{"data":{"id":"sbm30fae123f979387347a55","short_id":7,"created":"2024-10-07T02:22:01.721Z","space_id":"spc30800006103164c8685a8","project_id":"prj307b31b5a31416c1c2800","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil30fae1181febc228c7183","zovp5q48":"Woodside Energy","upload-a-submiss_9dbd27":"fil30fae10d7f79a360f1f04"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil30fae1181febc228c7183":{"id":"fil30fae1181febc228c7183","bucket":"files-au-climate","remote_path":"climate-au/p/prj307b31b5a31416c1c2800/submission/spc30800006103164c8685a8/Letter_to_DCCEEW_Feedback_on_Proposed_Amendment_to_CFI_Rule_2015.15718d23.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj307b31b5a31416c1c2800/submission/spc30800006103164c8685a8/Letter_to_DCCEEW_Feedback_on_Proposed_Amendment_to_CFI_Rule_2015.15718d23.pdf","filename":"Letter to DCCEEW - Feedback on Proposed Amendment to CFI Rule 2015.pdf","transcribed":"Please direct all responses/queries to: Woodside Energy Ltd\nVanessa Tran\nE: vanessa.tran@woodside.com ACN 005 482 986\nMia Yellagonga\nRef: B761447P5768-993669707-3208\n11 Mount Street\nPerth WA 6000\nAustralia\nT: +61 8 9348 4000\n\nwww.woodside.com\n\n07 October 2024\n\nDepartment of Climate Change, Energy, the Environment and Water\nAttn: ACCU Scheme Policy and Legislation Team\n\nDear ACCU Scheme Policy and Legislation Team,\n\nFEEDBACK ON PROPOSED AMENDMENT TO CARBON CREDITS (CARBON FARMING INITIATIVE)\nRULE 2015\n\nWoodside Energy (Woodside) welcomes the opportunity to provide feedback on the exposure draft of the proposed amendment to the Carbon Credits (Carbon Farming Initiative) Rule 2015 (2015 Rule).\n\nWe acknowledge that the proposed amendment is intended to address recommendation four of the\nIndependent Review of Australian Carbon Credit Units Final Report 2022 (Independent Review) to maximise transparency and data sharing, supporting greater public confidence in the Australian Carbon Credit Unit\nScheme (ACCU Scheme).\n\nWoodside supports the proposed recommendations in the exposure draft as a step to increasing transparency.\nAs outlined in our earlier submission, we are of the view that further disclosure of information is necessary to maximise transparency.\n\nIn line with the recommendation in the Independent Review to make data public by default, Woodside recommends the publication of project documents (including, but not limited to, the publication of registration applications, offset reports, and audit reports) redacted as required to protect individual privacy and commercial-in-confidence information.\n\nIn our view, the proposed disclosure of project documents is essential to supporting a more transparent ACCU\nScheme, as it may assist with the provision of information required for robust analysis of projects. Moreover, doing so would align with international best practice.\n\nWoodside’s feedback on the exposure draft is detailed below (Table 1). Woodside looks forward to continued engagement on the transparency-related changes and on the ACCU Scheme generally.\n\nYours sincerely\n\nJason Greenwald\nVice President Carbon Solutions\n\nAttached: Feedback on exposure draft\nTable 1: Feedback on exposure draft\n\nRecommendation/observation Suggested implementation\n\nRecommendation: The Independent Review called for Implementation of these changes could take the form of amendment to the governing legislation of the ACCU modifying the exposure draft to add a new section to Part\nScheme to the extent that “the default should be that data 12 of the 2015 Rule, which could set out the requirements be made public”. for the publication of project documents and exceptions to\nsuch publication.\nTo fully adopt this recommendation, Woodside is of the view that project documents (including, but not limited to, registration applications, offset reports, and audit reports) should be made public, with redaction as required to protect individual privacy and commercial-in-confidence information.\n\nPublishing project documents aligns with international best practice, enables greater industry self-regulation and allows for reviews by independent carbon credit ratings agencies, with an overall benefit of increased ACCU\nScheme integrity. These potential benefits could provide\nAustralia’s trading partners with greater confidence regarding the carbon credits used by Australian exporters for upstream emissions.\n\nObservation: The proposed changes add to the existing Subsection (1) of Section 93A of the 2015 Rule could refer requirements for the publication of information on entries to Section 168 of the Act.\nin the register in Section 168 of the Carbon Credits\n(Carbon Farming Initiative) Act 2011 (the Act). However, the current exposure draft appears to incorrectly refer to\nSection 166A of the Act.","size":152404,"redacted":[],"meta":{"name":"Letter_to_DCCEEW_Feedback_on_Proposed_Amendment_to_CFI_Rule_2015.15718d23.pdf","local_path":"files/xNG-ebDDT4_vD0yFphm9_7pU.pdf"},"config":{}},"fil30fae10d7f79a360f1f04":{"id":"fil30fae10d7f79a360f1f04","bucket":"files-au-climate","remote_path":"climate-au/p/prj307b31b5a31416c1c2800/submission/spc30800006103164c8685a8/Letter_to_DCCEEW_Feedback_on_Proposed_Amendment_to_CFI_Rule_2015_signed.f13b6667.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj307b31b5a31416c1c2800/submission/spc30800006103164c8685a8/Letter_to_DCCEEW_Feedback_on_Proposed_Amendment_to_CFI_Rule_2015_signed.f13b6667.pdf","filename":"Letter to DCCEEW - Feedback on Proposed Amendment to CFI Rule 2015 - signed.pdf","transcribed":"Please direct all responses/queries to: Woodside Energy Ltd\nVanessa Tran\nE: vanessa.tran@woodside.com ACN 005 482 986\nMia Yellagonga\nRef: B761447P5768-993669707-3208\n11 Mount Street\nPerth WA 6000\nAustralia\nT: +61 8 9348 4000\n\nwww.woodside.com\n\n07 October 2024\n\nDepartment of Climate Change, Energy, the Environment and Water\nAttn: ACCU Scheme Policy and Legislation Team\n\nDear ACCU Scheme Policy and Legislation Team,\n\nFEEDBACK ON PROPOSED AMENDMENT TO CARBON CREDITS (CARBON FARMING INITIATIVE)\nRULE 2015\n\nWoodside Energy (Woodside) welcomes the opportunity to provide feedback on the exposure draft of the proposed amendment to the Carbon Credits (Carbon Farming Initiative) Rule 2015 (2015 Rule).\n\nWe acknowledge that the proposed amendment is intended to address recommendation four of the\nIndependent Review of Australian Carbon Credit Units Final Report 2022 (Independent Review) to maximise transparency and data sharing, supporting greater public confidence in the Australian Carbon Credit Unit\nScheme (ACCU Scheme).\n\nWoodside supports the proposed recommendations in the exposure draft as a step to increasing transparency.\nAs outlined in our earlier submission, we are of the view that further disclosure of information is necessary to maximise transparency.\n\nIn line with the recommendation in the Independent Review to make data public by default, Woodside recommends the publication of project documents (including, but not limited to, the publication of registration applications, offset reports, and audit reports) redacted as required to protect individual privacy and commercial-in-confidence information.\n\nIn our view, the proposed disclosure of project documents is essential to supporting a more transparent ACCU\nScheme, as it may assist with the provision of information required for robust analysis of projects. Moreover, doing so would align with international best practice.\n\nWoodside’s feedback on the exposure draft is detailed below (Table 1). Woodside looks forward to continued engagement on the transparency-related changes and on the ACCU Scheme generally.\n\nYours sincerely\n\nJason Greenwald (Oct 7, 2024 09:38 GMT+8)\nJason Greenwald\nVice President Carbon Solutions\n\nAttached: Feedback on exposure draft\nTable 1: Feedback on exposure draft\n\nRecommendation/observation Suggested implementation\n\nRecommendation: The Independent Review called for Implementation of these changes could take the form of amendment to the governing legislation of the ACCU modifying the exposure draft to add a new section to Part\nScheme to the extent that “the default should be that data 12 of the 2015 Rule, which could set out the requirements be made public”. for the publication of project documents and exceptions to\nsuch publication.\nTo fully adopt this recommendation, Woodside is of the view that project documents (including, but not limited to, registration applications, offset reports, and audit reports) should be made public, with redaction as required to protect individual privacy and commercial-in-confidence information.\n\nPublishing project documents aligns with international best practice, enables greater industry self-regulation and allows for reviews by independent carbon credit ratings agencies, with an overall benefit of increased ACCU\nScheme integrity. These potential benefits could provide\nAustralia’s trading partners with greater confidence regarding the carbon credits used by Australian exporters for upstream emissions.\n\nObservation: The proposed changes add to the existing Subsection (1) of Section 93A of the 2015 Rule could refer requirements for the publication of information on entries to Section 168 of the Act.\nin the register in Section 168 of the Carbon Credits\n(Carbon Farming Initiative) Act 2011 (the Act). However, the current exposure draft appears to incorrectly refer to\nSection 166A of the Act.\nLetter to DCCEEW - Feedback on Proposed\nAmendment to CFI Rule 2015\nFinal Audit Report 2024-10-07\n\nCreated: 2024-10-07\n\nBy: VANESSA TRAN (VANESSA.TRAN@woodside.com)\n\nStatus: Signed\n\nTransaction ID: CBJCHBCAABAAWHDuI5jMi9jn2If2bIduzSfeP7SkBIRb\n\n\"Letter to DCCEEW - Feedback on Proposed Amendment to CFI\nRule 2015\" History\nDocument created by VANESSA TRAN (VANESSA.TRAN@woodside.com)\n2024-10-07 - 1:35:49 AM GMT\n\nDocument emailed to Jason Greenwald (jason.greenwald@woodside.com) for signature\n2024-10-07 - 1:36:28 AM GMT\n\nEmail viewed by Jason Greenwald (jason.greenwald@woodside.com)\n2024-10-07 - 1:38:02 AM GMT\n\nDocument e-signed by Jason Greenwald (jason.greenwald@woodside.com)\nSignature Date: 2024-10-07 - 1:38:13 AM GMT - Time Source: server\n\nAgreement completed.\n2024-10-07 - 1:38:13 AM GMT","size":258569,"redacted":[],"meta":{"name":"Letter_to_DCCEEW_Feedback_on_Proposed_Amendment_to_CFI_Rule_2015_signed.f13b6667.pdf","local_path":"files/ltgqdu2FXgZdhC6_0-tTYd0e.pdf"},"config":{}}}}}