{"data":{"id":"sbm39920bb22de502eeb21d5","short_id":38,"created":"2025-12-08T03:13:28.621Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Andrew Smith","name-of-organisa_9974be":"Chevron Australia ","published-upload_e99675":"fil3b792aaa6e6ba1ce14081"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b792aaa6e6ba1ce14081":{"id":"fil3b792aaa6e6ba1ce14081","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Chevron_Australia.e638205e.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Chevron_Australia.e638205e.pdf","filename":"Chevron Australia.pdf","transcribed":"David Fallon\nGeneral Manager – Lower Carbon Execution, Australia\n\n05 December 2025\n\nSubmission – Enhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\n\nDear Sir/Madam\n\nChevron Australia Pty Ltd (Chevron Australia) is pleased to provide a submission to the Climate\nChange Authority’s (CCA) 2026 ACCU Scheme review public consultation, designed to inform the review of the Carbon Credits (Carbon Farming Initiative) Act 2011, which enables the Australian\nCarbon Credit Unit (ACCU) Scheme.\n\nChevron is one of the world's leading integrated energy companies and, through its Australian subsidiaries, has been present in Australia for more than 70 years. Chevron Australia operates the\nGorgon and Wheatstone natural gas facilities, manages a one-sixth non-operating interest in the\nNorth West Shelf Project and has commenced decommissioning of Australia's largest onshore oilfield at Barrow Island. Chevron Australia Downstream delivers quality fuels and lubricants primarily via its Caltex network of service stations across Australia.\n\nWe are advancing a lower carbon future and believe we all have a stake in a reliable, affordable energy system. Our belief that the future is lower carbon drives Chevron's lower carbon ambitions and the actions we take to advance them. Globally, we are investing to grow our oil and gas business, lower the carbon intensity of our operations and pursue new businesses.\n\nChevron supports well designed policies to manage greenhouse gas emissions. We see greenhouse gas management as an integral part of how we plan and operate our business and remain focused on reducing the carbon intensity of natural gas production at our facilities including through carbon capture and storage (CCS) as well as the use of offsets. Chevron supports the Australian Carbon\nCredit Unit (ACCU) scheme and is keen to participate in discussions such as this consultation to help grow a viable offset market that can support Australia’s lower carbon goals.\n\nIn providing feedback to the Australian Government’s consultation process, Chevron Australia also endorses submissions made by Australian Industry Greenhouse Network (AIGN) and Australian\nEnergy Producers (AEP)\n\nIf you require further information or clarification in relation to this submission, please do not hesitate to contact Andrew Smith at\n\nRegards,\n\nDavid Fallon\n\nChevron Australia Pty Ltd\nABN 29 086 197 757\nLevel 2, One The Esplanade, Perth WA 6000\nABU Doc ID: ABU251200056\nPage 2\nDecember 8, 2025\n\nFocus area 1: Methodologies – new and existing\n\n1. How can the development and approval of high-integrity, scalable methodologies be\naccelerated?\n\nMaintaining the integrity of the Scheme should remain the highest priority; however, the\ncurrent pace of methodology development is slow. The current Integrated Farm and Land\nManagement (IFLM) method development process is an example of this. While updates to\nexisting methods such as Land Fill Gas and Savanna demonstrate improvements can be\nmade without compromising standards, the overall process would benefit from improved\nefficiency.\n\nWhen selecting which method to develop, the potential volume of ACCUs to be generated\nfrom each method should be considered. With limited government resources, prioritising\nhigh-impact methods is likely to result in the greatest return on investment.\n\nResource constraints within DCCEEW suggests greater industry involvement in drafting\nmethodologies could help accelerate progress. A co-development model, where industry\nprovides technical input with regulatory oversight, could be a practical solution in expediting\nprogress while maintaining integrity and transparency.\n\nUtilising existing Paris Agreement-aligned frame works for offset methodologies from\ninternational jurisdictions, such as Europe or California, may also help accelerate method\ndevelopment within Australia.\n\nModular, flexible activities that can be used across multiple project types and/or\nmethodologies should be prioritised. Increasing the number of methods under consultation\nwould also help to accelerate the development and issuance of scalable methodologies.\n\nWe believe clear timeframes and regular progress reporting are highly important to build\ntransparency and confidence in the process. Defined milestones will encourage participation\nand accountability throughout method development.\n\n2. What are the current barriers to method development and how could they be overcome?\n\nWhile recognising that the integrity of method development is critical, several barriers exist to\nencouraging method development.\n\na. The first is the method development process itself. The carbon industry receives regular\nupdates from the Clean Energy Regulator (CER), Department of Climate Change,\nEnergy, Environment and Water (DCCEEW), and the Emissions Reduction Assurance\nCommittee (ERAC). These updates however are not sufficiently transparent on how\nmethod development is progressing at points in time and how key decisions are made.\nGreater clarity via regularly publishing methodology development work programs and\nincluding estimated approval dates and details on regulator decisions would better equip\nstakeholders to plan and participate. This increased visibility would encourage broader\nindustry involvement and help ensure resource and time commitments are well\nunderstood from the outset.\n\nChevron Australia Pty Ltd\nABN 29 086 197 757\nLevel 2, One The Esplanade, Perth WA 6000\nABU Doc ID: ABU251200056\nPage 3\nDecember 8, 2025\n\nb. Method development can be research intensive and requires long term financial support.\nTargeted government grants or tax concessions could be offered to support industry and\nencourage greater involvement in the method development process.\n\nc. The amount of data required to submit a robust methodology proposal is significant.\nMaking non-commercial, project-level registration documents publicly available would\nassist in reducing the current data gathering burden. For example, documents that\ndescribe the biophysical environment, or provide species-specific advice that could\ninform new methods or improve existing ones.\n\n3. What additional resources may be required to deliver the methods faster? How can\ntransparency of method development and projects be improved?\n\nTo deliver methodologies in a timely and efficient manner, consideration might be given for\nadditional government funding for government regulatory agencies such as CER, ERAC and\nDCCEEW. Opportunities for industry to support the work of government agencies should\nalso be considered. As mentioned previously, this could include improved transparency on\nthe method development approval and development process, sharing of non-confidential\nproject information and targeted government funding or tax concessions for method\ndevelopment.\n\n4. What potential new methods or refinements to existing methods could unlock significant new\nabatement?\n\nFor potential new methods, Biochar has strong appeal as a method due to the range of input\nmaterial available and certainty regarding abatement potential. Saltbush Planting is in the\nearly stages of development but could be applied to a large land area in parts of Australia 1\nAn example of refinement to an existing method would be the adjustment to the existing\nReforestation and Afforestation method to allow Perennial Oil Seed planting and Measured\nPlantation Forestry with Scenario Averaging. This would broaden the range of eligible\nactivities, providing greater flexibility and stronger economic incentives for proponents while\nmaintaining method integrity.\n\n5. Do the rules on permanence and crediting periods get the balance right between integrity\nand project viability?\n\nShort crediting periods do not incentivise the capital investment required for some methods.\nA minimum crediting period that allows project proponents commercial certainty proportional\nto the level of investment could assist. An example is the FOGO method which has a\ncrediting period of 7 years but requires capital investment in anaerobic digestion facilities\nwhich have a long depreciation schedule.\n\nFocus area 2: ACCU market dynamics\n\n1. How do you decide which ACCUs to buy? How much is your ACCU purchase impacted by\nfactors such as cost per unit, and the social, environmental or economic co-benefits\ninvolved?\n\n1\nSaltbush Carbon Project - Facey Group, Murdoch crunch carbon data for saltbush — Wheatbelt NRM\nChevron Australia Pty Ltd\nABN 29 086 197 757\nLevel 2, One The Esplanade, Perth WA 6000\nABU Doc ID: ABU251200056\nPage 4\nDecember 8, 2025\n\nChevron has confidence that all ACCU’s issued by government, via regular reviews and\naudits, have met the robust requirements of the regulator. Outside of commercial and\noperational considerations Chevron has no preference on ACCU methodology to meet our\nregulatory obligations.\n3. What role, if any, should the Government play in ACCU purchasing? Are there any\napproaches, besides direct purchase, the Government should consider supporting an orderly\ntransition for businesses?\nAs stated earlier, the government should ideally play a continuing role in ensuring the ACCU\nmarket is robust and that there are sufficient offsets entering the market. The Cost\nContainment Measure is a key part of this role, providing a backstop for safeguard entities in\nthe event there is a lack of ACCU supply or difficulties accessing ACCUs.\nMaking non-commercial, project-level registration documents publicly available to support\nfaster methodology development would also support development of the ACCU market.\nIn the longer term, enabling appropriately accredited internationally transferred mitigation\noutcomes (ITMOs) to be used together with ACCUs for meeting emission obligations would\nhelp facilitate an orderly transition for businesses.\n\nConclusion\n\n1. How fair and accessible is the scheme, considering the treatment of different sectors,\nbarriers to participation and access to benefits?\nCurrently, most methodologies are focused on the land and agricultural sectors. The\nuncertain timeline, short- lived crediting periods and potential expense to develop a\nmethodology is likely to limit proponents. This reduces the ability of different sectors of\nindustry to develop methodologies relevant to their sector and reduces the availability of\nACCUs in the long-term.\n\nChevron Australia Pty Ltd\nABN 29 086 197 757\nLevel 2, One The Esplanade, Perth WA 6000\nABU Doc ID: ABU251200056","size":155153,"redacted":[],"meta":{"name":"Chevron_Australia.e638205e.pdf","mime_type":"application/pdf","local_path":"files/DdG5CYGFXCBDh7u3iQju4fWN.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil39920b80cdcc571085312":{"id":"fil39920b80cdcc571085312","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/ABU251200056_ACCU_Scheme_20251205.563362be.pdf","filename":"ABU251200056_ACCU Scheme_20251205.pdf","transcribed":null,"size":186142,"redacted":[],"config":{}}}}}