Chartered Accountants Australia and New Zealand (CA ANZ) has provided feedback to the Department of Climate Change, Energy, the Environment and Water (DCCEEW) on its draft Greenhouse Gas (GHG) Emissions Estimation and Reporting Guidelines for Agriculture, Fisheries and Forestry.

Key points from CA ANZ’s submission:

• Clarity and accessibility: CA ANZ recommends clearer references to existing standards, such as the GHG Protocol and ISO frameworks. The submission calls for more plain language, visuals and interactive elements to make the Common Requirements Framework easier to use.
• Scope 3 guidance: CA ANZ suggests providing more context on inclusions and exclusions in Scope 3 categories, particularly in Table 1.
• Method 3 approaches: CA ANZ supports limiting the Guidelines to Methods 1 and 2 for now. Method 3 should be acknowledged but not prescribed, given its complexity and voluntary nature.
• Emerging technologies: Adjustments for new mitigation technologies, such as methane-reducing feed additives, should not be incorporated into Methods 1 or 2 until the Guidance is updated.
• Data quality criteria: CA ANZ proposes adopting GHG Protocol criteria for assessing data quality across all datasets to improve rigour and comparability.
• AASB 16 alignment: Using principals of operational control to determine emissions responsibility in lease arrangements is appropriate for the agriculture sector.
• Global alignment: CA ANZ encourages referencing the strategic partnership between the GHG Protocol and ISO to support unified global standards.