Environmental Defenders Office (EDO) welcomes the opportunity to comment on the Independent Review of Australian Carbon Credit Units (ACCU) Discussion Paper. EDO agrees that for the public to maintain confidence in the ACCU Scheme (formerly the Emissions Reduction Fund), a robust and transparent institutional framework is essential.

EDO is of the view carbon offsetting using ACCUs must only be utilised as a last resort, once emissions have been reduced and mitigated, rather than the default option used to justify continued and increasing emissions. However, ACCUs may play a role in offsetting residual emissions in hard to abate sectors, and for this purpose carbon credit generating schemes must be
robust, trustworthy, and actually provide the emissions reductions they purport to.

While EDO remains concerned about the ongoing role of carbon offsets in national emissions reduction policy, it is clear that demand for ACCUs will only increase as a result of the Safeguard Mechanism reforms. As such, it is imperative that the ACCU Scheme and the ACCUs it generates have integrity, and represent real and additional emissions abatement.