{"data":{"id":"sbm3799d96c5d5064df28ed0","short_id":44,"created":"2025-09-01T05:29:57.085Z","space_id":"spc36e573d0a3f7d764ba5a0","project_id":"prj36e56fbec442ea80abc09","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Gary Wyatt","submission_5bfc8c":"fil3954833bed9c0926f0a42","name-of-organisa_9974be":"Corporate Carbon"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3954833bed9c0926f0a42":{"id":"fil3954833bed9c0926f0a42","bucket":"files-au-climate","remote_path":"cca/p/prj36e56fbec442ea80abc09/submission/spc36e573d0a3f7d764ba5a0/Corporate_Carbon.5668995f.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj36e56fbec442ea80abc09/submission/spc36e573d0a3f7d764ba5a0/Corporate_Carbon.5668995f.pdf","filename":"Corporate Carbon.pdf","transcribed":"Monday 1 September 2025\nMr Brad Archer\nCEO Climate Change Authority\nGPO Box 3090\nCanberra ACT 2601\nVia email: brad.archer@climatechangeauthority.gov.au\nDear Brad,\nConsultation on Climate Change Authority’s 2025 Annual Progress Report\nThank you for the opportunity to provide input into Climate Change Authority’s 2025 Annual Progress Report. We are pleased to make a contribution, especially as the 2025 Annual Progress Report will be used to inform the Minister’s 4th\nAnnual Climate Change Statement to Parliament.\nAs one of Australia’s leading carbon market participants, we have extensive experience in designing, developing, owning, registering, managing and delivering Australian Carbon Credit Units (ACCUs).\nWe believe the Safeguard Mechanism and the ACCU Scheme are intrinsically linked to Australia’s safe climate contributions and that more policy support is required to fast track the transition to a net zero economy. For example:\n– Safeguard provides the demand driver for emissions reductions\n– ACCU scheme provides the supply of high-integrity, flexible, and cost-effective abatement.\n\nFor the Safeguard Mechanism to succeed, Australia must maintain and expand a thriving ACCU market that is accessible, diverse, and scalable.\nFurther detail on suggested mechanisms to support and enable the transition to a net zero economy are provided in this submission. We are also happy to provide any further information to Climate Change Authority should this be required.\nWe are also happy to host any of the Authority’s team on fact finding visits to further the understanding of the importance of ACCU Scheme projects.\n\nSincerely,\n\nGary Wyatt\nManaging Director\n\nCorporate Carbon Group Pty Ltd\nABN 30 637 262 189  Suite 3, Level 7/25 Bligh St, Sydney NSW 2000\n1300 227 206 (1300 CARBØN) info@corporatecarbon.com.au  www.corporatecarbon.com.au\nSupporting and enabling the transition to a net zero economy\nThe Government has laid strong foundations to support and enable the net zero transition including regulation, oversight and policy frameworks. However, more must be done to:\n\n– provide long-term certainty for the ACCU Scheme, which underpins Safeguard compliance and voluntary\ncorporate action\n– expand methodologies to increase the breadth and resilience of ACCU supply, including both nature-based and\nengineered removals\n– align finance and investment signals to scale up ACCU supply in line with rising Safeguard demand.\nWithout an expanding ACCU Scheme, the Safeguard risks becoming a compliance burden with insufficient abatement options. This could undermine Australia’s progress and puts at risk the opportunity to capitalise on the associated innovation premium from a net zero economy.\n\nSafeguard Mechanism Improvements\nSafeguard reforms have strengthened the functionality of the Mechanism, especially since 2023. However, many facilities face technological and cost barriers to deep on-site cuts. ACCUs are an important economic tool to assist facilities meet their targets. Purchasing ACCUs allows compliance obligations to be met and also places an internal price on carbon for each of these facilities which incentivises ‘in-house’ emissions reductions.\nFurthermore, because the Earth is a closed system, ACCUs are an important ecological tool with certified drawdowns equivalent to avoided emissions. The ACCU Scheme provides elegant complementarity to Safeguard through flexibility of compliance, economic incentive and ecological outcome.\nWith this in mind, there are some improvements we suggest to the Safeguard Mechanism:\n– thresholds, baselines and decline rates: Should align with national targets, and be paired with policy incentives\nand targets to a growing ACCU market\n– flexibility: ACCUs should remain a central compliance option, with reforms directed at expanding supply and\naccelerating participation\n\n– integration: ACCU supply forecasting should be embedded into Safeguard policy design. For example,\nintroducing participation targets for nature based ACCU projects in Agriculture would enable increased\nconfidence in ACCU supply\n\nSafeguard performance cannot be measured in isolation; it depends on the strength, growth, and credibility of the ACCU\nScheme.\n\nACCU Scheme Improvements\nThe Carbon Farming Initiative is about to enter its fifteenth year of operation since its introduction in 2011 under the\nGillard Labor Government. Since then there have been many major milestones delivered, including a comprehensive review by former Chief Scientist Ian Chubb who concluded that the ‘ACCU Scheme arrangements are essentially sound’.\nCorporate Carbon Group Pty Ltd\nABN 30 637 262 189  Suite 3, Level 7/25 Bligh St, Sydney NSW 2000\n1300 227 206 (1300 CARBØN) info@corporatecarbon.com.au  www.corporatecarbon.com.au\nIn order to improve the operation of the ACCU Scheme as a complementary tool with Safeguard Mechanism in delivering a net zero economy, we make the following recommendations:\n\n– continued support for new method development with a focus on new emerging technologies to provide\ncustomised participation options (for example, the use of AI to integrate existing methodologies into a true ‘meta-\nmethod’ platform\n\n– increased policy certainty for continuity of existing methods: need to improve handling of periodic reviews. Beef\nHerd Management and Soil Organic Carbon are examples of how poorly managed processes run overtime, cut\nout consultative processes to continuous improvement and have negative impacts on method development\n\n– ACCU Scheme investment: CCA should be tasked with recommending policy adjustments to the ACCU Scheme\nto encourage investment into the ACCU Scheme. For example, investment into the scheme could be\nencouraged by allowing project developers to acquit their liabilities associated with legacy Carbon Abatement\nContracts by investing into new projects\n– setting milestones and targets: CCA should be specifically tasked with setting targets for ACCU creation and\narea based land-sector participation targets. This should be done on both a national and state basis\n\n– reporting: CCA should be tasked with reporting investment flows into the ACCU Scheme and the performance of\nthe scheme against the milestones and targets described above.\n\nConclusion\nAustralia’s emissions reduction framework is strongest when the Safeguard Mechanism (demand) and the ACCU scheme\n(supply) are viewed as a single, mutually reinforcing system.\n\nCorporate Carbon recommends that the Authority:\n– explicitly recognise the Safeguard–ACCU interdependence\n– expand methodologies and policy support to grow ACCU supply\n\n– provide demand certainty so project developers and investors have confidence to scale up\n– position ACCUs not as an ‘offset of last resort’ but as a fit-for-purpose cornerstone of national climate policy.\nA thriving ACCU scheme is not optional, rather it is the foundation on which Safeguard compliance, industrial transition, and Australia’s net zero ambitions rest.\n\nCorporate Carbon Group Pty Ltd\nABN 30 637 262 189  Suite 3, Level 7/25 Bligh St, Sydney NSW 2000\n1300 227 206 (1300 CARBØN) info@corporatecarbon.com.au  www.corporatecarbon.com.au\nAbout Corporate Carbon\nCorporate Carbon Group is Australia’s largest Emissions Reduction Fund project owner, with 1.3 million hectares of land under active management (shown in the map below), more than 100 projects across 12 different methodology types and four standalone ‘special purpose companies’ that are in various stages of ‘spin out and scaleup’ (Agriprove, Paniri\nAgricultural Co, AspiraDAC and Maki Wildfire Management).\n\nCorporate Carbon has been at the forefront of commercialising climate innovation in the Australian carbon market, with a long history of innovative engagement under the Carbon Farming Initiative regulatory framework. Our founder and Chair was the author of the first privately sourced Methodology to be made into a Determination.\n\nOur portfolio of projects includes projects across every sector of the Australian economy. We are at the cutting edge of carbon removal technology with our work in commercialising Direct Air Capture and are active in exporting wildfire management emissions avoidance technology overseas. Also, we recently became the first carbon company to establish material ‘climate smart cattle ’operations in Queensland, with a herd size of 16,000 and growing.\n\nCorporate Carbon Group Pty Ltd\nABN 30 637 262 189  Suite 3, Level 7/25 Bligh St, Sydney NSW 2000\n1300 227 206 (1300 CARBØN) info@corporatecarbon.com.au  www.corporatecarbon.com.au","size":381771,"redacted":[],"meta":{"name":"Corporate_Carbon.5668995f.pdf","local_path":"files/YJ6rfqslBaZorg7gmK1VYsG6.pdf"},"config":{}}}}}