{"data":{"id":"sbm326dbfa572b4820c9d474","short_id":15,"created":"2024-12-18T02:44:33.778Z","space_id":"spc30800006103164c8685a8","project_id":"prj307b31b5a31416c1c2800","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"GreenCollar","upload-a-submiss_9dbd27":"fil326dbf9bfa5573523c673"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil326dbf9bfa5573523c673":{"id":"fil326dbf9bfa5573523c673","bucket":"files-au-climate","remote_path":"climate-au/p/prj307b31b5a31416c1c2800/submission/spc30800006103164c8685a8/GreenCollar_submission_ACCU_Consultation_paper_Oct_2024.d999f791.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj307b31b5a31416c1c2800/submission/spc30800006103164c8685a8/GreenCollar_submission_ACCU_Consultation_paper_Oct_2024.d999f791.pdf","filename":"GreenCollar submission  - ACCU Consultation paper_Oct 2024.pdf","transcribed":"11 October 2024\n\nACCU Scheme Policy and Legislation Team\nDepartment of Climate Change, Energy, the Environment and Water\nACCUscheme@dcceew.gov.au\n\nDear ACCU Scheme Policy and Legislation Team,\n\nRE: Exposure Draft amending the Carbon Credits (Carbon Farming Initiative) Rule 2015\n\nThank you for the opportunity to provide comments on the ACCU Scheme Transparency Amendment\nRules.\n\nGreenCollar is a strong supporter of increased transparency across the ACCU Scheme and that confidence of on-ground land managers, the public, project investors and the market more broadly requires the Scheme’s systems and processes to be open and transparent. This is consistent with previous GreenCollar submissions including:\n\n1. the submissions of 11 September 2022 and 3 October 2022 to the Independent Review of\nAustralian Carbon Credit Units; and\n2. the joint submission of 13 October 2023 with ANU and UNSW ERF Research Team in response\nto the ACCU Review Discussion Paper.\n\nConsistent with this position GreenCollar supports the overall proposed approach to increase transparency and public access to information under the ACCU Scheme. In fact, much of the information proposed to be published by the Regulator under the draft Rule amendment is, for\nGreenCollar’s projects, already publicly available on GreenCollar’s website at: www.greencollar.com.au\n\nSummary of exemptions - Section 93A (2)(b)\n\nWe suggest that consideration is given to providing a third exemption category to protect personal information, such that the proponent could request, for privacy reasons, that the CER redact personal information from the material that is to be published. For example, a landholder name, phone number and email, where they are not the proponent, is not a valuable inclusion from a transparency point of view. Redacting such personal details do not impact on the intended transparency intent of this proposed amendment.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470) 1\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nGeneral clarifications\n\nGreenCollar considers the following general clarifications are needed in relation to the proposed amendment.\n\nWe understand the Rule amendment will commence when the amendment is made, and new publication requirements introduced by the amendment will apply to all eligible offsets projects that have been declared for all methodologies. On the basis that the Rule amendment does not introduce any additional information to be provided to the CER by project proponents, we understand the intention to be for information that will be published by the CER will be extracted from offset reports and other material, submitted by project proponents to the CER in accordance with the existing regulatory requirements. It would be beneficial if the Department could confirm that the CER already has access to the necessary information from the materials already been submitted by proponents\n(e.g., offsets reports), whether there is any additional information required and/or clarification of process and timing relating to any new reporting requirements being imposed on proponents as a result of this amendment. That is, if the CER requires additional information to meet its publication obligation under s166A of the CFI Act, clarification of those expectations and the transitional period that will apply would be helpful.\n\nSpecific comments and clarifications\n\nGreenCollar’s specific comments and clarifications sought are provided below:\n\nSection 93A Comments and clarifications sought\nParagraph 1(a) • We understand the published description of project\n“a description of the project activities will be drawn from offsets reports submitted\nthat includes a list of to the CER previously for each eligible offsets project.\nactivities that have been, are • Clarification is required as to the level of detail in\nbeing, or are to be, carried which project activities will be described in the\nout during the project’s published information (e.g., will it be a high-level\ncrediting period” description of the activities?).\n\nParagraph 1(b)\n“where the project is carried • Clarification is sought regarding the level of detail that\nout under a methodology would be published regarding baseline suppression\ndetermination that requires mechanisms.\nidentification of suppression\nmechanisms in the baseline\nperiod, a description of any\nidentified suppression\nmechanisms”\nParagraph (c) and (f)\n• It would seem reasonable to apply this calculation at\nthe CEA level. Will that be the case?\n\nTerra Carbon Pty Limited (ABN 69 154 094 470) 2\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\n“a description, including the • A 6-month transition period is likely to be needed for name and version where the CER as it involves significant data.\nrelevant, of any estimation or measurement approach or model used to calculate • It is unclear why this provision applies only to projects carbon abatement in relation which are required to used use FullCAM or RMT.\nto the project” Noting that it is possible that future ACCU Scheme\nAND methods will allow proponents the option to use\n“where the project is carried FullCAM or take a measured or hybrid approach, it is out under a methodology suggested that modelling start date for each CEA be determination that requires published for all projects modelled by FullCAM or carbon abatement to be RMT regardless of whether the project is required to modelled using the Full be modelled by FullCAM or RMT., that the.\nCarbon Accounting Model or\nReforestation Modelling\nTool, the date on which modelling starts for each carbon estimation area within the project”\nParagraph (h)\n“where the project proponent has authorised • As drafted, the scope of this paragraph is ambiguous another person as their agent and needs to be clarified. Currently, it is unclear what for any purpose listed in is meant by ‘otherwise relied on another person’s section 290(1) of the Act or significant involvement in the registration or has otherwise relied on administration of the project’.\nanother person’s significant • Current drafting could extend beyond independent involvement in the auditors and other consultants (such as geospatial registration or administration specialists and or data collection service providors) of the project—the name of engaged to assist with project monitoring but also to that other person and a the names of all of the individuals employed by the description of their proponent (or its agent). It is unclear whether this is involvement in the project.” the intention, so it is not possible to comment on the\nscope of this provision as currently proposed.\nAnother query would be whether the provision\nextends to publication of names of professional\nservice providers (e.g. lawyers) engaged to assist with\nprojects.\n• This provision requires amendment to make the\nscope clear.\n\nSubsection two “exemptions” • See Summary of Exemptions text above where we\n(i) the withholding of suggest that there be an additional category of\nthe information is exemption for personal information.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470) 3\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nrequired to\nprotect or respect\nAboriginal\ntradition; or\n(ii) the publication of\nthe information\nmay threaten,\ndamage or cause\nharm to a\nthreatened\necological\ncommunity or\nthreatened\nspecies\n\nAgain, thank you for the opportunity to provide these responses and comments.\n\nIf you require any further information in relation to this feedback please contact Hugh Wareham,\nPolicy Adviser M: 0417 139809 or E: hugh.wareham@greencollar.com.au\n\nYours sincerely\n\nNerida Bradley\nChief Impact Officer\nP: +61 414 966 129\nE: nerida.bradley@greencollar.com.au\nW: www.greencollar.com.au\n\nTerra Carbon Pty Limited (ABN 69 154 094 470) 4\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au","size":170106,"redacted":[],"meta":{"name":"GreenCollar_submission_ACCU_Consultation_paper_Oct_2024.d999f791.pdf","local_path":"files/ol2DpmWrpXTIXYxlpAixefIL.pdf"},"config":{}}}}}