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To make it as easy as possible to make a submission, CMI offers some text below that is the basis for our own submission.
The text could be added into part 2, question 2 of the Survey or it could be uploaded as a separate document.
Text to Answer Question 2a
Part 2: Options for program direction
2) Do you support Option 1 (Close the program) or Option 2 (Close the Climate Active program but the department retains some voluntary standards and select guidance)?
[INSERT YOUR ORGANIZATION HERE] strongly supports option 2, where the department retains some voluntary standards and select guidance. Noting, Option 2 can only support organisations in reporting and reducing their emissions if the government commits to updating and maintaining the standard, guidance and tools so they align with best practice and community expectations. The corporate standards for Science Based Targets Initiative (SBTi V2), the draft ISO Net Zero Standard, Greenhouse Gas Protocol and the ICVCM Core Carbon Principles provide an initial base for this important work.
a) Please provide a short summary of your reasoning.
Originally launched as the National Carbon Offset Standard (NCOS) in 2010, the government program was a world-leading program to drive voluntary climate action through enabling businesses to measure and manage their environmental footprint including emissions reductions and offsetting. The NCOS was rebranded in 2019 as Climate Active to standardise voluntary carbon-neutral claims.
When it was introduced, the Climate Active program filled a domestic policy need and was taken up by hundreds of Australian brands across corporate, government and civil society sectors. It has also been highly valued by small to medium sized businesses who genuinely want to be able to take climate action but have no regulatory framework for reference.
Key strengths of the Climate Active program were:
- Accessibility for organisations starting their emission accounting and reduction journey.
- Simplicity of the claim for consumer understanding.
- Security of Government backing.
However, the Climate Active program has not kept pace with international best practice or consumer expectations, reducing demand for the program and increasing the risk of greenwashing claims for those certified by the program.
Revamping, rather than closing the Climate Active program provides more immediate solutions to these problems. Complete cessation of the program leaves a substantial gap in the market for:
- Organisations at the start their emissions documentation and reduction journey.
- Certifications standards easily understood by consumers.
- Additional action which goes beyond lowest-cost market engagement which supports First Nations, nature and regional opportunities in the carbon market.
Most of the demand for ACCUs, with significant First Nation co-benefits has been driven through Climate Active, and without the program or a replacement, there is a significant challenge to realising the full economic opportunity that the carbon market offers to First Nations communities. Similarly, voluntary demand is critical for investment in higher cost carbon projects with significant biodiversity and nature co-benefits. Unlike in the compliance market through the safeguard mechanism, lowest cost abatement is not the key driver.
Removal of government-backed standards and guidance at a time when organisations are likely to be seeking support and certainty may act to dilute the previously strong signals the government has created regarding voluntary action.
Discontinuing the program completely, without providing updated standards and guidance risks creating a vacuum that deters voluntary private sector engagement with carbon markets and contributes to “green chilling” in this critical decade for climate action. We need more additional action across the entire economy by organisations of all sizes if we are to achieve the ambition of our Nationally Determined Contribution, and a revamped Climate Active standard is an important tool for delivery. |
