This submission is made in the context of EDO’s primary submission in response to the Safeguard Mechanism Consultation Paper, 20 September 2022 (EDO’s Primary Recommendations). Here, we respond directly to a narrower set of proposals drafted in the Safeguard Mechanism (Crediting) Amendment Bill 2022 and Carbon Credits (Carbon Farming Initiative) Amendment (Safeguard Facility Eligibility Requirements) Rules 2022 (the draft amendments).