{"data":{"id":"sbm39b69b72de23940ededec","short_id":92,"created":"2025-12-15T05:36:49.374Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Jenny Samiec","name-of-organisa_9974be":"Woodside Energy","published-upload_e99675":"fil3b7930d766a02508d182f"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b7930d766a02508d182f":{"id":"fil3b7930d766a02508d182f","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Woodside.5bcec440.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Woodside.5bcec440.pdf","filename":"Woodside.pdf","transcribed":"Please direct all responses/queries to:\nJason Greenwald\nVice President Carbon Solutions\n\nWoodside Energy Group Ltd\nACN 004 898 962\nMia Yellagonga\n11 Mount Street\nPerth WA 6000\nAustralia\nT: +61 8 9348 4000\nwww.woodside.com\n\n15 December 2025\n\nClimate Change Authority\nGPO Box 2013\nCanberra ACT 2601\n\nDear Review Team\n\nWOODSIDE SUBMISSION TO THE 2026 REVIEW OF THE ACCU SCHEME\n\nWoodside Energy welcomes the opportunity to comment on the Climate Change Authority’s (CCA) fifth review of the\nAustralian Carbon Credit Unit (ACCU) Scheme. In addition to this submission, as a member of the Australian Energy\nProducers, the Australian Industry Greenhouse Network, the Chamber of Minerals and Energy of Western Australia and the Business Council of Australia, we also draw your attention to their respective submissions.\n\nWoodside is a global energy company founded in Australia, providing reliable and affordable energy to help people lead better lives. Driven by a spirit of innovation and determination, we established the liquefied natural gas (LNG) industry in Australia 35 years ago and today supply a growing base of customers. We have reliably delivered natural gas to homes and businesses in Australia for decades, supporting the development of local industry and driving economic prosperity.\n\nWoodside has made substantial investments in the ACCU market, reflecting our ongoing commitment to supporting carbon abatement initiatives and ensuring compliance with our regulatory requirements as the operator of, and equity owner in, multiple Safeguard Mechanism (SGM) facilities. These investments encompass both the development of our own ACCU projects and the acquisition of credits from various ACCU market participants. Woodside expects to continue to be a significant participant in the ACCU market through to 2030 and beyond.\n\nIn this submission, Woodside recommends that the Government should:\n\n- Use evidence from real industry decarbonisation opportunity planning, rather than scenario-based trendlines,\nto assess future ACCU supply and demand and guide policy decisions.\n- Improve the process to develop new methods quickly and allow international offsets for SGM compliance,\nbecause both are a priority to improve liquidity and avoid shortages.\n- Increase transparency and information sharing in the ACCU scheme to build confidence in using ACCUs for\ndecarbonisation.\n\nWoodside’s detailed comments to the CCA’s ACCU scheme review are outlined in Attachment 1.\n\nWoodside would welcome the opportunity to meet with the CCA to discuss the feedback in this submission.\n\nYours sincerely,\n\nTony Cudmore\nExecutive Vice President – Sustainability, Policy & External Affairs\nAttachment 1: Issues Paper Response\n\nPreamble: Importance of the ACCU scheme, challenges of large-scale decarbonisation on ACCU supply\nand demand\n\nRecognition of the importance of the ACCU scheme\n\nThe ACCU scheme provides essential support to the SGM and its role in helping meet Australia’s Nationally\nDetermined Contribution to the Paris Agreement. It provides an essential mechanism for facilities to supplement their\non-site decarbonisation options and facilitates investment flows to the most cost-effective opportunities for\ncompliance.\n\nImproving ACCU supply and demand forecasts\n\nSustaining liquidity in the ACCU market through the introduction of new methodologies and clear forward demand\nsignals is vital to the continued effectiveness of both the ACCU scheme and the SGM. In order to achieve this, it is\nimportant that the Government receives comprehensive and accurate information regarding expected future supply\nand demand.\n\nKey factors that may impact future demand include the scale and timing of decarbonisation initiatives at SGM facilities,\nwhilst supply is impacted by forward ACCU yields from sunsetted, active and emerging methods. Assessment of\nACCU demand would be improved if it were based on evidence from industry’s actual plans, rather than the\nextrapolation of scenario-based trendlines. This can be achieved by facility-by-facility level consultation to obtain\nreliable data. A model for this exists in the Australian Energy Market Operator’s (AEMO) equivalents for gas and\nelectricity, which enables both suppliers and users to confidentially provide planning data that can be aggregated into\nforecasts. AEMO prepares two Statement of Opportunities (SOO) - one for electricity (power) and the other for gas.\nThese SOOs provide long term (10-20 year) forecasts and assessments intended to guide investment and policy\ndecisions across Australia’s energy systems.\n\nDemand and decarbonisation rates\n\nAssessment of ACCU demand is important due to the ambitious nature of the SGM which requires rapid and\naccelerating annual decarbonisation rates. Importantly, the SGM does not apply a fixed 4.9% year-on-year decline,\nbut rather a straight-line annual reduction of 4.9% from the initial baseline, adjusted for production. This method\nresults in a year-on-year effective decline rate that is expected to accelerate beyond 4.9%, reaching approximately\n6.9% year-on-year by FY2030 for all facilities covered by the SGM in the economy. Conversely, the challenge to\nreduce emissions gets harder over time: the marginal abatement cost increases over time as the lowest cost\nopportunities are implemented. As such, early reductions opportunities cannot be assumed to continue to be available\non a linear annual basis.\n\nWe anticipate that Woodside's experience will be characteristic of many SGM facilities: there are initial \"low-hanging\nfruit” opportunities after which decarbonisation becomes more expensive and technically challenging. Facilities may,\nlike Woodside, find it viable to pursue abatement opportunities to achieve significant reductions – Woodside pursues\nopportunities up to US$80/tCO₂-e, 1 which is significantly higher than either the most recent generic ACCU spot price\nor the Australian Government’s cost containment measure. 2,3 We also anticipate that facilities will have further\nopportunities for which the challenges cannot be overcome at the present time, for example due to cost or technical\nchallenge. The ACCU scheme is a critical policy measure to bridge between these more challenging opportunities\nand the ambitious annual declines inherent in the SGM.\n\nFuture ACCU supply\n\nThere is significant uncertainty in relation to the future supply of ACCUs that will arise from projects utilising active,\nemerging and sunsetted methods. These include:\n\n1\nWoodside’s assumption on carbon cost pricing includes a long-term carbon price of US$80/tonne of emissions (real terms\n2024). Woodside continues to monitor the uncertainty around climate change risks and will revise carbon pricing assumptions accordingly.\n2\nBased on the most recent generic ACCU spot price $A35.45 (approximately US$23.20) on the 14 November 2025 data cut off:\nAustralian Government Clean Energy Regulator - The Quarterly Carbon Market Report – September 2025.\n3\nAn ACCU purchased under the cost containment measure in 2025–26 costs $A82.68 (approximately US$54.07): Cost containment measure | Clean Energy Regulator.\n• The impact of method changes at existing projects. For example, significant cumulative reductions in forecast\nyields for Human Induced Regeneration (HIR) projects may occur following further HIR Regeneration\nGateway Checks introduced under the Chubb Review to support increased integrity.\n• The impact of slower investment due to delays in the development of new methods, in particular in relation to\nthe types of abatement activities previously recognised under the sunsetted HIR Method.\n• The impact of recommendations that may be made by the Emissions Reduction Assurance Committee\n(ERAC).\n• Uncertainty about how quickly new methods will be deployed by industry. For example, obligations in relation\nto sequestration permanence may be a barrier to entry for potential proponents regarding Savanna Fire\nManagement.\n• Limited availability of data in relation to new and emerging methods such as Soil Carbon and Integrated Farm\nand Land Management increase forecast uncertainty.\n\nInternational carbon credits\n\nIn addition, despite the Government’s in-principle policy position in support of the use of international carbon credits\nunder Article 6 of the Paris Agreement, the necessary legislative and administrative arrangements have not been\npursued in Australia. This is lagging international progress. The Article 6 “rulebook” was finalised at COP29 in Baku\nin 2024. According to the Paris Agreement Article 6 Implementation Status Report (2025 edition), under Article 6.2\n(which facilitates bilateral agreements between countries), some 99 bilateral agreements have now been formalised\nand 61 countries are currently engaging in bilateral cooperation. In addition, under Article 6.4 which establishes an\nUN-supervised global carbon market mechanism, a total of 110 countries have submitted information to the UN about\ntheir Designated National Authorities. 4\n\nIn Woodside’s view, it is time for Australia to adopt its own Article 6 implementation. This would allow carbon credits\nto be traded internationally and to be applied across both SGM and non-SGM sectors, providing flexibility and cost-\neffective options to help achieve Australia’s national emissions reduction targets.\n\nMethodologies – New and Existing\nQuestions 1, 2 How can the development and approval of high-integrity, scalable methodologies be\n&3 accelerated?\n\nWhat are the current barriers to method development and how could they be overcome?\n\nWhat additional resources may be required to deliver the methods faster? How can\ntransparency of method development and projects be improved?\n\nWoodside The development of new methods or the extension of existing methods could be accelerated by\nResponse the following:\n\ni) Leveraging the existing pipeline of Expression of Interests (EOI)\n\nThirty-nine EOIs to develop new ACCU methods were submitted in July 2024. The ERAC\nassessed each EOI’s alignment with the Offsets Integrity Standards and triage criteria.\nWoodside recommends:\n\n• A secondary review is undertaken with support from additional scientific and economic\nsubject matter expertise to confirm the identified prioritisation.\n• Increasing the number of methods under consultation. As method development\nrequires significant lead time, running more method consultations in tandem will allow\nappropriate time for consultation and reduce the potential for “bottlenecking” if the\ncurrent “priority methods” encounter unexpected delays.\n\nii) Improving governance and transparency\n\nWoodside supports publication of:\n\n• Up-to-date information on target timelines and consultation events per method; and\n• Quarterly reports on key outstanding issues in relation to each method’s\ndevelopment which identify issues to be resolved and research or other support\nrequired.\n\niii) Implementing recommendations from previous consultations and reviews\n\n4\nArticle 6 Implementation Partnership. https://a6partnership.org/a6-implementation-status/current-developments-in-bilateral- cooperation-and-article-6-4-mechanism.\nThe Chubb Review concluded that a new entity should be established to replace the\nERAC, with a revised structure and support framework, and primary responsibility for\nensuring method integrity. It recommended naming this organisation the Carbon\nAbatement Integrity Committee (CAIC).\n\nThe Government should proceed with implementing this recommendation without delay to\nuphold the integrity and effectiveness of the scheme.\n\niv) Early alignment with Offset Integrity Standards\n\nUnder the Carbon Credits (Carbon Farming Initiative) Act 2011 (Cth), prior to deciding on\na methodology, the Minister must seek advice from the ERAC. The ERAC must provide the\nrequested advice to the Minister, taking into consideration offsets integrity standards and\nany other legislated requirements.\n\nThe Department of Climate Change, Energy, the Environment and Water (DCCEEW) could\nassist this process by playing a more active role by providing early feedback on draft\nmethods to proponents and stakeholders regarding alignment with offsets integrity\nstandards.\n\nIn instances where consultation stalls because stakeholders could not reach consensus,\nconsideration should be given to whether DCCEEW could play a larger role by providing a\ncasting vote or informed opinion, rather than pursuing a consensus position.\n\nQuestion 4 What potential new methods or refinements to existing methods could unlock significant\nnew abatement?\n\nWoodside Leveraging the existing pipeline of EOIs\nResponse\nWoodside refers to its answer to Question 2 above. The Government should consider developing\nand finalising additional methods identified under the proponent-led EOI process in 2024. Of the\n39 methods submitted in July 2024, only four were selected in October 2024 for further\ndevelopment. Since the 2022 Chubb Review, no substantively new method determinations have\nbeen made – the Environmental & Mallee method determination 5 was “a remake of the 2014\nmethod 6 with changes improving ACCU Scheme integrity and ease of use.” 7 The Landfill Gas\nmethod determination made in November 2025, 8 whilst significant, is a replacement of the 2015\nand 2021 Landfill Gas methods. 9\n\nRefine assessment processes and provide faster opportunities for reassessment\n\nWoodside’s participation in the 2024 EOI process for a Great Western Woodlands Fire\nManagement Method provided us with firsthand experience of opportunities to improve the process\nand unlock new abatement methods. Woodside notes that:\n\n• There was insufficient notice provided for the EOI process and a short submission timeframe.\nThis restricted proponents’ ability to develop detailed submissions.\n• Subsequent to this EOI, the method has continued to progress, and Woodside would like to\nsee it reassessed (see further response to Question 1 above).\n\nMaintaining Safeguard Mechanism Credits post-2030\n\nWoodside supports the generation of SGM credits beyond 2030 to maintain flexible compliance\narrangements and provide financial incentives for facilities to invest in lowest cost abatement.\n\nInternational carbon markets access (Article 6)\n\n5\nCarbon Credits (Carbon Farming Initiative) (Reforestation by Environmental or Mallee Plantings—FullCAM) Methodology\nDetermination 2024.\n6\nCarbon Credits (Carbon Farming Initiative) (Reforestation by Environmental or Mallee Plantings—FullCAM) Methodology\nDetermination 2014.\n7 Extract from CER website - Reforestation by Environmental or Mallee Plantings - FullCAM 2024 method - DCCEEW.\n8 Carbon Credits (Carbon Farming Initiative-Reducing Methane Emissions from Landfill Gas) Methodology Determination 2025.\n9 Carbon Credits (Carbon Farming Initiative – Landfill Gas) Methodology Determination 2015; Carbon Credits (Carbon Farming\nInitiative – Electricity Generation from Landfill Gas) Methodology Determination 2021.\nSee Preamble above.\n\nQuestion 5 Do the rules on permanence and crediting periods get the balance right between integrity\nand project viability?\n\nWoodside Nil response.\nResponse\n\nACCU Market Dynamics\nQuestion 6 How can the right price signals be established to incentivise high-quality abatement?\n\nWoodside Price signals should incentivise sufficient new supply over at least a 5-year period (reflective of the\nResponse time required to develop new supply) to avoid volatility.\n\nPrice signals should be market-led. Key factors which incentivise investment in ACCU projects\ninclude efficiency, transparency, stability and fairness in the ACCU scheme. Key enablers of market\ntransparency and stability include:\n\ni) Timely, accurate information to inform supply and demand analysis (see Preamble above).\nii) Project level transparency to incentivise high-quality abatement.\niii) Market information symmetry, in particular Carbon Abatement Contracts (CACs) and the\nvolumes of credits held in the cost containment measure.\n\nMarket information symmetry - CACs\n\nWoodside welcomes the 3 December 2025 announcement of the “new permanent fixed delivery\nexit arrangement” which aims to resolve the management of fixed delivery carbon abatement\ncontracts by providing an alternative pathway for sellers to meet their obligations.\n\nOngoing uncertainty around the future of fixed-delivery CACs, and the information asymmetry\nassociated with the exit mechanism could have undermined confidence in the ACCU market.\n\nWoodside supports:\n\ni) Public information to be updated regularly.\nii) Greater transparency on outstanding delivery volumes and timeframes.\niii) Forward notice on changes to the ACCU scheme, CAC arrangements or the exit\nmechanism where practicable.\n\nThe volumes and timing of CAC deliveries, deferrals and exits have a significant impact on market\nsupply and price signals due to the relative scale of CAC volumes. Forty-six percent of all issuances\nto date have been delivered into CACs. 10,11 The volume of ACCUs remaining under fixed CAC is\nestimated to be 84 million, more than 1.5 times the volume of ACCUs currently held in Australian\nNational Registry of Emissions Units (ANREU) accounts as at January 2025 (51.7 million\nACCUs). 12\n\nHigh quality abatement can be supported by transparency.\n\nWoodside is supportive of increasing the extent to which ACCUs are mutually interchangeable or\nfungible and does not consider that transparency will drive market stratification over the long term.\nTransparency can assist by creating a more level playing field for developers.\n\nMaintaining public confidence in the scheme’s integrity will be important to create the certainty\nrequired for industry to take long-term investment decisions. Transparency incentivises good\nconduct by developers and auditors and allows for “stakeholder regulation”.\n\n10\n174 million ACCUs have been issued under the scheme as at 30 September 2025: Emissions Reduction Fund Register\n30/9/2025 – website: ACCU project and contract register | Clean Energy Regulator.\n11\n81.7 million ACCUs have been delivered under CACs as at January 2024: Performance audit report | Auditor-\nGeneral Report No. 24 of 2023–24, para 1.6 – website: https://www.anao.gov.au/work/performance-audit/issuing-compliance- and-contracting-australian-carbon-credit-units\nNote an official breakdown between fixed delivery and optional delivery CACs has not been published.\n12\nCER Quarterly Market Report June Quarter 2025, p11 quarterly-carbon-market-report-june-quarter-2025.\nTo enhance transparency, Woodside recommends amending the legislative protected information\nobligations 13 which make project information confidential by default. Instead, key project\ninformation should be subject to public disclosure, except where the proponent establishes that\ninformation meets clear, documented criteria for it to be kept confidential (see the approach taken\nby Verra as an example 14). Transparency should extend to publishing the project related\nsubmissions required under the legislation such as offset reports, permanence plans and audits\n(including the name of the auditing company), and the publication of regulator notices issued to\nprojects for non-compliance, subject to limited exceptions.\n\nQuestion 7 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\nWoodside Woodside values the integrity measures already embedded in the ACCU scheme. We would\nResponse welcome publication of additional project level information for ACCU projects – as noted in our\nresponse to Question 6 – to further increase confidence.\n\nWoodside applies its own assessment to its carbon credits portfolio. 15 Woodside’s assessment\ntakes into consideration available information on criteria such as additionality, permanence,\nquantification accuracy, leakage mitigation, vintage, and environmental, social and governance\nissues.\n\nWoodside also subscribes to emerging independent carbon credit rating platforms to inform its\ndecision making. While Woodside forms its own independent view on its portfolio design, its\napproach is informed by current and emerging external frameworks such as the Integrity Council\nfor the Voluntary Carbon Market's (ICVCM) Core Carbon Principles, the Investor Group on Climate\nChange’s (IGCC) guidance, and the Oxford Principles for Net Zero Aligned Offsetting. Over time,\nWoodside is increasing its focus on project origination, enabling it to directly manage the integrity\nand cost of its carbon credits.\n\nQuestion 8 What role, if any, should the Government play in ACCU purchasing? Are there any\napproaches, besides direct purchase, the Government should consider to support an\norderly transition for businesses?\n\nWoodside The Government should focus on stabilising and underpinning market integrity, and ensuring that\nResponse credit supply, methodology development, and governance arrangements support a well-\nfunctioning, credible market.\n\nRather than competing with private demand, Government purchasing should be targeted to\nstrategic purposes, such as catalysing investment in innovative or early-stage abatement methods\n(which may initially have high costs), achieving co-benefits in regional or Indigenous projects, and\naddressing temporary demand shortfalls.\n\nThe Government can support an orderly and efficient transition for businesses through market\ndesign and risk mitigation measures. These include developing a forward market framework or\nofftake mechanisms to support price stability, providing concessional finance for early abatement\ninvestments, and ensuring transparent registry and data systems to enable informed decision-\nmaking.\n\nGovernment participation in the carbon market should focus on ensuring market confidence, policy\npredictability and investment certainty, to enable private markets to lead Australia’s carbon credit\ndemand in a stable and credible way.\n\n13\nSee sections 43-55 of the Clean Energy Regulator Act 2011 in relation to protected information and sections 213-215 of the\nCarbon Credits (Carbon Farming Initiative) Act 2011 in relation prohibition on disclosure and limited mandatory public disclosures.\n14\nSee 4.2.7 Verra Registration and Issuance Process, v4.6; VCS Program Definitions, v4.5.\n15\nSee Integrity assessment for carbon credits on the Scope 1 and 2 GHG Emissions page of the Woodside website.","size":339337,"redacted":[],"meta":{"name":"Woodside.5bcec440.pdf","mime_type":"application/pdf","local_path":"files/4Yrvb4tTdAsHEPmyfittTFIx.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil39b69ad6b121f0f0f2839":{"id":"fil39b69ad6b121f0f0f2839","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/Woodside_submission_CCA_ACCU_Scheme_Review_2026_15_December_2025.3c3805d1.pdf","filename":"Woodside submission - CCA ACCU Scheme Review 2026 - 15 December 2025.pdf","transcribed":null,"size":428747,"redacted":[],"config":{}}}}}