As predicted in our previous alert, the Department of Climate Change, Energy, Environment and Water (DCCEEW) has now launched a new proponent-led approach to developing new Australian Carbon Credit Unit (ACCU) Scheme methods.
Whilst the proponent-led approach is not yet in its final form, proponents are now being encouraged by DCCEEW to start putting pen to paper and submit expressions of interest (EOI) for a new method or method variation for crediting carbon abatement. In this alert, we take a look at the interim approach, and how proponents can get involved.
Background
In 2022, the Federal Government commissioned an independent review into the integrity of the ACCU Scheme (Chubb Review). The Chubb Review report was issued in January 2023 containing various recommendations including re-establishing the Emissions Reductions Assurance Committee (ERAC) as the Carbon Abatement Integrity Committee (Integrity Committee) and developing a proponent-led approach to carbon credit method development.
August 2023 saw the release of the Federal Government’s ACCU Review Discussion Paper (Discussion Paper) which contained significant detail about the proposed proponent-led method development framework and the functions of the new Integrity Committee.
This was then followed by the Federal Government committing $48 million over four years in last week’s Budget to progress the range of legislative reforms needed to implement the recommendations of the Chubb Review, including the establishment of the Integrity Committee.
Whilst those legislative reforms are still being developed, DCCEEW has announced the establishment of a new interim proponent-led method development process.
The interim proponent-led approach generally follows the process outlined in the Discussion Paper and our previous alert, with two key differences:
- prior to submitting an EOI, proponents are encouraged to submit a “Method Idea” to be placed on a Method Development Tracker; and
- once an EOI is submitted using the approved template, instead of the Integrity Committee, the ERAC will be responsible for assessing the EOIs for new methods or method variations.
How to get involved
The submission of Method Ideas is open permanently. Conversely, EOIs will only be accepted by the ERAC during submission rounds. The first submission round runs from 21 May 2024 to 12 July 2024. Further rounds are set to occur at later dates.
For those considering developing a method, DCCEW has suggested attending information sessions with the ERAC Secretariat to answer any questions on the process for submitting method proposals.
Method Ideas
The first step to the interim proponent-led approach is the submission of a “Method Idea”. Method Ideas can be submitted when still in their infancy and do not need to be well developed, but must be submitted in the approved template.
These Method Ideas will then be placed on a public Method Development Tracker. In doing so, it is hoped the interim proponent-led approach will be transparent and enable proponents the opportunity to see, reach out to, and collaborate with other proponents developing similar methods.
Proponents may then be able to share associated costs with researching and developing particular methods or method variations prior to the EOI stage. It may also allow for the pooling of other resources such as expertise, tools, or otherwise confidential information.
Expression of Interest
In preparing to submit your EOI, check the following:
|
Further details
|
INDIVIDUAL
|
Example
uses 2
|
|
|
Submitted a Method Idea?
|
Whilst not critical, it is strongly encouraged to submit a Method Idea before submitting an EOI. It is also recommended that consultation with the ERAC Secretariat occurs prior to submission. |
|
|
|
Considered time and cost implications?
|
The ERAC may require further information after the submission of your EOI to assess the method. This may involve further investigations that may have time and cost implications. |
|
|
|
Checked the Method Development Tracker for opportunities to collaborate?
|
Where method developers have similar proposals, consider working collaboratively to prepare the strongest possible proposal. Should you wish to be involved with the development of a particular method listed on the Method Development Tracker, email methodproposal@dcceew.gov.au where the ERAC Secretariat will be able to put you in contact with the relevant method developer. |
|
|
|
Complied with the EOI template?
|
You must use the EOI template to submit a proposal for a new method or method variation. DCCEEW has provided a Guideline to assist proponents with completing this template. The final template should not be longer than 20 pages, however supporting information either referenced or appended is strongly encouraged. |
|
|
|
Relied on confidential information?
|
Information that is submitted as part of an EOI can be kept confidential, however, it must be clearly marked as such and an explanation must be provided as to why it should not be published. |
|
|
Next Steps
Once submitted, an EOI will be assessed via the process outlined in our previous alert, with the ERAC acting as the Integrity Committee in the interim.
Broadly, this involves:
- further development of the draft method or method variation;
- public consultation on the draft method or method variation; and
- finalisation of the method.
Where to from here?
This “interim” proponent-led approach to method development is set to be quite similar to its predicted “final form” – the main difference being the Integrity Committee replacing the ERAC. That said, DCCEEW is actively seeking feedback as to how this approach can be improved, including with regards to guidance material and template documents. Changes to the approach may yet come as a result of feedback received.
Until the ink dries on the proponent-led approach, we encourage you to monitor the development this approach and consider whether the submission of a Method Idea, collaboration with other proponents, or submission of an EOI may provide opportunities.
