Environmental Defenders Office (EDO) welcomes the opportunity to comment on the Credits and Other Legislation Amendment (Integrity and Transparency) Bill Exposure Draft (Exposure Draft Bill). The Exposure Draft Bill proposes amendments to the Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act) and the National Greenhouse and Energy Reporting Act 2007 Act (the NGER Act).

The CFI Act sets out the rules established for the Australian Carbon Credit Unit Scheme (ACCU Scheme). Integrity issues with the ACCU Scheme have been substantially documented over the 10 years it has been in operation, including in relation to a lack of integrity with ACCU methodologies1 and conflicts of interest in relation to the governance arrangements of the Scheme. Given the substantial role ACCUs play in companies’ net zero emissions plans, including companies which are Safeguard Mechanism facilities, a legal regulatory framework for ACCUs that is robust, operates with high integrity, and delivers real carbon abatement is more important than ever.