{"data":{"id":"sbm2f4bde1ae419cf416e89b","short_id":26,"created":"2024-07-15T09:42:22.692Z","space_id":"spc2e87423b0413d1fd9c277","project_id":"prj2e872b17b456d5488f86f","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil31d9f98fdb0ed6e76668c","zovp5q48":"Origin Energy","confirm-that-you_b979c5":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil31d9f98fdb0ed6e76668c":{"id":"fil31d9f98fdb0ed6e76668c","bucket":"files-au-climate","remote_path":"climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/26_Origin_Energy_Redacted.ab9e029a.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/26_Origin_Energy_Redacted.ab9e029a.pdf","filename":"26_Origin Energy_Redacted.pdf","transcribed":"15 July 2024\n\nDepartment of Climate Change, Energy, Environment and Water\n\nLodged online: https://consult.dcceew.gov.au\n\nDear Sir/Madam,\n\nResponse to Draft Reforestation by Environmental or Mallee Plantings method 2024\n\nOrigin Energy Limited (Origin) welcomes the opportunity to provide comments on the draft Reforestation by Environmental or Mallee Plantings method 2024.\n\nOrigin is a large Australian integrated energy company with activities in energy retailing, power generation, natural gas production and LNG export. Origin also has recent experience in exploring new product offerings and has focused on areas such as solar & storage, connected homes, electric vehicles (EVs) and future fuels including hydrogen.\n\nWe have broad experience with both domestic and international offsets including Australian Carbon\nCredit Units (ACCUs). Historically we have used these offsets to underpin green retail products for our customers. However, we also consider the role offsets may play in meeting our voluntary targets or any future mandated requirements to reduce emissions, such as under the Safeguard Mechanism.\n\nWe view offsets as having an important role to play in the future, especially for hard to abate sectors.\nOffsets can allow for deeper and more cost-efficient emissions reductions over the medium to longer term. However, we note that offsets are only one part of the mitigation strategy which should also focus on direct emission reductions where practical and cost effective.\n\nOrigin supports a robust and credible ACCU market and supports the reforms recommended by the independent Chubb Review. We are currently exploring a number of environmental planting opportunities and welcome the update to this method.\n\nCarbon projects, including environmental plantings (EP), in general are economically challenging and complex, relative to some other methods under the ACCU scheme. Overall, Origin is supportive of the increased flexibility that is being proposed in the updated method. This includes seed and fruit harvesting and the potential use of more climate change tolerant species to improve resilience.\nHowever, we have concerns with the increased commercial risk potentially introduced by unknowable future changes to the Full Carbon Accounting Model (FullCAM), and therefore ACCU yields over time.\nThis is explained further below.\n\nOverall, we believe the Government should be strongly encouraging further take-up of ACCU methods by reducing the regulatory burden and minimising financial risk and uncertainty to proponents, where practicable to maintain integrity.\n\nOur key points on this updated method include:\n\n• Flexibility - the additional flexibility contained in the draft method is welcomed.\n\n• Collection of seeds, fruits and nuts - it is unclear whether the 10% limit is a general\napproximation or based on scientific studies. It is considered likely that significantly higher\ncollection would still achieve environmental outcomes and seed bank establishment given the\n\nPage 1 of 2\n\nOrigin Energy Limited ABN 30 000 051 696 • Level 32, Tower 1, 100 Barangaroo Avenue, Barangaroo NSW 2000\nGPO Box 5376, Barangaroo NSW 2000 • Telephone (02) 8345 5000 • Facsimile (02) 9252 9244 • www.originenergy.com.au\nlong timeframes over which these projects are managed. Potentially this could be informed by\na suitably qualified ecologist, similar to the selection of suitable climate change resilient\nspecies. This may be important as it could improve economic support for further take-up of the\nEP methods, thereby improving Australia’s abatement outcomes.\n\n• FullCAM updates - the requirement to only use the FullCAM version in force at the end of\neach reporting period may create significant investment risk. Future changes are unknowable,\nor limited to assumptions at best. Therefore, ACCU yields and economic outcomes are also\nunknown. We understand that the Government wishes to make use of the most up to date\nscience when reporting Australia’s national inventory to the United Nations. However, the\naccuracy of rules in the EP method should be balanced with the need to promote the use of\nthat method and stimulate investment.\n\nWe suggest that a compromise be struck which looks to incorporate updates to the FullCAM\nversion over time in the new EP method but limits the downside to investors for a minimum\nperiod. For example, for the first ten years of a project, any updates to the FullCAM can only\nresult in a reduction in overall ACCU yields by at most 5%. This will provide an abatement\n‘floor’ by which proponents can make an investment decision, with the potential for upside, but\nonly if and when it is supported by improved science.\n\n• Canopy cover - the Paris Agreement expanded the Kyoto Protocol rules for accounting\ncarbon abatement actions from forest vegetation types, by removing strict minimum thresholds\nof canopy cover and vegetation height that previously limited where land management\nabatement could be counted in national greenhouse gas accounts. It appears that this has not\nbeen considered and included in the revised EP Method.\n\nThe inclusion of sub-canopy as eligible vegetation within the revised Method has the potential\nto drive significantly greater abatement outcomes and ACCU yields. This may also lower the\neconomic barriers to investing in EP projects resulting in better abatement outcomes.\n\nIt is understood that ‘sub-canopy’ (forest <2 meters tall) is being considered as part of the\nproposed draft Integrated Farm and Land Management Method (IFLM). It is therefore\nconsidered important that this is also accordingly included in the EP method for consistency.\n\nIf you wish to discuss any aspect of this submission further, please contact Matthew Kaspura at\n.\n\nYours sincerely,\n\nMatthew Kaspura\nSenior Manager Green and Future Energy Policy\nOrigin Energy Limited\n\nPage 2 of 2","size":114032,"redacted":[],"meta":{"name":"26_Origin_Energy_Redacted.ab9e029a.pdf","local_path":"files/Ponk-pMSz23IseAL0RSdDGJp.pdf"},"config":{}}}}}