{"data":{"id":"sbm39ba3d0ab5a24b499dbe7","short_id":98,"created":"2025-12-15T22:32:11.189Z","space_id":"spc385d5d0e2bd5c37dfd20e","project_id":"prj385d5adf82a6fe7d357df","org_id":"org25a4efd179c5b5ba55d6e","content":{"name_ba03fa":"Martha Hudson","name-of-organisa_9974be":"bp Australia","published-upload_e99675":"fil3b7931bf8ea0be9783604"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3b7931bf8ea0be9783604":{"id":"fil3b7931bf8ea0be9783604","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/BP.44d82155.pdf","url":"https://storage.googleapis.com/files-au-climate/cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/BP.44d82155.pdf","filename":"BP.pdf","transcribed":"bp Australia Pty Ltd\nA.B.N. 53 004 085 616\n717 Bourke Street\nDocklands, Victoria 3008\nAustralia\n\n15 December 2025 bp Australia response to Issues Paper: Enhancing the ACCU Scheme to support Australia’s\n2035 emission reduction target bp Australia welcomes the opportunity to contribute to the Climate Change Authority’s review of the\nCarbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act), enabling the Australian Carbon Credit Unit\n(ACCU) Scheme. The ACCU scheme is an important element of Government’s overall climate policy and this review can help to ensure it remains effective and continues to have high integrity.\n\nAbout bp Australia bp’s purpose is to deliver energy to the world, today and tomorrow.\n\nWe are an integrated energy company, serving customers across all sectors, from light vehicles to heavy transport, rail, aviation, and marine. Our history in Australia spans more than a century, and our customers are at the heart of our operations across all states and territories. Through our growing network of over\n1,400 retail sites and bp pulse charging stations, we provide the convenience, mobility, and energy solutions they rely on.\n\nWe are continuing to invest in upstream oil and gas, further grow and develop our mobility and convenience offer, progress our low carbon projects including hydrogen, biofuels, solar, onshore wind and extend our power and carbon trading capabilities.\n\nOur business model and service offerings continue to evolve with our customers’ needs, today and into the future.\n\nAs a foundation partner in the North West Shelf Joint Venture, bp engages in the ACCU scheme as a compliance buyer to meet its Safeguard obligation. Many of our strategic customers are also Safeguard entities, whose willingness to pay for our low carbon energy offers is influenced by the ACCU market. bp is also an intermediary, trading in the ACCU market. Our submission reflects our experience in the ACCU scheme.\nAccelerating the development and approval of high-integrity, scalable methodologies\n\nAccelerating the development of high integrity and scalable methods will require concerted effort. A predictable, transparent, collaborative and efficient process is needed. Current processes for method development and approval are complex, at times lack transparency, are resource-intensive, and take far too long to reach an outcome. bp welcomed the findings of the 2022 Independent Review of the ACCU scheme (the Chubb Review) that determined generally the ACCU scheme was of high integrity. Implementation of the recommendations under that review as well as the regular review of the legislation, including this one, provide a further opportunity to ensure integrity. The method development process is essential to maintaining the overall integrity of the scheme. Making sure all approved methods are of high integrity is fundamental to the scheme. This can give confidence the ACCUs issued under an approved method are also of high integrity and meet the Offset Integrity Standards.\n\nWe support the prioritisation of methodologies for development, giving weight to those that have potential to generate abatement at scale. However, this prioritisation also needs to consider the complexity and likely time it will take to finalise and approve a methodology. If a methodology is facing delays and there is no resolution in sight, we encourage the government to move on swiftly so other methods can be progressed\n\nA more streamlined and coordinated approvals process would have the biggest impact on accelerating the development and approval of methodologies. The current two track process with DCCEEW leading some and others being developed through the newer proponent lead approach is cumbersome. Currently, a single method must work its way through multiple steps, initial drafting by DCCEEW, Emissions Reduction\nAssurance Committee (ERAC) review, public consultation, further revisions, and then a final ERAC assessment to advise the Minister to make the method. Even when the underlying method is straightforward, this intensive process creates delays. Opportunities include consolidating steps that duplicate effort, clarifying decision making roles, and setting clearer timeframes for each stage. This would help move well designed methods to approval faster, without compromising integrity.\n\nWe suggest Government publishes clear target timelines and consultation processes for each methodology under development and regularly update these if delayed, to promote accountability and orderly workflows.\n\nOvercoming current barriers to method development\nA number of barriers continue to slow method development and limit the pace for new opportunities to be introduced. These relate to the complexity of some methodologies, resource constraints and uncertainty over priorities and timelines.\n\nProgressing a new or revised methodology has regularly taken multiple years. Often the market has a lack of clarity around the timelines or where the methodology is in the pipeline. This is costly, can erode commercial viability and reduces the appetite to invest in abatement. Concerted effort is needed from government to reduce the time taken for new method development.\n\nMethod development is highly resource intensive and requires a mix of expertise. A lack of resources within Government (for both policy and drafting) has often been a bottleneck for methodology development. Ensuring the Department and ERAC have stable, ongoing funding and access to technical expertise will be important.\n\nAt times, long delays have occurred because of disagreements on the best practice in quantifying abatement between different stakeholders and interest groups. Early involvement of a wider field of experts could be beneficial. Bringing technical experts and policy specialists into the drafting process through collaborative forums can bring issues to the surface early and avoid disputes later in the process.\nIt would also ease the resourcing pressure on government by tapping into specialist expertise early.\n\nThere could be an opportunity to provide more guidance on methodology development, and to encourage more modular or standardized design across different methodologies. Over time this should speed up the approval process. High integrity methodologies that have been developed and approved for reputable internation programs could also be adapted for use under the ACCU scheme.\n\nDelivering the methods faster and improving transparency of method development\n\nPrompt delivery of the methods is crucial to accelerate the development of projects and allow for new opportunities to be introduced. The department and ERAC will need to be properly resourced to accelerate the development of methodologies.\n\nPublishing a transparent work program that outlines which methods are under consideration, their development stage and expected timeline for completion would be beneficial. Open communication on the status of the review, as well as issues creating delays, could facilitate resolution more quickly.\nPublishing decision summaries would also give better line of sight and help inform further development activities.\n\nWhere industry stakeholders and experts are engaged it will be important to be transparent in their involvement and to share more widely the basis for outcomes. There can be a perception otherwise that\nsome vested interests are getting preferential treatment and benefiting from having their methods and activities registered ahead of others.\n\nPotential new methods or refinements to existing methods to unlock new abatement\n\nThere is potential to integrate a measure-and-model approach to vegetation methods, in addition to\nFullcam.\n\nThere is also potential for planting perennial oil seed tree species, with biodiverse environmental plantings and crediting the carbon sequestration associated with living biomass and potentially soil carbon.\n\nEstablishing price signals to incentivise high-quality abatement\n\nThe continued focus of integrity in the method development process and the regular reviews of the program should provide sufficient assurance that high quality abatement is being achieved under the\nACCU scheme. Ongoing and at times unfounded criticism of the integrity of the scheme should not go unchecked. There is a role for government in defending the scheme as a high integrity and standing behind the findings of the various reviews in this regard.\n\nThe price of ACCUs is determined by the market. Currently demand is a mix of compliance, voluntary and government purchasing and highly dependent on the settings underpinning these sources of demand.\nHowever, the Government’s recently released net zero plan and accompanying modelling indicates there is a material role for removals in achieving Australia’s emissions reduction targets. This implies an expansion of demand for ACCUs. The Productivity Commission has also noted a potential role for the\nACCU scheme to align incentives across different sectoral policies, most of which are yet to be detailed.\nClarifying the role of the ACCU scheme within the overall policy suite will be important in assessing the market’s dynamics.\n\nDifferent actors in the ACCU market may also price different methodologies and abatement according their own views, i.e. avoided deforestation typically trades at a discount to HIR, and HIR trades at a discount to environmental planting, which provides a potential market view on how buyers view different credit types, even though they are all compliant under the Safeguard Mechanism. We think there will be good and bad projects in every methodology, and therefore also try for a diversified portfolio approach.\n\nEstablishing effective price signals for ACCU scheme requires a well-functioning, transparent and forward-looking market. A key foundation to this will be stability. Frequent, unexpected or retrospective changes to market relevant settings should be avoided. Unfortunately, there have been unexpected interventions that have seen material adjustments in the market. These types of events undermine confidence of investors in the ACCU market.\nConsiderations in purchasing ACCUs\n\nAs discussed above, bp is both a compliance buyer as well as an intermediary in the ACCU market. For compliance purposes, costs per ACCU is an important consideration. We also consider the use of SMCs as well as direct abatement. The data released about the ACCUs used under the Safeguard Mechanism also means that we consider other aspects of the ACCUs purchased, particularly considering if there are any reputational risks associated with the purchase of certain ACCUs.\n\nAs an intermediary we have observed varying degrees of purchase strategies in the market, ranging from: cheapest cost of compliance (i.e. generic ACCU or SMC) to those which have specific lists of projects they would prefer to purchase from. We also see buyers with a strong preference to the No-\nAvoided Deforestation ACCUs or diversification across the methodologies. As an intermediary, we would be active in transacting in all methodologies with the caveat that the more premium units (i.e.\nhigher relative purchase price) have proven more challenging to place, and those typically stay with the developers until they can be sold at a premium to a more limited set of buyers.\n\nThe role of Government in ACCU purchasing\n\nThe Government will likely continue to have a role in purchasing ACCUs. For example, to support the functioning of the cost containment mechanism under the Safeguard mechanism. Further clarity is needed from Government on the overall policy suit to achieve Australia’s emission reduction targets, but the modelling does indicate a need for material removals in the land sector. We assume the ACCU scheme will be important for achieving these removals. These will need to be incentivised either by new policy or government funded purchases.\n\nThere may also be a role for Government to support greater participation and competition in ACCU project development. We see some barriers to entry for new developers. Government may have a role in supporting new entrants to the market, for example, with preferential offtake for projects of new entrants.\n\nWhere government is a material source of demand for ACCUs, it will be important that these arrangements are transparent and stable, so the rest of the market can invest with confidence.\n\nMaking the scheme fair and accessible\n\nThe accessibility of the ACCU scheme varies across sectors, and participation is still heavily influenced by a project’s size, capacity, and familiarity with the complex regulatory requirements. The current scheme favors larger, established developers who have the resources to interpret methodologies, and cover the cost involved with registration and audit requirements.\nThe latest 2024 reforestation methodology enables smaller (<200 ha), “low risk”, projects to be fast tracked by going through alternative assurance pathways without scheduled audits. This allows for smaller landowners to participate in the scheme and increases liquidity.\n\nIt is important to ensure that improvements to quantification don’t inadvertently shut out smaller proponents. As methods are developed, research institutions and think-tanks should be leveraged to create open source technology so that access is not limited to those who can afford costly systems.\n\nAccessibility is shaped by how well the scheme supports engagement with indigenous groups. Greater transparency and clearer guidance on the interaction between national and state land frameworks, particularly with indigenous titles, would improve the process for securing eligible interest holder consent. For example, freehold land cancels native title consents at federal level under the Native Title\nAct 1993, but this does not apply under the Northern Territory Aboriginal Land Rights Act 1976, which grants inalienable freehold title to Aboriginal Land Trust. Practical guidance that navigates these differences would help ensure Indigenous groups can participate in the scheme on equal footing and without unnecessary administrative burden.\n\nConclusion bp Australia thanks the Climate Change Authority for the opportunity to contribute to the review of the\nCarbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act). We welcome further engagement with you as the Australian Carbon Credit Unit Scheme is developed.","size":67654,"redacted":[],"meta":{"name":"BP.44d82155.pdf","mime_type":"application/pdf","local_path":"files/xpAGcDJ8jOcVi2eRFbAluYxP.pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}},"fil39ba3ceacdd2ed797b55d":{"id":"fil39ba3ceacdd2ed797b55d","bucket":"files-au-climate","remote_path":"cca/p/prj385d5adf82a6fe7d357df/submission/spc385d5d0e2bd5c37dfd20e/bp_submission_Enhancing_ACCU_scheme_to_support_2035_target.7166948d.pdf","filename":"bp submission - Enhancing ACCU scheme to support 2035 target.pdf","transcribed":null,"size":67654,"redacted":[],"config":{}}}}}