as reliable, ongoing demand for low carbon maritime fuels.
The best approach for aviation would be mandates for future long-term use of SAF (such as in the EU), and incentives to help producers and users close the commercial gap. Incentives are best targeted where first-of-a-kind projects carry higher risk and cost, and can reduce as technology advances and efficiency improvements are made.
A mandate will need a grace period to enable capability so that Australian producers are not disadvantaged while industry scales up; we note that even using biogenic feedstock for SAF at scale requires new refineries to be developed. In the meantime, the Australian Government should work closely with international standard-setting entities to develop and expedite international standards.
We also recommend further exploration of government procurement policy targets to stimulate more local SAF production. Given its consumption of aviation fuels, the Australian Department of Defence would seem an obvious lead, as well as government travel.
Recommendation 1: Policy to kickstart key markets.
Consistent with its FMIA and NHS agenda, the Australian Government should prioritise and fund the following demand side policies for the 2026-27 Budget:
• Public procurement of green metals; at least an initial assessment of options and mapping major opportunities against timelines for construction, facility development, and procurement.
• A consumption target for low to zero carbon ammonia for miners to use in explosives.
• A mandate or demand mechanism for low carbon liquid fuels, especially SAF (including blends), that is tailored to Australia’s market and national security interests.
Australia must resolve obstacles to reliable access to energy inputs
For an Australian hydrogen industry to be established, we need reliable access to electricity and gas, both to service a new and existing industry base.
In the decarbonisation context, hydrogen allows sectors that cannot electrify to reduce emissions and participate in the transition: ammonia and fertiliser production, ironmaking, and low carbon fuels.
However, the certainty and volume of demand for hydrogen is somewhat dependent on which existing industries remain in Australia. Much of the divestment of nationally significant facilities over the past few years has been in part due to the high cost of energy inputs, notably gas. We recognise that retaining industries has been a major focus of the Australian Government in 2025, including the establishment of the Net Zero Fund and Green Iron Investment Fund.
Gas prices and access to gas are negatively affecting Australia’s heavy industry, threatening the viability of feedstock-reliant domestic manufacturers and are indirectly impeding Australia’s nascent hydrogen industry.
From a pro-hydrogen economic competitiveness perspective, higher natural gas prices would usually be viewed favourably because this closes the competitive gap with hydrogen. However, by driving future hydrogen anchor industries away, very high gas prices will instead have strong chilling effects on Australia’s hydrogen prospects.
It is, therefore, welcoming to see the recent acceptance of the Gas Market Review recommendations, including the development of a gas reservation policy. This will be a key mechanism in addressing these concerns; we look forward to the consultation and swift implementation of this strategy.
Similarly, electricity prices have also been a significant roadblock to progress. In 2019-2020 the common understanding was that electricity would need to be around AU$20MWh to get the cost of hydrogen production low enough to develop commercial renewable hydrogen projects. At the time, electricity prices were closer to AU$40MWh, with many assuming they would fall to the right level in the coming years.
However, with COVID affecting supply chains, the war in Ukraine affecting gas prices, and with pressure on renewables from coal generation plant retiring, we have seen electricity prices go the wrong way, with the gap to $20MWh increasing two to three times greater. And the inflationary pressures that affected renewable projects have similarly blown out construction costs for hydrogen projects.
We raised these arguments in our response to the 2025-26 pre-budget submission and reiterate them here because the hydrogen industry (and the decarbonisation of downstream products) will continue to be significantly hindered if the environment of expensive inputs is not adequately addressed. We endorse the Australian Government’s steps to date (including to develop renewables, transmission infrastructure, and a gas reservation policy) and advocate for the ongoing attention to this challenge.
Common user industrial infrastructure will reduce inefficiency and avoidable costs
Industrial transformation cannot occur without reliable access to power, water, port, and transport networks. The infrastructure choices made in this decade will determine whether Australia simply hosts a series of disconnected demonstration projects or builds the backbone for a globally competitive manufacturing position.
When governments signal big ambitions but leave enabling infrastructure to be ‘market-led’ developers respond rationally but inefficiently: hoarding land and berths to hold a place, lodging connection requests they may never use, and crowding out projects that are genuinely ready.
We note a consultant for the CEFC recently highlighted the value of common user transmission infrastructure, finding that company-by-company private lines risk $30 billion in avoidable cost and land impacts over 25 years compared to a coordinated network.[5]
For example, the Kwinana Industries Council (KIC) has provided clear advocacy on the needs of the industry at Kwinana, highlighting lagging investment in common user infrastructure that is “contributing to significant delays, rising operational costs, and reduced efficiency across industry”.[6] This is said to “limit the region’s ability to compete globally and respond effectively to emerging economic opportunities”. KIC recommends that the state and federal governments should develop a coordinated infrastructure investment strategy that identifies and prioritises projects that align with industry needs and national growth objectives and ensures timely delivery of essential infrastructure. There is also a need to plan future infrastructure investment.[7] This philosophy aligns with our position.
This is why the intended infrastructure must be viewed not as hydrogen infrastructure, but as industrial infrastructure: electricity, water, port access, digital systems and transport systems capable of supporting a portfolio of industries and products over time. By planning these assets as common user from the outset, we can ensure that today’s investments in decarbonisation directly reinforce the domestic and export industries that underpin Australia’s prosperity.
The AHC has conducted an in-depth geopolitical and economic overview of Western Australia’s (and Australia’s) decarbonisation opportunity, including the common user infrastructure roadmap to secure this opportunity.[8] This resource could be used to support the design and implementation of common user infrastructure. Some of the key recommendations have been included below.
Recommendation 2: Support the delivery of common user industrial infrastructure
To avoid each proponent needing to self-fund and duplicate infrastructure, and to avoid excessive risk for first movers, the Australian Government could:
• Establish special-purpose vehicles (SPVs) at the precinct level to plan and own shared transmission, water and port assets under published access and tariff rules.
• Pre-plan and co-develop minimum shared infrastructure (berths, desalination, pipelines) to serve both new industries and existing users.
• Support precinct CfDs/production credits targeted to high-temperature/hard-to-abate uses (green ammonia feedstock; DRI). Pair with government offtake or guarantees where possible.
• For each anchor facility, negotiate facility-specific decarbonisation compacts tying public infrastructure milestones (water/port/transmission) to private FIDs (calciner retrofits, feedstock switches, DRI pilots). This can also be supported with financing instruments such as mezzanine finance or subordinated equity to bridge the gap between government infrastructure delivery and private FID.
• Work to lead nationally harmonised ammonia/methanol bunkering codes, and pre-permit generic safety designs (berths, bunkering pipelines) to allow proponents to focus approvals on their plants, not the whole chain.
Reform inconsistent policies that undermine public funds
As the Australian Government develops decarbonisation incentives, it is paramount to reform any pre-existing rebates that would limit the effectiveness of the public funds.
The coverage of the fuel tax credit scheme is a salient example, and has been in the public discussion over the past two years, most notably addressed by the Climate Change Authority,[9] Grattan Institute[10] and Climate Energy Finance.[11] It has been noted that for some industries, this credit effectively subsidises diesel use, which widens the cost gap with alternative fuels and thus disincentivises industry investment in the transition.[12] [13] This is particularly the case for very large on-land consumers of diesel, such as miners, who can invest in alternatives and who can lead the way for Australia. Reform of the fuel tax credit can support retaining the full credit for entities in agriculture, tourism, maritime and freight, while making available significant funds for decarbonisation.[14]
Recommendation 3: Review existing funding that is inconsistent with decarbonisation.
Audit and reform any conflicting policies that could undermine decarbonisation progress and public funds. This could start with modifying the fuel tax credit to exclude very large volumes of on-land diesel use, to reflect modern decarbonisation needs and encourage private investment.
Deploying allocated funding in industry
We have seen significant funding put towards the FMIA priority areas and are keen to ensure that this financial commitment is not undermined by inefficiencies, bottlenecks or overcomplication. It is in the interest of the federal government and Australian industries that this capital is swiftly deployed to reinforce Australia’s ambitions.
Addressing Australia’s inefficient investment ecosystem
For some time now we have observed that the complexity and uncertainty of the investment environment and the overall ecosystem (multiple states, regulatory differences, permitting within states) is making hydrogen project proponents’ decisions unnecessarily difficult.[15]
There are numerous funding programs and specialist investment vehicles (SIVs) for clean technologies and renewable energy in Australia. Each of these funding sources has unique objectives which often overlap. The funds do not, however, coordinate or hand over eligible projects between funding programs or between assessment stages. This translates to the same project or technology often needing to start again with each party, going through multiple lengthy application processes which consumes significant resources. For smaller organisations with limited resources, this hurdle can be enough to not apply, potentially restricting the speed to market.
This is particularly concerning when we recognise that the SIVs have not deployed capital at the pace required, or with the necessary coherence. Application processes are reportedly needlessly complex and slow, the risk appetite of the SIVs is too limited, and funds are spread across fragmented programs that do not line up with the needs of large-scale transformation. It is worth noting that, according to publicly available information, not one of the federal level or state level investment vehicles has met its investment targets. The result is that industry struggles to reach final investment decision on critical projects even though billions remain notionally allocated on government balance sheets.
The AHC supports many of the themes and actions to reform the SIVs that the Chair of the Net Zero Economy Authority highlighted in the organisation’s submission to the Treasurer and the Minister for Finance on the opportunities to support the Government’s productivity agenda in August 2025.[16] Key themes in the submission include the need to optimise finance, streamline the funding ecosystem, improve collaboration, and reform regulatory settings.
Under the FMIA industry policy, the Australian Government has committed to building sovereign capability in hydrogen, green iron, low-carbon fuels and other clean industries. The array of new funding opportunities under the FMIA build a strong value offering but only if the hurdles to participate aren’t unnecessarily high and it can be demonstrated that Australian Government institutions will deliver.
To enable an efficient funding system, we must accept additional risk, shorten timelines, deploy instruments proven internationally, and coordinate across the full ecosystem. Guarantees, procurement, targeted subsidies and declining financial support as technology moves up the TRL-based support have worked elsewhere and should be adapted here. Above all, priority designations must mean more than symbolic statements; they must guarantee real, coordinated action.
Similarly, the Australian Government should work to develop a ‘touch once, use many times’ model that guides applicants through the complex tapestry of funding opportunities. The model would wrap around each technology or project, big or small, and provide a case management approach that stewards businesses through (and between) eligible programs, so as to safeguard and incubate Australian innovation.
Without careful reform, Australia risks falling behind competitors such as those in the Middle East, which are moving faster to close investment gaps.
Recommendation 4: Reform the investment ecosystem to maximise the impact of public funding.
The Australian Government should conduct a targeted audit of the clean technologies and renewable energy programs and specialist investment vehicles to identify inefficiencies and duplication, and opportunities for a wrap around, case management approach that stewards applicants through the funding ecosystem.
Striking the right balance for the Community Benefit Principles
The Community Benefit Principles (CBPs) add to this complexity in applying for and securing government funding.
AHC supports the CBPs as a legitimate expression of the Australian Government’s right to expect public benefit where significant public funding is provided to private proponents. In an emerging industry context, CBPs can also play a constructive role by making proponents think early and systematically about workforce, community, First Nations engagement, domestic capability and integrity.
However, the industry has identified some concerns in the current Australian Government proposal for how the CBPs will operate in practice. This largely covers the publication risk, discretionary uncertainties, duplication in processes, the potential administrative burden, and the possibility of uniform targets that ignore location and project contexts. We address this in greater detail in our submission to the CBPs consultation,[17] however, the point to be raised here is that if there is insufficient clarity, substantial complexity, undue cost or drain on resources, then the Australian Government may see some organisations choose to not participate. While there is industry appetite to support and share benefits with local communities, this formalised process would need to be reasonable.
The FMIA funding programs have been designed to accelerate the pace and certainty of Australia’s decarbonisation and sovereign capabilities; this strategic ambition should not be undermined by unnecessary bureaucracy.
Recommendation 5: Ensure compliance with the Community Benefit Principles is not unreasonably complex.
To maximise the participation in FMIA industries, Treasury should ensure that the design of the Community Benefits Principles is not unnecessarily complicated or costly to comply with.
[1] IRENA (2024) Green hydrogen strategy: A guide to design, International Renewable Energy Agency, Abu Dhabi, see https://www.irena.org/Publications/2024/Jul/Green-hydrogen-strategy-A-guide-to-design.
[2] Pollard and Buckley (2024) Green Metal Statecraft: Forging Australia’s Green Iron Industry, Climate Energy Finance, 15 November, see https://climateenergyfinance.org/wp-content/uploads/2024/11/CEF_Green-Metal-Statecraft_FINAL.pdf.
[3] Butler and Denis-Ryan (2024) How mining could ignite Australia’s green hydrogen boom: The financial case for shifting to green explosives, Institute for Energy Economics and Financial Analysis, February, see https://ieefa.org/sites/default/files/2024-02/How%20mining%20could%20ignite%20Australia%27s%20green%20hydrogen%20boom_Feb24_0.pdf.
[4] See the AHC response here: AHC (2025) Cleaner Fuels Program – Policy Design and Engagement Paper, submission, December, https://h2council.com.au/wp-content/uploads/2025/12/251219-Cleaner-Fuels-Program-submission.pdf.
[5] Marsden Jacob Associates (2025) Common user transmission and decarbonising Pilbara energy demand: A report for the Clean Energy Finance Corporation, September, https://www.cefc.com.au/document?file=/media/jwlnajzx/common-user-transmission-and-decarbonising-pilbara-energy-demand.pdf.
[6] Kwinana Industries Council (2025) Kwinana Industries Council Submission to the Economic Round Table, July, https://kic.org.au/wp-content/uploads/2025/07/KIC-Submission-to-the-Economic-Reform-Roundtable2025-1.pdf, p. 5.
[7] Ibid., p. 10.
[8] For more in depth discussion of this topic, see: AHC (2025) Inquiry into the role of Western Australia in the global effort on decarbonisation, submission, October, https://h2council.com.au/wp-content/uploads/2025/10/251024-AHC-submission-to-WA-inquiry.pdf.
[9] Climate Change Authority (2024) Sector Pathways Review, Commonwealth Government, https://www.climatechangeauthority.gov.au/sites/default/files/documents/2024-09/2024SectorPathwaysReview.pdf.
[10] Terrill, M., Burfurd, I. & Bradshaw, N. (2023) Fuelling budget repair: How to reform fuel taxes for business, Grattan Institute, February, https://grattan.edu.au/wp-content/uploads/2023/02/Fuelling-budget-repair-Grattan-report.pdf.
[11] Pollard, M. (2024) Reforming the Fuel Tax Credit Scheme is not ‘economy-wrecking’, but will align economic incentives with Australia’s climate ambition and accelerate our pathway to a Future Made in Australia,Climate Energy Finance, 29 August, https://climateenergyfinance.org/wp-content/uploads/2024/08/Fuel-Tax-Credit-Scheme-Report-Response.pdf ; Pollard, M. & Buckley, T. (2025) Transition Tax Incentive: Reforming Fuel Tax Credits into a Decarbonisation Tailwind, Climate Energy Finance, 20 August, https://climateenergyfinance.org/wp-content/uploads/2025/08/CEF_Transition-Tax-Incentive-Report-FINAL_20August2025.pdf.
[12] More information can be found here: Terrill, M., Burfurd, I. & Bradshaw, N. (2023) Fuelling budget repair: How to reform fuel taxes for business, Grattan Institute, February, https://grattan.edu.au/wp-content/uploads/2023/02/Fuelling-budget-repair-Grattan-report.pdf.
[13] Climate Change Authority (2024) Sector Pathways Review, Commonwealth Government, https://www.climatechangeauthority.gov.au/sites/default/files/documents/2024-09/2024SectorPathwaysReview.pdf.
[14] See Pollard, M. (2024) Reforming the Fuel Tax Credit Scheme is not ‘economy-wrecking’, but will align economic incentives with Australia’s climate ambition and accelerate our pathway to a Future Made in Australia,Climate Energy Finance, 29 August, https://climateenergyfinance.org/wp-content/uploads/2024/08/Fuel-Tax-Credit-Scheme-Report-Response.pdf.
[15] For more in depth discussion of this topic, see: AHC (2025) Investing in cheaper, cleaner energy and the net zero transformation, submission, September, https://h2council.com.au/wp-content/uploads/2025/09/250923-PC-interim-report-AHC-submission.pdf and AHC (2025) Inquiry into the role of Western Australia in the global effort on decarbonisation, submission, October, https://h2council.com.au/wp-content/uploads/2025/10/251024-AHC-submission-to-WA-inquiry.pdf.
[16] Net Zero Economy Authority (2025) Submission to the Economic Reform Roundtable, July, https://www.finance.gov.au/sites/default/files/2025-08/DISR%20-%20Net%20Zero%20Economy%20Authority%20-%20Attachment%20A_Redacted_0.pdf.
[17] AHC (2026) AHC submissions, https://h2council.com.au/ahc-submissions/.