{"data":{"id":"sbm39b5b92ffc2353a7111a9","short_id":85,"created":"2025-12-15T01:29:41.116Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Belinda Wood","name-of-organisa_9974be":"Corporate Carbon","published-upload_e99675":"fil3b79303a9c10acf2c423a"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b79303a9c10acf2c423a":{"id":"fil3b79303a9c10acf2c423a","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Corporate_Carbon.01341f89.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Corporate_Carbon.01341f89.pdf","filename":"Corporate Carbon.pdf","transcribed":"Monday 8 December 2025\nMr Brad Archer\nCEO Climate Change Authority\nGPO Box 3090\nCanberra ACT 2601\nVia on-line portal\nDear Brad,\nConsultation on 2026 ACCU Scheme Review\nThank you for the opportunity to provide input into the Climate Change Authority’s 2026 ACCU Scheme Review. We are pleased to contribute to the Climate Change Authority’s important work in ensuring Australia’s climate policies remain fit for purpose.\nAs one of Australia’s leading carbon market participants, we have extensive experience in designing, developing, owning, registering, managing and delivering Australian Carbon Credit Unit (ACCU) projects.\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 Mechanism provides the demand driver for emissions reductions\n– ACCU Scheme provides the supply of high-integrity, flexible, and cost-effective abatement.\n\nFor Australia to achieve its Net Zero goals, it must maintain and expand a thriving ACCU market that is accessible, diverse, and scalable.\nFurther details on suggested mechanisms to support and enable an effective ACCU Scheme are provided in this submission. We are also happy to provide any additional 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\nExecutive 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\nCLIMATE CHANGE AUTHORITY 2026 ACCU SCHEME REVIEW\n\n1 Executive Summary\nCorporate Carbon welcomes the opportunity to contribute to the Climate Change Authority’s 2026 Review.\nAs Australia’s only large-scale, multi-sector carbon project developer, owner and operator, with a portfolio spanning over 100 projects and 1.4 million hectares of land management, we offer a practical, commercially grounded perspective on the ACCU Scheme’s operation.\n\nOur Assessment: The Government has rightly framed Net Zero as Australia's essential future economic opportunity. We contend that the ACCU Scheme is the central engine of this opportunity; it is industrial and economic policy as much as it is environmental policy. However, the Scheme is currently not on track to deliver the volume of abatement required for the 2035 targets due to a systemic misalignment between policy, administration and commercial realities.\n\nWhile the integrity of the scheme was reinforced by the Chubb Review, a new crisis has emerged: a systemic failure in method development velocity. Since the transfer of method development functions from Clean\nEnergy Regulator to Department of Climate Change, Energy, the Environment and Water (DCCEEW), we have observed a deterioration in process efficiency and a lack of commercial insight that borders on being anti- business.\n\nOur Recommendation: To unlock gigatonne-scale abatement, the governance of the scheme must be realigned with its economic importance. Corporate Carbon proposes a National Net Zero ACCU Method\nDelivery Framework, underpinned by sectoral participation targets, statutory timelines, parallel processing and crucially, a shift in oversight to an agency with the commercial mandate to deliver economic transformation.\n\nComplementing this framework, the review must address the critical issue of market dynamics by endorsing a pathway to global trade. We recommend the Government embrace Article 6 of the Paris Agreement to establish a robust price signal, transforming carbon abatement into a major export industry that drives regional growth and incentivises deep industrial decarbonisation.\n\n2 The Case for Reform: Method Delays are Stalling Investment\nAustralia’s 2035 commitment requires a rapid scaling of ACCU supply. However, the gap between ACCU\nScheme policy ambition and administrative reality is widening.\n\n2.1 The Complexity of \"Hard Policy\"\nDelivering a functional carbon market is significantly harder than other environmental market based instruments, such as the Renewable Energy Target (RET). While the RET relied on relatively static targets, the\nACCU Scheme requires frequent, fine-grained adjustments to methodologies to reflect science, technology and market conditions.\n\nThis complexity demands an agile, commercially literate administrator. Instead, the current sequential, linear\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\nproject management approach to method development—characterised by opaque timelines and sequential bottlenecks—has created an investment freeze.\n• Savanna Fire Management (SFM): The new SFM method was critical for unlocking sequestration\npotential in Northern Australia. Industry planned for a late 2022 finalisation. The recent advice from\nDCCEEW that delayed ERAC consideration until early 2026, after four years of review, jeopardises live\ninvestment decisions approach worth over $100 million.\n• Integrated Farm and Land Management (IFLM): The conflation of an updated Human-Inducted\nregeneration (HIR) methodology into a poorly thought through ‘omnibus’ method (akin to writing all\nAustralian Standards into one giant standard), has meant that there has been no replacement of a HIR\nmethodology since sunsetting on 1 October 2023. The lack of a replacement HIR Method has stalled a\nlarge segment of development opportunity\n• Periodic Review of the Soil Carbon Method: The review of the Soil Carbon Method was announced on\n28 February 2025, with a timeframe of finalisation by June 2025. At the time of this submission, this\nreview is still ongoing, creating regulatory uncertainty for the one method that offers the greatest\namount of participation in the Agricultural sector. Given the sudden suspension of the Beef Herd\nMethod late in 2024, this regulatory uncertainty has effectively made soil carbon un-investable.\n•\n\n2.2 Administrative Disconnect and Governance Failure\nThere are significant organisational impediments within DCCEEW that prevent effective governance of the\nACCU Scheme. Since responsibility for method development returned to the Department from the Clean\nEnergy Regulator, the process has visibly deteriorated.\n\nWe observe a profound lack of commercial insight within the Department, manifesting in an administrative culture that appears misaligned with, or even hostile to, business realities. This is illustrated by:\n• Failure to Implement Review Recommendations: There is an ongoing failure to complete the\nimplementation of recommendations from the Chubb Review and the 2023 CCA Review, leaving the\nmarket in a state of prolonged transition.\n• Process Deterioration: The method development process has become slower, less transparent and\nmore bureaucratic than under the previous regime. The inability to deliver timely technical updates\nacts as a brake on national decarbonisation. This deterioration is most acute in the development of the\nSFM and HIR Replacement (IFLM) methods, where the Department has maintained tight centralised\ncontrol. However, delays are also evident in the new proponent-led process, where DCCEEW has\neffectively reasserted control by acting as the gatekeeper, selecting which methods advance rather\nthan allowing a true proponent-led approach.\n• Absence of Accountability on Timelines: There is currently no accountability for missed deadlines by\nDCCEEW. Committed timelines are routinely missed without explanation or consequence, shifting\nregulatory risk entirely onto industry proponents who have deployed capital based on government\nannouncements.\nMethods are not just technical documents; they are market signals. They tell the economy where to deploy\n2\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\ncapital to reduce national emissions. When methods stall, the signal fails and capital moves elsewhere creating a lost decarbonisation opportunity.\n\n2.3 Governance Failures: The Permanent Exit Arrangement\nA stark example of the Department's anti-business posture is the handling of the Permanent Exit\nArrangement for fixed delivery Carbon Abatement Contracts (CACs). This significant market intervention was developed unilaterally, without meaningful industry consultation, regulatory impact assessment or acknowledgement of the effect of government changes to increase costs of project operation, restrict project performance (less ACCUs) and delay opportunities for new project development.\n\nRepeated approaches by industry bodies and CAC holders to discuss alternative, more equitable transition mechanisms were summarily ignored. Instead, DCCEEW imposed a heavy-handed, non-negotiable framework that disregards commercial realities and the good-faith investments made by early movers. The execution of this policy suggests a regulator intent not on supporting the industry's pioneers, but on actively undermining the value of their early-stage risk capital. This approach destroys trust and signals to future investors that sovereign risk is a material concern in the Australian carbon market.\n\n3 Focus Area 1: Recommendation for a National Net Zero ACCU Method Delivery\nFramework\nCorporate Carbon recommends the Authority advise the Government to establish a nation-wide statutory framework to ensure rapid, predictable method development. This framework must move beyond vague commitments to actionable performance management.\n\nTo ensure effectiveness, this statutory framework should be underpinned by detailed participation targets.\nThese targets should be sector-specific (for example Agriculture, Industrial Processes, Savanna Fire\nManagement) and designed to measure the actual uptake of methods by industry. Performance against these targets, not just administrative milestones, should be regularly measured and reported to Parliament.\nA method that exists on paper but fails to attract participation is a policy failure and regular reporting against uptake targets will enforce accountability for delivering commercially viable methods.\n\nThe solution involves seven actionable steps to transition method development from a bureaucratic process to a performance-based delivery system.\n\n3.1 Step 1: Method Assessment\nThe performance of existing and new methods must be assessed against two critical criteria: integrity and uptake. A high-integrity method with no uptake delivers zero abatement and is therefore of no value to the\nCommonwealth. Future method reviews must weigh commercial viability and barriers to entry equally with integrity considerations to ensuring the scheme delivers actual environmental outcomes rather than theoretical perfection.\n\n3.2 Step 2: Establish Statutory Timeframes\nWe recommend mandatory time limits for each stage of method development (Scoping → Drafting →\nConsultation → ERAC Review → Ministerial Approval).\n3\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\n• Mechanism: \"Stop-the-clock\" provisions should only be available in extraordinary technical\ncircumstances.\n• Accountability: Compliance with these timelines must be reported in CER and DCCEEW Annual Reports.\n\n3.3 Step 3: Method Development Acceleration Fund\nA dedicated, ring-fenced appropriation is required to enable the administrator to dynamically scale technical resourcing. This fund would target:\n• Expiring methods (continuity risk).\n• High-demand sectors (e.g., Agriculture/HIR 2.0).\n• High-opportunity regions (e.g., Northern Australia).\n\n3.4 Step 4: Enable Parallel Governance Pathways\nThe current sequential (\"waterfall\") process is obsolete. We propose a parallel processing model:\n• Eliminate Top-Down Prioritisation: There should be no centralised or political \"picking of winners\"\nregarding which methods are developed. Instead, any proposed method that demonstrates it meets\nthe scheme requirements (integrity and uptake) should be automatically allowed to proceed to\ndevelopment.\n• Early Industry Drafting: Allow qualified industry technical working groups to draft method modules\nconcurrently with government scoping.\n• Real-time Review: Move ERAC review from a \"final gate\" to an iterative process.\n• Defined Escalation: Create a clear pathway for technical disputes to be resolved quickly by\nindependent experts.\n\n3.5 Step 5: Technology Enabled Proponent-Led Methods (New Initiative)\nThe proponent-led method process is currently resource-intensive and slow. Corporate Carbon proposes the integration of new information technology (in the form of Artificial Intelligence) into the method drafting and triage phase.\n\n• Concept: A government-sanctioned \"Method Sandbox\" where proponents can use fine-tuned Large\nLanguage Models (LLMs) trained on existing legislative instruments and Offsets Integrity Standards\n(OIS) to test and develop method concepts.\n• Benefit: This tool would allow proponents to draft method modules that are \"pre-validated\" for\nlegislative consistency, reducing the drafting burden on the Department by up to 60%.\n\n3.6 Step 6: Transparency & Accountability Package\nThe \"black box\" of method development must end. We call for:\n• Public Gantt charts for all active methods, updated monthly.\n• Publication of specific ERAC questions and proponent/department responses.\n4\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\n• Clear, public articulation of reasons for any timeline deviation.\n\n3.7 Step 7: Institutional Realignment\nGiven the demonstrated impediments within DCCEEW, Corporate Carbon recommends that oversight of the\nACCU Scheme be moved to an agency with a stronger commercial and industrial focus.\n\nThe ACCU Scheme is a driver of economic transformation. Its governance belongs within the Department of\nIndustry, Science and Resources, or preferably, a separate independent statutory body modelled on the\nAustralian Energy Market Commission (AEMC). This would ensure the scheme is managed with the rigorous, market-focused discipline required to deliver Net Zero as an economic opportunity.\n\n4 Focus Area 2: Market Dynamics and the Global Export Opportunity\nThe Issues Paper rightly identifies market dynamics as a critical focus area. Corporate Carbon contends that the market must be managed to deliver a robust price signal that incentivises both the development of new high-integrity projects and deep on-site emissions reductions.\n\n4.1 The Necessity of a Strong Price Signal\nTo achieve the 2035 targets, the ACCU price must reflect the true cost of abatement and the value of co- benefits. A suppressed or artificially capped price signal discourages investment in \"hard-to-abate\" sectors and delays the deployment of emerging technologies like Direct Air Capture (DAC).\n\nThe market requires a signal strong enough to:\n• Unlock Capital: Make new, high-integrity supply projects bankable.\n• Drive Innovation: Incentivise industrial facilities to invest in on-site decarbonisation technology by\nusing the ACCU cost curve as their own internal price of carbon.\n\n4.2 Article 6: Building Australia’s Next Export Industry\nThe most effective mechanism to ensure this price signal, and to align the ACCU Scheme with Australia’s economic policy, is to fully embrace global carbon trade through Article 6 of the Paris Agreement.\n\nWe must reframe the export of ACCUs not as \"losing abatement,\" but as building a new export industry.\nJust as Australia has been a global leader in the export of energy and resources, we have the comparative advantage (land mass, renewable energy potential, geological storage) to become a global leader in the export of high-integrity carbon abatement and removals.\n\nAllowing the export of ACCUs to meet international demand (e.g., CORSIA, international corporate voluntary markets, and partner nations) will:\n• Deepen Liquidity: Connect the Australian market to global capital pools, reducing volatility.\n• Scale Supply: Provide the demand certainty required to underwrite gigatonne-scale projects that the\ndomestic market alone cannot support.\n5\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\n• Drive Regional Growth: Channel international climate finance into regional and Indigenous\ncommunities, particularly in Northern Australia (via Savanna Fire Management) and agricultural\nregions.\n\n4.3 Governance Implications: DCCEEW is Not Fit-for-Purpose\nManaging a global export industry requires sophisticated commercial trade policy, international market negotiation skills and a deep understanding of commodity market dynamics.\n\nThis reinforces our assessment that DCCEEW is not the appropriate body to administer the ACCU Scheme.\nThe Department lacks the commercial DNA to manage a complex financial market and an emerging export industry. The administration of this scheme requires the trade and industrial expertise found in the\nDepartment of Industry, Science and Resources or a specialised statutory authority. Continuing to house this economic engine within an environmental regulator risks stifling Australia’s potential to become a carbon trading superpower.\n\n5 Response to Specific Issues Paper Questions\n\n5.1 Q: What are the correct policy settings that could allow industry innovation to develop new\nabatement opportunities?\n\nCorporate Carbon submits that the question originally posed in the Issues Paper, asking for a list of\n\"potential new methods\", illustrates a disconnect with the practicalities of ACCU Scheme administration.\nCCA should not be asking DCCEEW to pick winners, but rather what policy settings will empower industry to solve the abatement challenge.\n\nThe correct policy setting is a market-led, technology-neutral framework. If a proponent can demonstrate that an activity meets the Offsets Integrity Standards (OIS) Assessment Criteria and has commercial uptake, it should be allowed to proceed without bureaucratic pre-selection.\n\nCorrect policy settings would naturally unlock innovation in:\n• Method Integration: By removing top-down restrictions on activity stacking, a plug-and-play approach\nwould allow landholders to optimise for their specific landscape with as many projects and methods as\nthey would like to implement under a ‘one farm one audit’ approach.\n• Technology-Neutral Engineered Removals: By establishing a high-level \"Carbon Removal\" standard\nthat allows any technology (including Direct Air Capture) to generate credits if it meets robust\nmeasurement and verification criteria, rather than waiting for technology-specific method writing.\n• Savanna Fire Management: By allowing the sector to drive the integration of sequestration and\navoidance based on practical fire management data, rather than theoretical models alone.\n\n6\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\n5.2 Q: Do the rules on permanence and crediting periods get the balance right between integrity\nand project viability?\n\nCorporate Carbon considers the current permanence period settings and the associated discount to be adequate.\n\n• Permanence Settings are Appropriate:\nWe support the current framework that allows project proponents to choose between 25-year and 100-\nyear permanence periods. This flexibility is essential for broad participation, particularly in the\nagricultural sector where intergenerational planning horizons vary. We believe the current discount\napplied to 25-year projects is an adequate reflection of the scheme’s integrity principles and provides\nsufficient stability for investment decisions. Note that we recommend the flexibility to change between\n25 and 100 year and 100 year and 25 year, with appropriate increase/decrease in ACCU balances to\nbuild flexibility and increase participation.\n• Crediting Periods for High-CapEx Projects:\nWhile current settings are adequate for land-sector methodologies, emerging technologies like Direct\nAir Capture (DAC) may require review. We recommend allowing for flexible crediting periods (up to 50\nyears) for high-capital-expenditure projects to align with infrastructure lifecycles.\n\n5.3 Q: How fair and accessible is the scheme, considering the treatment of different sectors,\nbarriers to participation and access to benefits?\n\nThe primary barrier to fairness and accessibility in the scheme is that DCCEEW is not an optimal fit as\nScheme administrator. DCCEEW consistently demonstrate a lack of sensitivity to the commercial realities faced by businesses participating in the scheme.\n\nFairness requires an administrator that understands the practical constraints of landholders, businesses, and regional communities. Instead, the current administrative culture within DCCEEW is characterised by distance, opacity and a lack of urgency that disproportionately impacts those without the resources to navigate complex bureaucratic mazes.\n\nSpecific barriers to fairness include:\n• Administrative Distance: The centralisation of method development in Canberra has created a \"design\nvacuum.\" Methods are drafted by policymakers who lack practical understanding of land management,\nresulting in rules that are technically compliant but operationally unworkable.\n• The \"Black Box\" of Decision Making: Accessibility is severely compromised by the lack of transparency\nin method development. Regional stakeholders and Indigenous groups often invest significant\nresources in consultation, only for the process to disappear into the Department for years without\nfeedback or progress updates. This erodes trust and discriminates against smaller participants who\ncannot afford to sustain engagement over indefinite timelines.\n• Governance Failure: As noted in Section 2.2, the failure to implement review recommendations and\nthe deterioration of process efficiency since functions were transferred to DCCEEW signal a\n\n7\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\nadministrator that is struggling with its mandate. This creates a scheme that is \"accessible\" only in\ntheory, but in practice is mired in delays that lock out new participants.\nTrue fairness and accessibility will only be achieved when the scheme is administered by an agency that understands commercial drivers and views participants as partners in national decarbonisation, rather than subjects of regulation.\n\n5.3.1 Q: Are there any other ways that the ACCU Scheme could be improved?\n\nRecognise and Reinforce the Performance of the Clean Energy Regulator.\n\nOne of the most effective ways to improve the scheme is to properly resource and empower the agencies that are performing well. We highlight the strong operational performance of the Clean Energy Regulator\n(CER). While the Chubb Review recommended removing certain policy functions from the CER to separate powers, subsequent events have underscored the Regulator’s capability. The CER has consistently demonstrated a practical, implementation-focused approach to administering the scheme, in stark contrast to the policy paralysis observed elsewhere.\n\nImproving the scheme requires leveraging this capability. We recommend that the Government ensures the\nCER retains full operational autonomy for scheme administration and is not further burdened by upstream policy indecision. A high-performing regulator is the bedrock of market confidence; diminishing its role or resources would be a strategic error.\n\nMove away from Qualified and toward Quantification of Offsets Integrity Standards\n\nSupporting an increased method development velocity needs greater guidance around Offsets Integrity\nStandards that can be achieved by moving away from the current opaque and qualitative process employed by ERAC and toward a transparent and quantitative framework that standardises method assessment and provides a continuous improvement approach to quality.\n\nFor example, the suspension of the Beef Herd Management method caused an industry uproar (see especially comments from Cattle Australia). The suspension would never have happened if a quantitative assessment of integrity had been part of ERAC’s process. ERAC published an Information Paper in 2021 that set out how they interpret Offsets Integrity Standards. There are 23 Offsets Integrity Assessment Criteria buried in this document. This provides useful insights into the factors that build up into an integrity assessment. The challenge is that the Assessment Criteria are qualitative and open to interpretation.\n\nWe ran a quantitative assessment of the Beef Herd Method which demonstrates that the Method would likely not have been suspended if ERAC had to justify their decision on quantitative grounds, in addition to providing an impact assessment of the decisions they make. The ACCU Scheme needs this type of approach to assist with the efficient administration of the market.\n\n8\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\n6 Conclusion\nThe ACCU Scheme is a national asset, but it is currently constrained by an administrative structure that lacks commercial capability. A scheme that cannot develop methods at the speed of business is a scheme that will fail the 2035 targets.\n\nBy adopting the National Net Zero ACCU Method Delivery Framework and realigning governance to a commercially capable body, the Government can restore investor confidence, unlock stalled capital and ensure the ACCU Scheme drives the gigatonne-scale abatement Australia needs.\n\n9\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":604991,"redacted":[],"meta":{"name":"Corporate_Carbon.01341f89.pdf","mime_type":"application/pdf","local_path":"files/0JES8V79QPcirRtJP_bMlKFm.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil39b5b904a621759a34e59":{"id":"fil39b5b904a621759a34e59","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/251215_CCG_submission_to_CCA_2026_ACCU_Scheme_Review_FINAL_WITH_COVER_LETTER.9735ad67.pdf","filename":"251215 CCG submission to CCA 2026 ACCU Scheme Review - FINAL WITH COVER LETTER.pdf","transcribed":null,"size":751111,"redacted":[],"config":{}}}}}