The methodology’s structure must remain focused on its core purpose, which is to deliver verifiable carbon abatement under the ACCU Scheme. It must not be a mechanism for broader revegetation or conservation goals. The methodology risks creating a de-facto permanent reforested estate, with long-term land-use implications extending well beyond the project lifecycle. This outcome would be inconsistent with the voluntary, market-based foundations of the Carbon Farming Initiative (CFI) and would undermine landholder confidence in the Scheme.
Read the full submission here.