AGL’s submission to proposed new ACCU Scheme Savanna Fire Management Methods

AGL welcomes the opportunity to provide feedback to the Department of Climate Change, Energy, the Environment and Water (DCCEEW)’s ACCU Scheme Savanna Fire Management Methods Consultation.

AGL supports regular review and development of ACCU methodologies in alignment with the latest science to improve emissions reporting accuracy and scheme integrity. However, we hold concerns around the proposed transitioning of existing projects to the new methods, particularly the permitted back-crediting of ACCUs for activities that have taken place in the past, and question whether this meets additionality requirements of the Offsets Integrity Standards. We believe this could have unintended consequences for the ACCU market as well as decarbonisation efforts, and could potentially set a precedent for other new ACCU methods looking to back-credit for past activities.

While we support improvements to ACCU methodologies to better account for carbon avoided or removed, and support the ability of projects to transfer to these improved methodologies, we suggest that back-crediting should not be permitted. This would help preserve scheme integrity, ensure alignment with additionality principles, and maintain a credible signal for future abatement.

Read the full submission (PDF).