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Gateway checks and audits for carbon projects

05 December 2024

If you conduct a carbon project on your land pursuant to the human-induced regeneration of a permanent even-aged native forest (HIR) method, you will have likely heard references to “gateway checks” and “gateway audits”.

So, what are they and what are they targeting?

Gateway checks

“Gateway checks” refers to the regeneration checks and forest cover attainment checks that occur throughout a HIR project’s crediting period.

Regeneration checks occur approximately every 5 years and are used to demonstrate, among other things, compliant carbon estimation area (CEA) stratification and a project’s progress towards forest cover.

Forest cover attainment checks occur approximately 15 years after the project declaration or modelling start date and are used to confirm if a CEA has attained forest cover to then determine whether it remains eligible to receive Australian Carbon Credit Units (ACCUs).

When a gateway check is due, the project’s next offsets report must include information and evidence to demonstrate compliance. The regeneration check or forest cover attainment check is assessed by the Clean Energy Regulator (CER) before ACCUs are issued.

The CER has also commissioned independent audits of gateway checks. To date, two audits have been conducted both of which concluded that HIR projects are being managed in accordance with the legislative requirements and appropriate methods are being used to classify CEA areas.

Gateway audits

Since 6 May 2023, all offsets reports that are subject to gateway checks are now also subject to a gateway audit. Gateway audits are in addition to the standard audits that also required during the lifetime of a HIR project.

The intention of the audit is to independently confirm that the offsets report complies with the legislative requirements, taking into account the guidelines on stratification, evidence and records.

Next steps

These changes appear to be part of the CER’s attempt to respond to the growing criticism of HIR projects.

It is unlikely that these changes will silence the critics. Landowners conducting HIR projects will need to continue to adapt quickly to any reporting changes that are applied to their projects.

This information is intended to provide a general summary only and should not be relied on as a substitute for legal advice.

About the Author

Hannah Barbour
Hannah Barbour
Special Counsel Ph: +61 7 3231 8892 Email: hbarbour@thymac.com.au

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