Public submission to the Clean Energy Regulator: Draft Guidance on Meeting the Regulatory Additionality Requirement

Some states and territories have expressed a desire for companies to meet their regulatory requirements to reduce emissions by undertaking Emissions Reduction Fund (ERF) projects as the ERF provides a robust and established mechanism for carbon accounting and emissions reductions.

Corporate Carbon Advisory have provided a public submission on this update, which can be found on the Clean Energy Regulator’s page. Our main ideas are:

• The changes will encourage greater participation in the CSF scheme, leading to an increase in carbon abatement.

• The proposed new approach is likely to develop a stronger sense of participation between states and territories, assisting in driving ambition in each area to reach climate goals.

• We recommend that ACCUs be placed in a new cancellation state, to negate the problematic approach of placing them in a new Commonwealth holding account.

• Publishing data on ACCUs moved into this account would provide a high level of transparency through the process, benefiting all.