With the Government relying on major increases in land‑based carbon sequestration to meet climate targets, carbon market procurement efforts should maximise public value rather than rather only lowest cost abatement.
Background
ALCA has prepared a submission in response to the Climate Change Authority’s review of the ACCU Scheme and the Carbon Credits (Carbon Farming Initiative) Act.
The review comes at a time when the Federal Government is relying heavily on land‑based carbon sequestration and large‑scale environmental restoration to meet Australia’s Net Zero Plan and interim emissions targets.
Land‑based mitigation can deliver substantial emissions reductions while improving biodiversity and climate resilience, yet the ACCU Scheme is still structured around securing the lowest-cost abatement. This approach no longer fits the scale of restoration the Government expects from the land sector.
Our recommendations respond to how the ACCU Scheme can shift from a narrow carbon‑accounting tool to a mechanism that protects nature, supports communities and helps deliver national climate commitments.
Nature based solutions offer a major but underused opportunity
International and Australian scientific assessments show that nature‑based solutions are critical to achieving global climate goals. The Intergovernmental Panel on Climate Change describes land‑based mitigation as uniquely positioned to deliver co‑benefits when implemented well, yet only a small share of global mitigation funding currently flows to these opportunities.
Research shows that nature‑based solutions could provide up to one‑third of the emissions reductions required globally by 2030 to keep warming below two degrees.
Meanwhile, the Federal Government’s own sector planning documents outline the large-scale environmental restoration needed to deliver Net Zero. This means the ACCU Scheme is becoming increasingly important because it underpins how carbon projects are designed, approved and incentivised.
The scheme must evolve if it is to support both effective emissions reduction and the biodiversity outcomes the Government needs to meet its environmental commitments, including protecting 30 percent of land by 2030.
Recommendations
- Allow ACCU purchasing to maximise public value, not just lowest‑cost abatement. ALCA recommends amending the CFI Act so government procurement can account for biodiversity, social and cultural co‑benefits alongside carbon outcomes.
- Prioritise biodiversity co‑benefits that contribute to Australia’s 30 by 30 commitment, ensuring permanence in line with national protected‑area standards (in perpetuity or at least 99 years).
- Strengthen and clarify the role of regional Natural Resource Management organisations in the ACCU Scheme and related reforms, building on earlier Climate Change Authority recommendations that remain unexplored.
- Embed Free, Prior and Informed Consent in procurement processes and clarify how First Nations organisations will be resourced to participate in the carbon market.
- Develop new ACCU methods that integrate biodiversity and support ecosystem restoration at scale.
- Align the ACCU Scheme with the Nature Repair Market so carbon and biodiversity projects can complement each other.
Image: David Jenkins/Unsplash



