{"data":{"id":"sbm39b6bdbf50235a2f82877","short_id":93,"created":"2025-12-15T06:14:17.168Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Hugh Wareham","name-of-organisa_9974be":"GreenCollar","published-upload_e99675":"fil3b7931078ea05da2964cb"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b7931078ea05da2964cb":{"id":"fil3b7931078ea05da2964cb","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/GreenCollar.f375da82.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/GreenCollar.f375da82.pdf","filename":"GreenCollar.pdf","transcribed":"15 December 2025\n\nClimate Change Authority\nLevel 5, 7 London Circuit\nCanberra ACT 2601\nVia email: consultation@climatechangeauthority.gov.au\n\nDear Climate Change Authority,\n\nRE: Climate Change Authority: Issues Paper – Enhancing the ACCU Scheme to support Australia’s 2035\nEmissions Reduction Target\n\nGreenCollar welcomes the opportunity to make a submission to the Climate Change Authority’s 2026 ACCU\nScheme Review, which includes a review of the Credits (Carbon Farming Initiative) Act 2011 (‘CFI Act’).\n\nGreenCollar’s submission responds to all the questions from the Issues Paper as below; GreenCollar agrees to our submission being published.\n\nSection 1 – The Role of the ACCU Scheme in Meeting the 2035 Target\n\nContext:\nThe Authority is exploring how the ACCU Scheme can best support Australia’s new 2035 emissions reduction target (62–70% below 2005 levels). The review will consider how the ACCU Scheme complements the\nSafeguard Mechanism and supports efficient, equitable abatement.\n\nGreenCollar General comments:\n\nThe ACCU Scheme is foundational to achieving the 2035 target, particularly given the land sector’s significant contribution to national abatement requirements.\n\nThe Net Zero Plan and the Sector Decarbonisation Plans highlight that the land sector needs to make a disproportionately large contribution to national emissions reduction through to 2050. Nature-based sequestration will need to more than double, and an expanded ACCU Scheme is therefore critical for achieving the 2035 target. At the same time, the Safeguard Mechanism review will play a central role in driving emissions reduction across multiple sectors, making the availability of ACCUs fundamental to enabling compliance markets and providing flexibility and transition pathways.\n\nHowever, method development and project lead times mean it takes years for new supply to reach the market. Perceptions that the ACCU market is currently balanced or oversupplied appear to have influenced government resource allocation, reducing priority on method development. Without accelerated investment in method development now, it is our view that there will be a significant supply deficit relative to anticipated future demand.\n\nA national environmental markets roadmap co-designed with industry and communities would support supply growth, investment certainty and alignment with broader environmental objectives. GreenCollar supports development of a national market roadmap that grows environmental markets into a multi-billion-dollar sector based on four pillars: customers and value chains, innovation, people and communities, and capital and risk. The roadmap should be co-developed by industry, government and communities and supported by formal recognition of environmental markets within national policy frameworks.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n1\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nSection 2\n\nFocus Area 1: Methodologies (New and Existing)\n\nContext:\nThe review seeks to address slow method development and ensure methodologies are robust, transparent, scalable, and adaptable. Four methods are currently under development, with further prioritization through the new proponent-led process.\n\n1. Accelerating development and approval of new and existing methods\n\nQuestion: How can the development and approval of high-integrity, scalable methodologies be accelerated?\n\nResponse:\nMethod development is currently slow and uncertain creating significant barriers to planning, investment, market growth and impact.\n\nAccelerating method development requires structural reform, increased capability, and transparent timeframes. Resourcing must increase for both government and proponent-led method development which could include novel ways of supporting method development. For example, method development authorship incentivisation such as that observed in the voluntary market standards (a royalty for every project registered under a method). Alternatively, increased private sector involvement in method development could be incentivised by offering tax credits to method authors.\n\nProcess guidance should be expanded, and a pipeline of private-sector contributions to new method development explicitly endorsed to shorten timeframes. Government guidance such as frameworks, processes, templates and checklists would help proponents develop consistent approaches to putting forward different methods.\n\nConsideration should be given to improving the proponent-led method development process. For example, a similar approach to the Nature Repair Market could be adopted, where once a proponent-led method is selected, the Government engages several groups through an EOI process to develop the method over a defined period.\n\n2. Barriers to method development and potential solutions\n\nQuestion: What are the current barriers to method development, and how could they be overcome?\n\nAs outlined above, method development is currently slow, costly and opaque. Roles and responsibilities across agencies are not well defined, and the Stakeholder Reference Group (SRG) process is inefficient. The complexity and administrative burden of method design increases costs, deters participation and creates uncertainty. Clearer, standardised guidance would significantly reduce this burden and support more consistent and transparent development.\n\nIn addition, provision of targeted support by Government would help ensure that method development process is reflective of a range of method proponents. Please see also responses provided above and below.\n\n3. Resources, process improvements and transparency\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n2\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\n3(a) What additional resources may be required to deliver the methods faster?\n\nA predictable, well-resourced and transparent development process is essential for unlocking supply and ensuring that the ACCU Scheme can support the 2035 emissions reduction target. Scheduled reviews should enable incremental updates throughout a method’s life rather than waiting until sunset, preventing gaps where no active method is available and new projects cannot be registered.\n\nAdditional resources and process improvements should include:\n\n• Strengthening ACCU Scheme capability and technical expertise within DCCEEW and ERAC, noting\ncurrent reliance on seconded CER staff.\n• Increasing Parliamentary Counsel drafting capacity, or alternatively:\no Providing prescriptive technical guidance that enables proponents (or their legal teams) to\ndraft methods;\no Re-drafting ACCU methods in a more flexible manner, that allows updates to be implemented\nthrough regulatory guidelines without triggering the need for additional legislative drafting.\n• In lieu of newness and/or notice of intent provisions for developing methods so that pilot projects\nbeing tested during a method development phase do not end up being ineligible from being registered\nonce the method is available.\n• Establishing funding for field trials and pilot projects to test new abatement opportunities and\naccelerate evidence-gathering to support development of new methods.\n• An approach that allows small projects, that would otherwise be commercially unviable for project\ndevelopers, to be run by individual landholders and that has potential to provide scalable abatement.\n\n3(b) How can transparency of method development and projects be improved?\n\nImproved transparency is essential to strengthen market confidence, support integrity, and enable industry, landholders and investors to align projects with government expectations and realistic timelines. Greater visibility over decision-making of development prioritisation, evidence sources for eligible activities and treatment of co-benefits would significantly improve trust and efficiency. It is noted that method development is currently under an interim only set of rules, with much uncertainty on when this interim phase will conclude and be transitioned to a new permanent arrangement reflected in CFI legislation updates, if there will be any further formal expression of interest method proposal invitations, and what support the government is providing to method proponents that do have a proposal prioritised.\n\nGreenCollar recommends:\n\n• Clarity be provided on intentions for the transition out of the current interim arrangements including\nplans for the next expression of interest method proposal invitation window.\n• Clarity be provided on what support the government is intending to provide to method proponents\nwith a successful proposal to aid in resource planning.\n• Publicly disclosing method development rationale, including scientific evidence, modelling\nassumptions and approaches to measuring and validating co-benefits and non-carbon outcomes.\n• Providing transparency on how nature repair and biodiversity outcomes are considered within method\ndesign, including reasons for exclusion where relevant.\n• Consideration should be given to establishing an open evidence docket, to demonstrate what is being\nachieved by projects and enhance integrity, consistent with leading international standards such as\nVerra VCS, Gold Standard and the Integrity Council for the Voluntary Carbon Market.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n3\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\n• Improving transparency of project operations through clearer reporting expectations and accessible\npublic data.\n\n4. Potential new or refined methods\n\nQuestion: What potential new methods or refinements to existing methods could unlock significant new abatement?\n\nResponse:\nThe Government should undertake method gap analysis and set priorities based on the amounts of carbon that needs to be sequestered. We note the land/vegetation methods have historically been the largest sources of ACCU supply, but are currently experiencing a lack of in-force methods outside environmental planting and plantation forestry.\n\nSignificant additional abatement could be unlocked through improved biomass monitoring (this could also be supported through the expansion of TERN sites to include regional reference sites to determine attribution and increase integrity), enhanced carbon modelling, more flexible crediting across multiple carbon pools (for example, by enabling additional carbon pools to be added to methodologies after the initial legislative instrument has been made), and enabling aggregation of smaller properties into single projects.\n\nHybrid abatement calculation approach\nIncorporation of advancements in Above Ground Biomass (AGB) measurement via option of a measure-model- measure hybrid approach to abatement calculation within existing and new methods will facilitate uptake on the high biomass/high diversity/high rainfall regions where projects are small, data is poor and growth rates variable. Taking this approach will opening up new opportunities where commercial viability has historically been and is currently low.\n\nFullCAM guidelines for REMP and PF methods require generalised Tree Yield Formula (TYF) options based on previous calibrations1,2 to estimate carbon drawdown and its distribution across carbon pools3,4. While cost-effective, this approach has key limitations:\n\n1. Inflexibility: application is restricted to the planting types and stocking densities used in its calibration,\nexcluding many potential project scenarios due to limited calibration data.\n2. Low project-scale precision: Calibration prioritises broad applicability over accuracy, with prediction\nefficiencies often < 60%5,6.\n3. Risk of bias: ACCU estimates may be over-predicted if on ground project conditions differ from the\nconditions represented in the generalised calibrations.\n\nUpdating methods to incorporate cost-effective measure-model-measure approaches would increase the number of eligible projects, unlock co-benefits, and improve confidence in the ACCU Scheme. Since 2015,\n\n1 Paul., K.I., and Roxburgh, S.H. (2020). Predicting carbon sequestration of woody biomass following land restoration. Forest Ecology and Management, 460, 117838.\n2 Paul, K.I., Roxburgh, S.H., England, J.R. (2022). Sequestration of carbon in commercial plantations and farm forestry. Trees, Forests and People, 9, 100284\n3 Waterworth, R.M., Richards, G.P., Brack, C.L., Evans, D.M.W. (2007). A generalised hybrid process-empirical model for predicZng plantaZon forest growth. Forest Ecology and Management, 238, 231-243.\n4 Forrester, D.I., England, J.R., Paul, K.I., Rosauer, D.F., Roxburgh, S.H. (2024). Modelling carbon flows from live biomass to soil using the full Carbon AccounZng Model (FullCAM). Environmental Modelling and So\\ware, 177, 106064.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n4\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nresearch into uncertainties in measuring above-ground woody biomass (AGB) has led to significant improvements in the cost-effectiveness of AGB measurement.\n\nPast methods use traditional plot-based inventories that record stem diameters and apply allometric models, while recent studies show that, to maximise the accuracy of stand-level AGB estimates, resources are better allocated to improving sampling design and intensity (i.e. stem diameter inventories) rather than sampling trees to develop or validate new allometric models.5,6 Existing generalised allometric models are typically sufficient for this purpose7. Modernising past/existing methods through incorporation of AGB measurement advancements since 2015 including but not limited to leveraging LiDAR which provides the ability for detailed and accurate survey measurement, and enabling a measure-model-measure hybrid approach would greatly increase cost-effectiveness (and therefore uptake), while also provide a means for on-going model improvements and consistency with Australia’s National Greenhouse Accounts.\n\nProject Aggregation\nCurrent regulatory settings, particularly under the Managed Investment Scheme (MIS) framework in the\nCoporations Act, create barriers that prevent effective aggregation and limit participation by smaller landholders.\n\nAs noted in GreenCollar’s submission to ASIC’s consultation on revisions to Regulatory Guide 236, land suitable for large-scale carbon projects often spans multiple property boundaries and ownerships. The Carbon Credits\n(Carbon Farming Initiative) Act 2011 allows for multi-property aggregation, enabling integrated projects that deliver environmental outcomes and financial returns to all participating landholders. This is especially relevant in areas such as the Daintree region of Far North Queensland, where individual land parcels are small and standalone projects are often not viable.\n\nHowever, under current MIS rules, aggregated carbon projects are likely to be classified as managed investment schemes. If a project includes more than 20 members, including any retail investors, it must be registered with ASIC and comply with Chapter 5C requirements, including minimum financial resource thresholds for the responsible entity. In practice, the regulatory burden outweighs the benefits of aggregation and makes it difficult to maintain projects over time as ownership changes.\n\nThese types of aggregated carbon projects were unlikely to have been contemplated when MIS regulations were originally established. Treasury previously considered exemptions in 2015 to avoid unintended regulatory impacts that could discourage efficient market participation, but these proposals were not implemented.\n\nGreenCollar recommends that ASIC and the Government revisit targeted exemptions or provide clear guidance identifying circumstances under which multi-property carbon projects could proceed without triggering MIS registration requirements. Alternatively, if existing settings already allow for such arrangements in certain cases, these should be clearly articulated (for example, through expanded examples in a further updated version of RG236 – for instance, beyond the existing soil carbon example in RG236.108). Such clarity would enable aggregation and unlock significant additional abatement from smaller landholder participation.\n\n5\nPaul, K.I., Radtke, P., Roxburgh, S.H., Larmour, J.S., Waterworth, R., Bulter, D., Brooksbank, K., Ximenes, F. (2018a). ValidaZon of exisZng allometric models: How to have confidence in the applicaZon of exisZng. Forest Ecology and Management, 412, 70-79.\n6\nRoxburgh, S.H, Paul, K.I. (2024). Comprehensive propagaZon of errors for the predicZon of woody biomass. Methods in Ecology and\nEvoluZon, 16, 197-214.\n7\nPaul K.I., Roxburgh, S.H., Chave, J., England, J.R., et al. (2016). TesZng the generality of total aboveground biomass allometry across plant funcZonal types at the conZnent scale. Global Change Biology 22, 2106-2124.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n5\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\n5. Permanence and crediting periods\n\nQuestion: Do the rules on permanence and crediting periods get the balance right between integrity and project viability?\n\nResponse:\nConsideration should be given to revisiting the minimum permanence period obligations for new projects, particularly in light of the minimum permanence obligations within comparable market standards and methods that exist in the international voluntary carbon market.\n\nWe note that the Queensland Government has proposed a minimum permanence obligation of 50 years rather than 25 years for avoided re-clearing of forest and sub forest CEAs under its draft Avoided Clearing and Native\nReforestation Method8. The Queensland Government have coupled this proposal with eligibility criteria for an extended crediting period in an effort to align crediting periods with actual abatement pathways. We recommend similar considerations should be taken into account for all future methods/method variations but caution these considerations should be made on a project type by project type basis rather than in a blanket scheme wide rule change and should apply to future projects only to maintain continuity for already existing projects.\n\nGreenCollar also considers that greater flexibility is needed to incentivise longer permanence obligations for existing registered projects, specifically permitting the ability to increase permanence obligation periods after registration (from 25 years to 100 years) and consideration for the eligibility criteria of a second/extended crediting period in such cases.\n\nAdherence to permanence obligations would be strengthened by recording the existence of the carbon project on the relevant land titles. This is mentioned in the CFI legislation as something that may occur. However, due to challenges with state-based land registries it has not yet been implemented. GreenCollar submits that registration of the carbon project on the land title would substantially enhance permanence arrangements by ensuring that incoming purchasers of the land are fully appraised of the long-term permanence obligations before acquiring the land.\n\nSection 3\n\nFocus Area 2 – ACCU Market Dynamics\n\n1. Question: How can the right price signals be established to incentivise high-quality abatement?\n\nResponse:\nClear price signals, transparent differentiation and strong voluntary demand (as well as compliance demand) are essential to ensure high-quality abatement and market stability.\n\n8\nh#ps://www.qld.gov.au/environment/climate/climate-change/land-restora:on-fund/growing-market/proposed- avoided-re-clearing-method\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n6\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nPrice differentiation must recognise high-quality credits that deliver measurable co-benefits such as biodiversity , water quality, social and cultural outcomes.\n\nGovernment recognition of high-integrity co-benefit crediting frameworks such as NaturePlus®, CarbonPlus and Reef Credits, would reduce greenwashing risks, provide credibility for buyers and strength demand for those products. GreenCollar has observed this approach working very successfully with the Land Restoration\nFund (LRF) administered by the Queensland Government, in which the government purchases ACCUs from projects that have verified co-benefit outcomes under the Accounting for Nature Framework, and makes an additional payment for the co-benefits that are delivered by the project.\n\nGovernment purchasing through traditional ACCU purchasing and co-benefit verification and payment programs like the LRF, can provide stability through creating price floors, long-term contracts and forward offtakes prioritising public-interest outcomes. This is particularly important for regional and First Nations led projects where long term revenue certainty underpins land stewardship models and project viability.\nGreenCollar supports optional delivery contracts as a means of incentivising project development by providing confidence that project costs can be covered whilst also supporting the evolution of environmental markets by enabling purchasing to transition to the private sector as the markets mature.\n\nGreenCollar considers that there is very significant value in having a government-backed program to provide confidence to voluntary credit purchasers and assist them in managing greenwashing risk. The outcomes of the ongoing ClimateActive review should be finalised without further delay to support voluntary demand and ensure alignment with mandatory climate reporting. Buyers need confidence that high integrity ACCUs and associated co-benefits credits will remain recognised, valued and compliant under emerging national climate and nature frameworks.\n\n2. How 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?\n\nThe decision-making process for purchasing ACCUs should prioritise integrity and market-driven value recognition. Buyers are increasingly looking for credits that deliver measurable co-benefits such as biodiversity, cultural outcomes or socio-economic growth. Standards like NaturePlus, Carbon Plus and Reef\nCredits provide credible frameworks for identifying and verifying these co-benefits, enabling the differentiation in pricing based on verified impact rather than cost alone.\n\nRather than relying on government-defined frameworks for measuring co-benefits, the market is well placed to develop standards for identifying and verifying co-benefits, such as biodiversity, cultural outcomes or regional economic benefits. These standards can then be endorsed or certified by government once proven effective, rather than requiring government to design them from the outset. This approach maximises innovation, ensures efficient use of public resources, and supports differentiation in pricing based on measurable and verified co-benefits, allowing buyers to make informed decisions based on value beyond price per unit.\n\n3(a). What role, if any, should the government play in ACCU purchasing?\n\nGovernment should play an important stabilising role in the ACCU market by providing long-term direction and purchasing mechanisms that support investment confidence and orderly market growth. This could include identifying long-term procurement intentions, developing risk-sharing approaches such as reverse auctions or price floor structures, and entering into long-term purchasing commitments for credits that deliver clear public\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n7\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\ninterest outcomes. As discussed above, GreenCollar supports optional delivery contracts as the preferred approach for incentivising new projects whilst also supporting development of private environmental markets.\n\nThere is also value in prioritising government purchasing from projects that deliver First Nations participation, regional community benefits and verified biodiversity outcomes. In addition, government support for robust independent environmental verification frameworks, such as Accounting for Nature, Reef Credits and\nNaturePlus, would strengthen integrity and transparency.\n\nThe use of mechanisms such as Project Investment Agreements (PIAs) under the Low Emissions Technology deployment programs demonstrates how government can formally recognise co-benefits within procurement decisions and encourage market development.\n\nConsideration should be given to government supported bridging finance mechanisms including but not limited to PIAs to cover the upfront implementation costs of projects that struggle with the time lag between the capital work cost and time taken to see revenue from credit issuance. This approach can provide up front financial support to enable projects that deliver significant social, environmental or cultural outcomes, such as landscape scale rehabilitation, treatment wetlands or intertidal habitat restoration, that would otherwise be limited by investment costs.\n\nAdditionally, the government can ensure the resulting verified credit are retired on its behalf, reinforcing the public benefit while simultaneously creating a clear, transparent pathway for valuing co-benefits in procurement decisions. This not only incentivises high-integrity project development and design, but also strengthens market confidence by demonstrating that co-benefits are explicitly recognised. By linking financial support, co-benefit recognition and credit retirement, the government can actively encourage projects that deliver multiple outcomes beyond carbon, while providing a stable signal that-high quality, co-benefit-rich\nACCUs are valued and rewarded.\n\n3(b). Are there any approaches, besides direct purchase, the Government should consider to support an orderly transition for businesses?\n\nBeyond direct purchasing, the Government can play a critical enabling role by strengthening policy frameworks that support voluntary demand and help businesses transition effectively. In particular, the ClimateActive review should be concluded to ensure that voluntary offsetting options remain credible and accessible, noting that uncertainty within the program is currently limiting corporate participation.\n\nAligning ClimateActive outcomes with emerging mandatory climate-related financial disclosure requirements would provide clearer guidance and encourage voluntary offsetting by companies not covered by the\nSafeguard Mechanism but seeking to meet emissions commitments. Removing uncertainty and enabling recognition of co-benefits within voluntary carbon markets would support greater demand and enable a more orderly transition for industry.\n\nProject Investment Agreement’s (PIAs) can also provide forward funding for capital works, offering up front financial support to enable projects that deliver significant social, environmental or cultural outcomes, such as landscape scale rehabilitation, treatment wetlands or intertidal habitat restoration, that would otherwise be limited by investment costs.\n\nAdditionally, the government can ensure the resulting verified credit are retired on its behalf, reinforcing the public benefit while simultaneously creating a clear, transparent pathway for valuing co-benefits in procurement decisions. This not only incentivises high-integrity project development and design, but also\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n8\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nstrengthens market confidence by demonstrating that co-benefits are explicitly recognised, qualitied and supported in long-term investment decisions.\n\nBy linking financial support, co-benefit recognition and credit retirement, the government can actively encourage projects that deliver multiple outcomes beyond carbon, while providing a stable signal that-high quality, co-benefit-rich ACCUs are valued and rewarded.\n\nAs mentioned above, there are several advantages in structuring Government purchasing on an optional delivery basis.\n\n4. Are there particular attributes (for example biodiversity, durability or socioeconomic benefits) that should be prioritised in any future government purchasing?\n\nIt is important not only that ACCU projects avoid causing harm, but that they actively deliver measurable, net- positive social and environmental outcomes. Government purchasing should therefore prioritise projects that can demonstrate verified co-benefits, supported by credible evidence. Co-benefit verification is well established in the international voluntary carbon market as a way to ensure integrity, reduce risk and support credible claims, and similar approaches should be embedded in Australian government procurement.\n\nHigh-integrity pathways already exist in Australia to independently verify broader environmental and social value. For example, the NaturePlusⓇ Credit Scheme measures and verifies biodiversity improvements and can be stacked alongside ACCUs without double crediting, helping to deliver biodiversity gains and support progress toward Australia’s Global Biodiversity Framework targets. Likewise, the Reef Credit Standard, supported by the Australian Water Quality Standard, provides a trusted mechanism to improve water quality outcomes and demonstrates the value of nature-based projects in catchment systems.\n\nFurther, GreenCollar’s current research into quantifying socioeconomic outcomes from ACCU projects will support the development of an independently verified socioeconomic pathway. Demonstrating these broader values, without compromising carbon integrity, would improve transparency, strengthen public confidence and increase the value of ACCU projects to government and the community.\n\nRecognising co-benefits through accredited verification frameworks offers a practical way for government to prioritise attributes such as biodiversity, durability and socioeconomic resilience, while maintaining environmental integrity and avoiding double counting.\n\nAs mentioned above, there are several advantages in structuring Government purchasing on an optional delivery basis.\n\nSection 4 – Fairness, Accessibility and Continuous Improvement\n\n1. How fair and accessible is the scheme, considering the treatment of different sectors, barriers to participation and access to benefits?\n\nDespite fair design intent, the ACCU Scheme remains difficult to access for many potential participants due to high complexity, administrative burden and limited technical support.\n\nOverall, the ACCU Scheme is generally fair in its intent and design, and there is broad support for the role it plays in enabling emissions reduction opportunities across diverse sectors. However, the scheme is not\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n9\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nconsistently accessible due to the complexity of the regulatory framework and the high level of technical expertise required to navigate method development, project registration and compliance (project implementation, monitoring and reporting) requirements and in some project cases relatively high upfront investment costs comparative to rate of return. These barriers particularly affect smaller landholders, First\nNations groups, and organisations without specialist resources or access to upfront funding. Increased government support through education, clear guidance and improved access to information would help level the playing field. Access to benefits is also heavily influenced by the commercial model and capacity of participants, which can lead to inequitable outcomes where only well-resourced entities are able to participate effectively.\n\nDedicated government participation support, including regional extension services, First Nations capacity funding and simplified entry models, would significantly expand fair access, particularly those focussed on providing bridging style funding to overcome upfront implantation costs for project types such as but not limited to those using the Environmental Planting method.\n\nWe note that the introduction of alternative audit arrangements has helped reduce administrative barriers for small-scale, low-risk projects. However, tying eligibility to a risk-based approach provides no justification for restricting project proponents or nominees to only freehold title holders, leaseholders, native title holders or registered native title bodies corporate, as is currently the case for Environmental Planting alternative assurance criteria.\n\nIn practice, this restriction limits landholders’ ability to choose how they participate in the Scheme by penalising those who engage specialist carbon service providers. Landholders routinely engage specialists across their operations, and many partner with us so they can continue to focus on their core business while integrating carbon projects effectively.\n\nEncouraging participation would be better supported by expanding, rather than limiting, the choices available to landholders. We therefore recommend removing the eligibility restriction so that project developers with formal agreements with the relevant landholders can act as project proponents. This would ensure equitable treatment and align with other methods—for example, plantation forestry alternative assurance requirements do not impose this constraint.\n\nConsideration should also be given towards applying alternative assurance arrangements for other ACCU\nScheme methods including but not limited to the Tidal Restoration of Blue Carbon Ecosystems method.\n\n2. Are there any other ways that the ACCU Scheme could be improved?\n\nThe ACCU Scheme could be strengthened through targeted enabling actions that increase confidence, transparency and operational capacity.\n\nAlong with implementation of a number of the Chubb Review recommendations (see below) transparency could also be improved through implementation of project-level disclosure of credit use and a system to trace credit ownership, which would support better market functioning and improve public confidence.\n\nThere is a need for investment to improve the availability of auditors as audit requirements and project uptake increases. This is a both a challenge and opportunity as uptake of the Scheme evolves. Building national audit capacity would help address current bottlenecks and reduce delays that limit the ability of projects to scale.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n10\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nIn addition, a number of outstanding Chubb Review recommendations and other in train updates (e.g.\nFullCAM updates and associated policy position on adoption/transition to the new release – we note this delay currently presents a significant source of uncertainty for the development of new projects utilising the\nEnvironmental Plantings method) remain unimplemented; progressing these without further delay is essential to reinforcing the integrity and credibility of the scheme and providing the investment certainty needed to support long-term participation and market growth.\nIn relation to Managing Carbon Abatement Contract (CAC) Obligations, and as laid out in our letter to\nAssistant Minister Wilson on 27 October 2025 GreenCollar supports an approach that is equitable, and sustainable — one that supports the ongoing commitment of landholders, farmers and traditional owner groups, strengthens confidence in the Australian Carbon Credit Unit (ACCU) Scheme and delivers long-term market stability and liquidity. The management of CAC obligations should prioritise confidence and fairness for\nCAC holders while providing enduring certainty to market participants.\nGreenCollar recommends that following principles inform options for future management of CACs:\n1. Equitable – Ensuring fair treatment of participants. All fixed delivery CACs are held by early\nparticipants in the carbon market including a significant number of family-owned farms.\n2. Recognition – Acknowledging historical performance in meeting delivery obligations and making exit\npayments should be recognised.\n3. Supply – Delivering market confidence and stability. A realistic and commercially sustainable volume\nof ACCUs should be delivered into the Cost Containment Measure (CCM) to provide ongoing\nconfidence in the scheme.\n4. Simple and Flexible – Minimising regulatory burden including regulatory costs for both contract\nholders and the government.\n5. Certainty – Providing a permanent, orderly solution.\n\nGreenCollar believes that any revised arrangements for the CACs should:\n• be designed to incentivise continued ACCU supply into the CCM rather than relying heavily on exit\npayments or contractual penalties. While this means there will not be a complete release of all fixed\ndelivery CAC obligations, appropriate incentives should be in place to encourage landholders and\nTraditional Owners to deliver ACCUs to the CCM as an alternative to the existing contract mechanisms.\n• take into account the fact that, due to a variety of factors outside the control of the CAC holders, the\ntotal supply volume that is anticipated to be generated by the projects that are covered by the CACs is\nmaterially less today than forecast when those CACs were first entered into.\n\nThank you again for the opportunity to provide feedback to the 2026 ACCU Scheme Review.\nFor further information in relation to this consultation please contact: Hugh Wareham, Policy Adviser, email hugh.wareham@greencollar.com.au or M 0417 139 809.\n\nYours sincerely,\n\nJames Schultz\nCEO\nGreenCollar\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n11\n3 Hickson Road, The Rocks, NSW 2000 | T. 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