{"data":{"id":"sbm39a6242bfce1135e924f4","short_id":79,"created":"2025-12-12T00:52:36.988Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Tom Parkinson","name-of-organisa_9974be":"Fortescue","published-upload_e99675":"fil3b792f6b51a056ac11443"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b792f6b51a056ac11443":{"id":"fil3b792f6b51a056ac11443","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Fortescue.3efb5394.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Fortescue.3efb5394.pdf","filename":"Fortescue.pdf","transcribed":"11 December 2025\n\nMr Matt Kean\nChair\nClimate Change Authority\nDear Mr Kean\n\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\n\nA proudly Australian company with balance sheet strength, Fortescue is a global leader in large-scale, ultra- efficient and highly complex developments with a proven track record in developing and operating assets in remote and isolated locations. Fortescue is also a global leader in industrial decarbonisation, evidenced by its target to achieve Real Zero emissions across our terrestrial mining operations in Australia by 2030, through the phase out of fossil fuels. We are establishing a global portfolio of renewable energy, green iron, green hydrogen and derivatives, battery system and green technology projects and operations that are at the forefront of the global energy transition.\n\nFortescue welcomes the opportunity to provide comment on the Climate Change Authority’s (CCA) consultation paper Enhancing the ACCU Scheme to support Australia’s 2035 emissions reduction target.\nThis review is timely following Australia’s recently updated 2035 Nationally Determined Contribution (NDC), setting an emissions reduction ambition between 62% and 70%. Fortescue led a campaign for a science- based target of 75% as part of the Business for 75 campaign and welcomes the upper end of the\nGovernment’s range. However, we note that it should be a floor not a ceiling on ambition, and that deeper reductions are necessary to limit warming as close to 1.5ºC as possible. As Australia progresses towards its targets, the Australian Carbon Credit Unit (ACCU) market will require close attention from Government to ensure that true emissions abatement from fossil fuel phase down, and ultimately out, remains the priority, and that there is not an over reliance on offsets.\n\nIn this context, Fortescue considers the core question posed by the consultation paper to be very important.\nHow can the ACCU Scheme deliver enough abatement to support Australia to meet its 2030 and 2035 emissions reduction targets? The question should not be how to increase the role for offsets within Australia, but to ensure that their use is capped and phased down, consistent with best practice in other nations, and in conjunction with substantial, near-term investment in genuine abatement – electrification and renewables deployment. Fortescue is concerned the current Safeguard Mechanism (SGM) settings and the ACCU scheme do not incentivise this outcome.\n\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 1 of 9\nThe evidence that even high-integrity offsets are non-equivalent to the fossil fuel emissions they purport to\n“neutralise,” in addition to suffering from other systemic issues, is now incontrovertible1,2,3,4,5,6,7. Burning fossil fuels adds new carbon to the active carbon cycle that has previously been stored underground for hundreds of millions of years, whereas nature-based solutions act as temporary (years to decades) stores of carbon, quickly releasing it back to the atmosphere.\n\nDue to this evidence, Fortescue is prioritising true abatement activities and has a fully costed plan to remove fossil fuel usage from our terrestrial iron ore mining operations. It is our hope that the evidence provided by our decarbonisation will pave the way for others across industry to follow. Fortescue's decarbonisation agenda for our mining operations is an industry-leading commitment to achieving 'Real Zero' operational emissions by 2030, pushing much further than common 'net zero' targets. We are focused on completely eliminating all Scope 1 and Scope 2 emissions from our Australian terrestrial iron ore operations without relying on voluntary carbon offsets or carbon capture and storage (CCS). We will achieve this goal through a significant capital investment of US$6.2 billion, deploying a comprehensive transformation of our electricity infrastructure and on-site machinery. The economic benefits of a Real Zero approach, as opposed to net zero, were documented in a recent analysis by Climate Analytics launched at COP308.\n\nOur pathway to Real Zero relies on two major pillars: switching to renewable energy and electrifying our heavy mining fleet. This includes building 2–3 GW of new renewable generation integrated with large-scale battery storage to fully power all mine sites and processing plants, displacing natural gas and diesel entirely.\nConcurrently, our entire fleet of mining machinery will be converted to run on renewable energy. Achieving this will demonstrate that full decarbonisation of a heavy industrial emitter is entirely possible while remaining one of the most profitable businesses in Australia. It is our hope that this demonstrates to broader industry and Government that there is an economic benefit to greater ambition in a national emissions reduction agenda, including the creation of jobs, new green export industries and innovation.\n\n1 Anderegg et al. (2020). Climate-driven risks to the climate mitigation potential of forests. Science, 368\n(6497). https://doi.org/10.1126/science.aaz7005\n2 Probst et al. (2023). Systematic review of the actual emissions reductions of carbon offset projects across all major sectors (Working Paper). ETH Zurich Research Collection. https://doi.org/10.3929/ethz-b-000620307\n3 West et al. (2024). Systematic assessment of the achieved emission reductions of carbon crediting projects. Nature\n\nCommunications, 15, 9481. https://doi.org/10.1038/s41467-024-53645-z; West et al. (2023). Towards a comprehensive assessment of carbon crediting projects. Nature Sustainability, 6, 1050–\n1060. https://doi.org/10.1038/s41893-023-01259-6\n4 Badgley et al. (2021). Systematic over-crediting of forest offsets. Proceedings of the National Academy of\n\nSciences, 118(19), e2004334117. https://doi.org/10.1073/pnas.2004334117\n5 Macintosh et al. (2024). Australian human-induced native forest regeneration carbon offset projects have limited impact on land cover. Nature Communications Earth & Environment, 5, 151. https://doi.org/10.1038/s43247-024-\n01313-x\n6 Johannessen and Christian (2023). Why blue carbon cannot truly offset fossil fuel emissions. Nature\n\nCommunications Earth & Environment, 4:411. https://doi.org/10.1038/s43247-023-01068-x\n7 Macintosh et al. (2025) Carbon credits are failing to help with climate change — here’s why. Nature, 646, 543-546\n8 Real Zero is within Reach. https://climateanalytics.org/publications/real-zero-is-within-reach\n\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 2 of 9\nSafeguard Mechanism review\n\nThe SGM is Australia’s flagship policy to incentivise heavy industry to decarbonise over time, in line with\nAustralia’s NDC under the Paris Agreement. The 2022 policy reform of the SGM was undertaken to ensure the policy aligned with this commitment and was a welcome step to ensure industrial emitters reduced their proportionate share of the 43% target. However, alongside this reform and many other policies that the\nFederal Government has announced and implemented, the Department of Climate Change, Energy, the\nEnvironment and Water now projects that Australia will reach 42.7% emissions reduction by 20309, falling just short of the target.\n\nWith Australia’s new NDC range of 62%-70% recently announced, it is timely that the SGM and its settings will be reviewed beginning in 2026. The ACCU scheme is relied on heavily by companies over their baselines to meet their compliance requirements under the SGM, therefore Fortescue encourages the CCA to consider our feedback on the role of offsets in the broader emissions reduction policy settings within the SGM.\n\nThe design and implementation of the SGM has not yet delivered the significant changes required to align industrial emissions with the 1.5-degree global warming limit, nor the updated 2035 target, which must be addressed through the 2026 review. While the SGM mandates declining emissions baselines for large polluters, facilities can choose to comply by reducing on-site emissions, purchasing ACCUs or buying\nSafeguard Mechanism Credits (SMCs). The fundamental problem is that most facilities have elected to use relatively low-cost offsets, which as discussed below have faced integrity concerns, rather than investing in decarbonisation technologies, renewable energy infrastructure and reducing on-site emissions. Importantly, the current framework allows for the unrestricted surrender of offsets to meet compliance obligations. This is due to the Government wanting to encourage the industrial sector to pursue the cheapest option to meet their compliance with the SGM. The fatal flaw with this is it assumes that purchased offsets and on-site fossil fuel reduction are equivalent, which is verifiably wrong10. Indeed, this is the reason why the majority of national pricing schemes globally set a relatively stringent upper quantitative limit on offset use11.\n\nAustralia’s lack of a cap on offset use makes it unusual among its peers. In California, offset use is limited to\n6% of an entity’s total emissions, and in South Korea the proportion is 10%. Some schemes set higher thresholds, with Vietnam allowing up to 30%. Australia is similar to Mexico, Chile and Kazakhstan in permitting unlimited use12. Roughly 40% of existing carbon-pricing schemes permit the use of offsets to meet mitigation obligations, whereas 60% do not allow for offsets13. It is notable that countries that are leaders in\n\n9 DCCEEW, Australia’s emissions projections 2024, available at https://www.dcceew.gov.au/climate- change/publications/australias-emissions-projections-2024\n10 Macintosh et al, Carbon credits are failing to help with climate change- here’s why, Nature.com, October 2025, available at https://www.nature.com/articles/d41586-025-03313-z\n11 Macintosh et al, Carbon credits are failing to help with climate change- here’s why, Nature.com, October 2025, available at https://www.nature.com/articles/d41586-025-03313-z\n12 Macintosh et al, Carbon credits are failing to help with climate change- here’s why, Nature.com, October 2025, available at https://www.nature.com/articles/d41586-025-03313-z\n13 Macintosh et al, Carbon credits are failing to help with climate change- here’s why, Nature.com, October 2025, available at https://www.nature.com/articles/d41586-025-03313-z\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 3 of 9\nemission reduction, such as the UK, have chosen not to use offsets on the repeated advice of their Climate\nChange Committee, most recently last year14.\n\nOn 27 November 2025 the Clean Energy Regulator (CER) released its 2024-2025 Safeguard Preliminary\nInsights. A key takeaway from these insights is that as the SGM baselines have declined, many facilities have not yet begun to invest in abatement technologies to reduce their onsite emissions. There is an overwhelming and continuing reliance on ACCU and SMC surrender to meet compliance obligations in the SGM, despite a\n15.7% reduction in SMC generation due to declining baselines15.\n\nFortescue strongly encourages the CCA and the Commonwealth Government to prioritise the Mitigation\nHierarchy recognised under the Science Based Targets Initiative (SBTi) when considering the use of ACCUs in emission reduction policy design. The Mitigation Hierarchy is the core principle underpinning SBTi Net-\nZero Standard. It dictates the order of priority for a company's climate action, ensuring that the majority\n(>90%) of reductions in Scope 1 and 2 emissions occur without offsets. Carbon removals are permitted for\n“residual” emissions totalling less than 10% of the total reduction.\n\nThe need for such a limit on offset use is further evidenced by the SGM data that is available on the CER website. Within the 2023-2024 data, there are 18 entities that submitted letters to the CER noting that their\nACCU usage had exceeded 30% of their above baseline liability (it is a legal requirement to submit this notice). It is unclear, for these 18 entities, to what extent ACCUs were relied on beyond the disclosed 30%.\nA brief review of these notes finds that the predominant reason for ACCU reliance was the perception that genuine decarbonisation was challenging commercially. However, as Fortescue’s own progress already demonstrates, commercial solutions to decarbonise industry already exist – they are simply unattractive because a far cheaper, ineffective option remains on the table, namely low-cost, ~$37 per tonne ACCUs.\n\nFortescue believes the SGM must be changed to restrict the usage of ACCUs. At the same time, there must be a material increase in the prices companies pay for their offsets so that abatement activities are prioritised over acquiring ACCUs. There are a number of options for restricting the usage of offsets beginning with an approach aligned with the SBTi of no more than 10% of facility emissions. One approach may be to start with a cap on ACCU usage at the 30% level that currently requires companies to provide an explanatory statement to the CER. This could be reduced over the space of 2-3 years to meet the SBTi limit of no more than 10% of facility emissions.\n\nIt is essential to modify the economic assessment SGM facilities undertake when considering investment in new technologies. Currently, with the ACCU price at approximately $37, it is much cheaper to acquire ACCUs than conduct capital-intensive technology upgrades at facilities. In the vast majority of cases, proven technologies based on battery electric systems already exist and can be deployed rapidly with the right incentives. It is also worth noting that the SGM design includes a cost containment mechanism ($82.68 in\n\n14https://www.theccc.org.uk/wp-content/uploads/2025/06/Letter-to-Minister-Jones-MP-10-June-2025-1.pdf\n15CER, 2024-2025 preliminary safeguard insights, November 2025 available at 2024–25 safeguard preliminary insights | Clean Energy Regulator\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 4 of 9\n2025-2026) ensuring that facilities have a government guaranteed alternative to investment in decarbonisation of their operations further ensuring onsite investment is discouraged.\n\nTo enhance the SGM’s effectiveness in meeting Australia’s emissions targets and noting our above concerns,\nFortescue recommends a suite of targeted reforms focusing on ACCU use, baseline settings, coverage, and the transition to a more integrated emissions trading framework.\n\n1. Rules on ACCU Use\n\n• Currently, facilities can meet 100% of their compliance obligations using ACCUs, unlike\ninternational best practice systems. It is recommended that the SGM set an initial annual cap on\nACCU use and provide a clear phase-down timeline for ACCUs to drive genuine onsite emissions\nreductions. Indeed, most successful ETS schemes have a reducing cap on the number of credits\nto drive price rises.\n\no Government may need to consider how this would impact sectors that emissions are a\nresult of a chemical process, such as cement, and therefore impossible to abate and\nprovide exemptions for these cases. This should not be extended to the fossil fuel sector.\n\n• It is recommended that the SGM set an initial annual cap on ACCU use of 30% of a facility’s\nbaseline exceedance, with a managed further reduction to <10% over the subsequent 2-3 years,\nallowing businesses time to update their business strategies.\n\n• Where companies fail to meet baselines, they should have alternative compliance pathways, such\nas investing in their own renewable energy capacity or decarbonisation investment for other\nfacilities, given documented integrity issues with carbon offsets. This will drive major investment\nby Australia’s largest emitters into the critical infrastructure required to allow Australia to meet its\nNDC. For example, in California, revenues from quarterly cap-and-trade auctions are deposited\nin the Greenhouse Gas Reduction Fund (GGRF) and the funds are allocated to climate-related\nprograms including a high-speed rail project, affordable housing and sustainable communities,\nlow carbon transit operations, forest health and wildfire prevention.\n\n2. Prioritisation of SMCs\n\n• Purchase of SMCs should be incentivised over ACCUs when available.\n\n• ACCUs should be phased out quickly once SMCs reach a critical mass, and no later than 2040.\n\nIt is important for us to acknowledge that Fortescue is currently a purchaser of ACCUs to meet our obligations under the SGM as we work to achieve our Real Zero 2030 target. It is our belief that SMCs are of higher integrity than ACCUs as they sometimes (not always) represent actual reductions in emissions made by other\nSGM participants. Our purchasing strategy therefore prioritises SMCs over ACCUs. Investing in SMCs has the potential to fund and reward companies engaging in on-site decarbonisation, driving further emissions\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 5 of 9\nreductions. In contrast, purchasing ACCUs diverts funds to external, profit-motivated projects not connected to an emitting facility. When achieved via genuine decarbonisation rather than baseline accounting, SMCs can represent in-scheme emissions cuts, making them a more direct and verifiable tool for achieving industrial climate targets under the SGM. Because SMCs have also been awarded to fossil fuel producing facilities that have not decarbonised but simply exploited baseline accounting, Fortescue has also committed to not purchase them from oil, gas and coal facilities.\n\nFortescue is also making use of the multi-year monitoring period to allow flexibility for our decarbonisation projects to take effect.\n\nThe Diesel Decarbonisation Disincentive\n\nA further difficulty for Fortescue and other large industrial companies looking to decarbonise is the impact the\nDiesel Fuel Tax Credit (DFTC) has upon investment. Under the Fuel Tax Act 2006 (Fuel Tax Act), taxes and excises on liquid fuels (including diesel and petrol), are credited back to certain business users. The rate of the fuel tax credit is currently 51.6c/L (indexed to CPI) for off road users, while heavy vehicle users on public roads receive a credit of 19.2 c/L16. Light vehicle commercial users and households receive no fuel tax credit.\n\nIn 2025-26, the federal budget forecasts fuel tax credits to cost a total of $10.805 billion17. This will increase to $13.107 billion in 2028-29, while total fuel taxes collected will rise from $27.3 billion to $30.3 billion 18.\nAccording to Treasury, the increase in fuel tax credits largely reflects an expected increase in the use of fuels that are eligible for credits19.\n\nThe mining industry – specifically metal ore miners – are the single largest industry beneficiaries of fuel tax credits. In 2023-24, 245 metal ore mining entities claimed $1.67 billion in tax credits20. The remainder of the credits are claimed by more than 180,000 individual entities. The mining industry at large (including coal) claims approximately 47 per cent of tax credits, with 19 per cent claimed by the transport, postal and warehousing industry, and 12 per cent for the agriculture, forestry and fishing industries.\n\nWithin the mining industry some large miners, like Fortescue, have announced whole or partial decarbonisation of their mining activities. However, the fuel tax credit scheme is a significant disincentive to decarbonising diesel fuel assets. This disincentive does not support the objectives of the SGM, or Australia’s goal of reaching net zero by 2050.\n\nReducing the cost of diesel for the mining industry incentivises its ongoing use and disincentivises investment in replacement technologies. Using cheap diesel dramatically impacts the internal rate of return (IRR) on any investment in decarbonisation. Figure 1 below shows a large mine consuming 150 million litres (ML) of diesel\n\n16 ATO Website Rates for fuel acquired from 4 August 2025\n17 Budget Paper No. 1 p 136\n18 Budget Paper No. 1 p 103\n19 Budget Paper No. 1 p 136\n20 Taxation statistics 2022–23 Excise and fuel schemes: Fuel tax credits scheme – claims paid, by industry2, 2006–07 to 2023–24 financial years\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 6 of 9\nper year at $1.50/L, where the DFTC provides a rebate of roughly $75 million per year (150ML at $0.5/L).\nThis means a mine investing $1.5 billion in eliminating diesel consumption loses $75 million per year from its projected savings, increasing the payback period and decreasing the IRR. This undermines the incentives in the SGM.\n\nACCUs can currently be purchased for approximately $37.00 each, while the first SMCs were issued in early\n2025 and traded at a slight discount to the ACCU spot price. This ACCU price equates to approx. 10 cents per litres of diesel consumed. In other words, the 51.6 cents per litre DFTC is approximately 5 times the cost of exceeding the emissions baseline under the SGM.\n\nThis completely undermines the SGM. For every tonne of diesel burnt over a facility’s baseline, the diesel user will pay ~$37/t while earning $191 in fuel tax credits. Put simply, that’s a ~$37t/CO2-e disincentive vs\n$191t/CO2-e incentive not to decarbonise.\n\nAs a company prioritising onsite emissions reduction, it is difficult to make investment decisions when the full context of the DFTC, ACCU and SGM policy frameworks are considered. This is clearly not the intent of the\nSGM and we strongly encourage the CCA to consider this in its advice to Government.\n\nIntegrity of offsets\n\nThe idea that emissions can be offset through projects that claim to avoid releases or to remove carbon dioxide from the atmosphere is fatally flawed due to the lack of permanence associated with nature-based\n\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 7 of 9\napproaches21. There are also issues of integrity: a 2024 meta-analysis examining some 2,300 offset projects\n— amounting to around one-fifth of all issued credits — found that less than 16% achieved the emissions reductions claimed by developers22.\n\nThe successful operation of the ACCU Scheme hinges entirely on setting a quantitative upper limit to offset use and a clear timeline for phase out. This is what is needed to ensure that investment occurs at scale and in the near-term in the two key elements – electrification and renewable energy deployment – that will underpin the economic opportunities that await Australia once it decarbonises its energy supply. The size of the opportunities was described in Fortescue and Future Group’s recent Deloitte report as part of the\nBusiness for 75 campaign23,24.There is a critical distinction between emissions avoidance and carbon drawdown, which Fortescue has raised in previous submissions to the 2022 Chubb Review of the ACCU frameworks.\n\nFortescue encourages strict integrity standards to be rigorously applied to all methodologies, new and existing, to prevent the creation of non-existent or non-additional credits. It is important the following principles are strictly adhered to25.\n\n• Additionality: The principle of additionality is a crucial component of the ACCU scheme integrity.\nHowever, assessing additionality is difficult, as it relies on comparing project outcomes against\nhypothetical 'business-as-usual' projections. Reliance on counterfactuals creates uncertainty in the\nestimate of “carbon saved” and can lead to manipulation by proponents.\n\n• Permanence: The current ACCU framework allows for projects to elect for either 25-year or 100-year\ncarbon sequestration permanence. Neither of these options represents “permanent” carbon\nsequestration, however we do note that the 25-year option includes a 20% derating for ACCU\ngeneration due to its lack of permanence. It is critical that the permanence of the sequestration is high\nintegrity and maintained to provide surety to purchasers their emissions have been appropriately\nabated. It is difficult for Government to provide this guarantee, however, and even more difficult to\nenforce over the 100-year period required, while greenhouse gas emissions remain in the atmosphere\nfor hundreds of years.\n\n21Macintosh et al, Carbon credits are failing to help with climate change- here’s why, Nature.com, October 2025, available at https://www.nature.com/articles/d41586-025-03313-z\n\n22 Probst et al. (2023). Systematic review of the actual emissions reductions of carbon offset projects across all major sectors (Working Paper). ETH Zurich Research Collection. https://doi.org/10.3929/ethz-b-000620307\n23 Australia to gain $370 billion with a 75% target https://www.fortescue.com/en/articles/australia-to-gain-370-billion- dollars-with-a-75-percent-target\n24 Business for 75 (2025) “Unlocking potential. Powering prosperity. The economic opportunity of a strong 2035 emission reduction target.” https://www.businessfor75.com.au/download/Unlocking%20potential.%20Powering%20prosperity.pdf\n25 Macintosh et al, Carbon credits are failing to help with climate change- here’s why, Nature.com, October 2025, available at https://www.nature.com/articles/d41586-025-03313-z\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 8 of 9\n• Measurement, audit and transparency: Efforts must be made to improve the accuracy of\nmeasurement for highly variable carbon sinks to ensure that verifiable accounting of emissions is\nundertaken and sold to purchasers of ACCUs. This in turn provides Government an accurate\naccounting of trajectory towards targets and builds more robust policy design to meet targets.\nTransparency within the scheme is also critical, throughout the ACCU supply chain.\n\nWithin the SGM, low-cost credits artificially depress the carbon price applied to emissions over entities baselines. According to Macintosh et al (2025), carbon pricing schemes that allow offsets have a weighted average price per carbon credit of ~US$17 whereas schemes with no offsets allowed have an average price of over US$40 per credit. This dilutes the incentive for industrial facilities to undertake physical decarbonisation and for project proponents to develop higher-quality abatement. It is abundantly clear that most ACCU purchasers are not incentivised to care about the quality of their offsets and the majority of buyers prioritise credits at the lowest cost available to them to meet SGM compliance26. It is critical that policy settings drive investment towards genuine decarbonisation; thus, Fortescue strongly recommends that companies have the opportunity, if they fail to meet baselines, to access alternative compliance pathways, such as investing in their own renewable energy capacity or decarbonisation investment for other facilities. We further note that for companies that do prioritise the integrity of ACCU acquisitions, the complexity related to carbon offsetting and the resource limitations most companies face when assessing ACCUs can make it difficult for companies to make an accurate assessment on which offset methods to favour. This is compounded by the\nGovernment recognising all ACCUs as equal in their surrender for 1 tonne of carbon abatement, removing the incentive to deeply consider the integrity of the offset acquired.\n\nGiven the extent of the gap between the scientific literature and global policy on offsets, Fortescue urges the government to consider the risk of banking on offsets to deliver emissions reductions. Global offset architecture is built on political support, not a robust scientific foundation. Australia chooses a high-risk pathway if it chooses to continue to allow unlimited offsets within its industrial carbon pricing scheme rather than prioritising policy settings that incentivise investment in genuine abatement – which in turn generates genuine economic benefits, through innovation, increased energy efficiency, new industries, new jobs in diversified fields and economic growth as traditional industries fade.\n\nThank you for the opportunity to comment on this consultation. We would welcome the opportunity to participate in a bilateral meeting with the CCA to discuss the contents of this submission. To discuss any of the issues raised in this submission or to arrange a meeting, please contact tom.parkinson@fortescue.com.\n\nYours sincerely\n\nBRONWYN GRIEVE\nDIRECTOR, GLOBAL SUSTAINABILITY AND EXTERNAL AFFAIRS\n\n26 Ibid\nEnhancing the ACCU Scheme to support Australia's 2035 emissions reduction target\nPage 9 of 9","size":337339,"redacted":[],"meta":{"name":"Fortescue.3efb5394.pdf","mime_type":"application/pdf","local_path":"files/qA86mKMLPQD-CceA1plqw0eN.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil39a62423a1b7c21350b42":{"id":"fil39a62423a1b7c21350b42","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Fortescue_submission_CCA_Enhancing_the_ACCU_Scheme_to_support_Australia_s_2035_emissions_reduction_target.4cb10756.pdf","filename":"Fortescue submission CCA Enhancing the ACCU Scheme to support Australia's 2035 emissions reduction target.pdf","transcribed":null,"size":359637,"redacted":[],"config":{}}}}}