{"data":{"id":"sbm39790f0e838164e363d86","short_id":18,"created":"2025-12-03T06:46:38.467Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Clare Stark","name-of-organisa_9974be":"Origin Energy","published-upload_e99675":"fil3b792877fc108b484a565"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b792877fc108b484a565":{"id":"fil3b792877fc108b484a565","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Origin_Energy.30261869.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Origin_Energy.30261869.pdf","filename":"Origin Energy.pdf","transcribed":"3 December 2025\n\nClimate Change Authority\n\nSubmitted online: consult.climatechangeauthority.gov.au\n\n2026 ACCU Scheme review – Issues Paper\n\nOrigin Energy Limited (Origin) welcomes the opportunity to provide comments on the Climate Change\nAuthority’s (CCA) 2026 Australian Carbon Credit Unit (ACCU) Scheme review Issues Paper titled\n‘Enhancing the ACCU Scheme to support Australia’s 2035 emissions reductions target’.\n\nAs the Issues Paper states, the ACCU Scheme is an important part of the journey to achieving\nAustralia’s commitments to reduce emissions. The Commonwealth’s Net Zero Plan also advises that a strengthened ACCU Scheme is a key enabler of the increase in net carbon removals required to achieve net zero by 2050. Treasury’s modelling to support this plan estimates total carbon removals will need to increase rapidly from 74 Mt CO2-e in 2025 to 167 Mt CO2-e by 2050. The Productivity Commission’s\n(PC) Inquiry Interim Report also emphasises the importance of widespread use of ACCUs across the economy to support achieving net zero in 2050 at as low a cost as possible.\n\nScaling and accelerating methods will be required to achieve policy ambitions\n\nWe recognise the Commonwealth, expert advisers such as the Emissions Reduction Assurance\nCommittee (ERAC) and CCA, and the Clean Energy Regulator are committed to progressing methods, projects, and markets for carbon crediting. These organisations have demonstrably collaborated to progress the recommendations from the 2022 independent review to ensure the ACCU Scheme is strong and credible. But these methods and their use must increase substantially to ensure the estimated scale of offsets required to achieve Australia’s decarbonisation targets can be delivered.\n\nAs the Issues Paper notes, there has been a reduction in methods available to acknowledge and reward projects that can help offset emissions across the economy. Several existing methods have expired or will soon expire which prevents additional projects from engaging with these offsets. The department’s\n‘ACCU method tracker’ advises many of these methods are currently either being reviewed by ERAC or considered by the Assistant Minister for Climate Change, but the timelines for these decisions are unclear. Similarly, timelines are unclear for decisions on methods proposed through the new proponent- led process recommended by the 2022 independent review. It appears that after 18 months, only two of the five main steps required to finalise methods under this process have been completed.\n\nIt is not immediately clear what is delaying decisions on whether existing methods will be reintroduced or removed, as well as whether proposed methods will be adopted. We suggest one solution to help identify and address bottlenecks could be to prescribe timeframes for each stage of these processes.\nThis would help identify which stages may be facing barriers that prevent the timely and successful completion of these processes and help target solutions, such as increasing resourcing and expertise for that stage. Reporting against these timeframes would also deliver greater clarity and confidence for stakeholders and enable them to propose potential solutions. We note the value of greater clarity on process and timeframes has been recognised in the context of improving connections processes for the\nNational Electricity Market, as well as reforms to planning and approvals processes.\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\nThere is also an opportunity for the CCA and Commonwealth to increase broader awareness of, and engagement with, the ACCU Scheme. For example, the Agriculture and Land Sector Plan identifies there is an opportunity to leverage carbon markets to deliver benefits for the sector, supported by improved measurement and reporting tools and ACCU methods. But it just notes banks, supply chains, and others are expected to encourage participants to adopt these tools and methods in the future.\nSimilarly, the Industry Plan notes the ACCU Scheme can incentivise emissions reductions but does not encourage the use of existing methods which reward upgrades, replacements and fuel switching for industrial and commercial processes. The CCA could consider how different industries could be supported and encouraged to use existing methods and be rewarded for supplying the offsets that net zero will require.\n\nThe evolving ACCU markets dynamics can support an orderly transition\n\nAs the Issues Paper notes, there has been an evolution from the nascent scheme which required the\nCommonwealth to be an ‘anchor customer’ towards a competitive market, strengthened by recent reforms to the ACCU Scheme and Safeguard Mechanism. This aligns with the PC’s Inquiry Interim\nReport which notes the need to integrate government settings into broader frameworks over time, as well as the Treasurer’s advice to the PC that effective regulation supports competition and reinforces the five pillars of the Commonwealth’s Productivity Agenda. It also allows the costs of projects to create these offsets to transition to be increasingly funded by the private sector, rather than the Commonwealth.\n\nThe role of the Commonwealth is also evolving from ensuring sufficient and certain demand for ACCUs through mechanisms like the Carbon Abater Contracts (CACs) to supporting efficient market outcomes.\nFor example, in 2022 the Commonwealth introduced a requirement for entities to deliver at least 20% of the ACCUs contracted through CACs to manage the impact of increasing supply into the ACCU market. It may be appropriate now for the Commonwealth to review CACs and consider how the impact on the market can be managed, such as signalling potential changes in contracted positions. It may also be appropriate for the Commonwealth and supporting entities to consider whether operational changes are required to support efficient market operation. For example, how they ensure market sensitive information, such as regulatory change or market data, is provided publicly and in a timely manner to prevent providing any participants with a competitive advantage or distorting market outcomes.\n\nIt may also be timely to revisit the CCA’s 2022 proposal for the Commonwealth to develop and publish a national carbon market strategy to provide greater clarity on the broader strategic framework. This could help improve coordination between the ACCU Scheme and other schemes to ensure they are aligned in efforts to accelerate activity to achieve net zero by 2050. For example, the credits generated under the Safeguard Mechanism (SMCs) provide large emitters with an alternative to ACCUs, while other schemes like Climate Active and the Guarantee of Origin offer alternative certification for emissions reductions. A coherent carbon market strategy could also support coordination on consultations to refine these schemes and allow for more efficient, aligned reporting under them.\n\nIf you wish to discuss any aspect of this submission further, please contact Clare Stark at clare.stark@originenergy.com.au or on 0458 286 194.\n\nYours Sincerely,\n\nShaun Cole\nGroup Manager, Regulatory Policy\n\nPage 2 of 2","size":113251,"redacted":[],"meta":{"name":"Origin_Energy.30261869.pdf","mime_type":"application/pdf","local_path":"files/0mfWwiuxpPV73KFk4x5VuImp.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil39790ef2ef812bfb6eda6":{"id":"fil39790ef2ef812bfb6eda6","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/ORG_sub_ACCU_Review_issues_paper.f4c25ffa.pdf","filename":"ORG sub -ACCU Review issues paper.pdf","transcribed":null,"size":113251,"redacted":[],"config":{}}}}}