Submission: DCCEEW Carbon Credits and Other Legislation Amendment (Integrity and Transparency) Bill consultation

22 May 2026
 

To: Department of Climate Change, Energy, the Environment and Water (DCCEEW)
Re: Submission to the Carbon Credits and Other Legislation Amendment (Integrity and Transparency) Bill consultation
 

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input to the Carbon Credits and Other Legislation Amendment (Integrity and Transparency) Bill consultation.

IEEFA is an independent energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

This submission builds on IEEFA’s April 2025 submission to the National Greenhouse and Energy Reporting (NGER) public consultation, which documented systematic method-change distortions in open-cut coal mine methane reporting. IEEFA has the following recommendations:

• B. CAIC (Q2). IEEFA supports the ERAC-to-CAIC transition and the expanded 45-day consultation period
• B. CAIC (Q3). CAIC should be given explicit functions to:
  • monitor and publicly report on the status of expired or lapsing methods, including the risk of lost abatement after method expiry (i.e. opportunity cost). 
  • monitor and publicly report on progress in implementing accepted government review recommendations, with specific reference to the CCA December 2023 NGER Act review and the unimplemented Method 2 sampling recommendation.
• I1. NGER Publication Powers. 
  • IEEFA supports new publication rule-making power. Regulations under section 23A should require publication of facility-level measurement-method information and material method changes.
  • Item 14 should be amended to remove the FY2026 restriction, allowing publication regulations to require provision of a minimum of five years of historical data to strengthen fossil fuel methane method-change transparency and allow for time-series comparability.
  • Section 23A regulations require that any Safeguard baseline restatement consequent upon a method change be published simultaneously, identifying the quantum attributable to the method switch.
• J1. Deregistration. Deregistration should not create a reporting gap for continuing emissions sources.

Kind regards,

Andrew Gorringe, Energy Finance Analyst, Australian Coal

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