{"data":{"id":"sbm3992baceaf7cbc5c3acd5","short_id":69,"created":"2025-12-08T06:24:44.719Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Carmel Forbes","name-of-organisa_9974be":"Shell Energy ","published-upload_e99675":"fil3b792df64110b0a81c015"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b792df64110b0a81c015":{"id":"fil3b792df64110b0a81c015","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Shell_Energy.9835d7ab.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Shell_Energy.9835d7ab.pdf","filename":"Shell Energy.pdf","transcribed":"8 December 2025\n\nClimate Change Authority\nGPO Box 3090,\nCanberra ACT 2601\n\nSubmitted online: consultation@climatechangeauthority.gov.au\n\nRE: 2026 ACCU Scheme Review – Issues Paper\n\nShell Energy welcomes the opportunity to inform the Climate Change Authority’s (CCA) fifth review of the\nCarbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act).\nShell Energy supports the evolution of an efficient carbon market that allows for price formation, price discovery and a robust price signal to drive investment in abatement opportunities across the economy. We support the use of high-quality carbon offsets to compensate for hard-to-abate emissions. Australian Carbon Credit Unit’s\n(ACCUs) form an important and legitimate component of this. It is integral that the ACCU Scheme is transparent, provides market participants with certainty, and has a high degree of integrity.\n\nResponse to consultation questions\n\nHow can the right price signals be established to incentivise high-quality abatement?\nPrice signals for high-quality abatement should be grounded in transparent market fundamentals, ensuring that supply and demand dynamics are clearly understood and reflected in policy settings. Demand clarity is critical, particularly in relation to abatement obligations under the Safeguard Mechanism and Climate Active, as these frameworks define compliance requirements and shape market behaviour.\n\nWithin this context, market fundamentals must drive price signals for ACCUs and Safeguard Mechanism Credits\n(SMCs), with prices reflecting supply, demand, and the marginal cost of production. Robust integrity measures are essential, including consistent principle-based methodology reviews to confirm that ACCUs represent genuine, additional, and permanent emissions reductions. At the same time, the role of international mitigation must be clearly defined. The use of high-integrity international offsets under Article 6 should be considered under the ACCU Scheme. Access to international offsets would enhance flexibility and cost-effectiveness for hard-to- abate sectors.\n\nThese measures will deliver a robust, transparent, and credible carbon market that aligns with international best practice, provides accurate price signals, and accelerates Australia’s transition to a low-emissions economy.\n\nHow do you decide which ACCUs to buy? How much is your ACCU purchase impacted by factors such as cost per unit, and the social, environmental or economic co-benefits involved?\nShell Energy considers that the ACCU market is primarily driven by compliance obligations under the Safeguard\nMechanism, where ACCUs currently serve as a standardized compliance instrument. In this context, we consider\nACCUs are likely to be homogeneous commodity, and unless specific compliance requirements dictate otherwise, additional attributes such as social, environmental, or economic co-benefits are unlikely to be factored into businesses pricing decisions. That is, without standardized frameworks or reliable measurement, it’s difficult to determine the right level of investment in creating or purchasing ACCUs with these benefits.\n\nShell Energy Operations Pty Ltd, Level 30, 275 George Street, Brisbane Qld 4000. GPO Box 7152, Brisbane Qld 4001.\nABN 28 122 259 223 Phone +61 7 3020 5100 Fax +61 7 3220 6110 shellenergy.com.au\nWhat role, if any, should the Government play in ACCU purchasing? Are there any approaches, besides direct purchase, the Government should consider to support an orderly transition for businesses?\nThe role of the Government should be to provide stability, certainty, and transparency to support a liquid ACCU commodity market and ACCU fungibility.\n\nShell Energy supports the Australian Government’s role in purchasing ACCUs as a mechanism to incentivise the development of new, high-integrity carbon projects. This role can be critical to strengthen market confidence and accelerate investment in abatement initiatives. However, for this approach to deliver its intended outcomes, greater transparency and forward visibility are required to maintain market confidence.\n\nClear objectives and market gap analysis should underpin any government purchasing decisions, informed by active consultation with developers and market participants. Policy transparency and clarity must extend to existing carbon abatement contracts, particularly regarding transitional exit arrangements. Forward visibility on expected abatement to be delivered to the government and interaction with the cost containment reserve is necessary to maintain confidence in supply security, including post-2030 arrangements.\n\nStakeholder engagement, advanced notice of changes, and clear guidance regarding the Australian\nGovernment’s role in purchasing ACCU’s will be key to the ongoing success of the ACCU Scheme.\n\nShell Energy welcomes ongoing dialogue on this important policy. If you have any questions or would like further details relating to this submission, please contact Carmel Forbes at carmel.forbes@shellenergy.com.au\n\nYours sincerely,\n\nJames Ell\nActing General Manager – Regulatory Affairs and Compliance\n\nPage 2 of 2","size":44258,"redacted":[],"meta":{"name":"Shell_Energy.9835d7ab.pdf","mime_type":"application/pdf","local_path":"files/ZFcwqSE2B9GgD8bB5hhqYYh_.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil3992baba777cae023fa86":{"id":"fil3992baba777cae023fa86","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Shell_Energy_submission_Climate_Change_Authority_2026_ACCU_Review.5d5a449a.pdf","filename":"Shell Energy submission_Climate Change Authority 2026 ACCU Review.pdf","transcribed":null,"size":53649,"redacted":[],"config":{}}}}}