Carbon Farming Initiative Methodology

Submission Template

Carbon Farming Initiative methodology

Overview
This submission template should be used to provide comments on a draft methodology proposed under the Carbon Farming Initiative.
Contact Details
Name of Organisation:
Name of Author: / Dr George Rechnitzer
Phone Number: / 0418 998 158
Email: /
Website:
Date: / 22 June 2011
Confidentiality
All submissions will be treated as public documents, unless the author of the submission clearly indicates the contrary by marking all or part of the submission as 'confidential'. Public submissions may be published in full on the Department of Climate Change and Energy Efficiency website, including any personal information of authors and/or other third parties contained in the submission. If any part of the submission should be treated as confidential then please provide two versions of the submission, one with the confidential information removed for publication.
A request made under the Freedom of Information Act 1982 for access to a submission marked confidential will be determined in accordance with that Act.
Do you want this submission to be treated as confidential? Yes X No
Submission Instructions
Submissions should be made by close of business on the day the public consultation period closes for the methodology. This date will be specified on the website. The Department reserves the right not to consider late submissions.
Where possible, submissions should be lodged electronically, preferably in Microsoft Word or other text based formats, via the email address – .
Submissions may alternatively be sent to the postal address below to arrive by the due date.
DOIC Secretariat, Land Division
Department of Climate Change and Energy Efficiency
GPO Box 854
CANBERRA ACT 2601
Name of methodology: CARBON FARMING INITIATIVE:
Management of large feral herbivores (camels) in the Australian rangelands draft methodology
Northwest Carbon Pty Ltd (Dr Tim Moore)
http://www.climatechange.gov.au/government/initiatives/carbon-farming-initative/methodology-development/methodologies-under-consideration/management-of-feral-herbivores.aspxhttp://www.climatechange.gov.au/government/initiatives/carbon-farming-initative/methodology-development/methodologies-under-consideration/~/media/publications/carbon-farming-initative/cfi-feral-herbivore-draft-methodology-pdf.pdf

General/overall comments

The proposed methodology should be rejected outright due to the fact it:
1.  Simply involves the killing of a large percentage of the camel population - no matter how it is disguised in the proposal-style jargon, elaborate maths and claimed ‘humane’ practices - and ignores far more constructive and valuable alternatives;
2.  Unscientific and is based on a false premise that the camel emissions of methane cause “damage to atmosphere”, invalid analyses, and presents data and claimed emission reduction benefits without proper context and perspective;
3.  Incorrectly conflates two unrelated arguments to control the adverse impacts of feral camels in Australia: that killing camels will reduce CO2 emission and killing camels to control their population and thus environmental impact. As all life depends on (and the earth’s environment) uses or emits CO2 by its very existence, why stop at just killing camels, let’s just “cull” life on the planet.
4.  Does not recognise the positive and unique values of the camel population in Australia, and constructive alternatives in managing this population.
5.  Unethical and immoral, degrading the value of life to be measured in gross simplistic terms of CO2e emissions;
6.  There are many ways to reduce CO2e emissions, without resorting to killing such animals. To make a case for killing life based on CO2e reduction is both amoral and senseless (CO2e is the CO2 equivalent estimate).
7.  The claimed ‘climate benefits’ in terms of CO2e reduction by killing camels are minute (<0.001GT CO2e or 0.0003GT Carbon) and inconsequential in relation to Australia’s CO2 emissions (o.56GT CO2e or 0.15GT Carbon) and the world’s human related emissions related (~29 GT CO2e; ~9GT carbon see Carbon Cycle diagram attached), and the total world environment (~210GT Carbon - see Carbon Cycle diagram attached).
8.  The solution to improving the environment is not found in destroying parts of the environment. Camels are part of nature, whether they are labelled as ‘feral’ or not. You don’t remedy nature by destroying parts of nature. Remove what’s not part of nature!
Should such a proposed methodology be accepted by the Department of Climate Change, it represents a reprehensible degradation in scientific integrity and abandonment of moral values. This alone should set off red flashing warning signs and alarm bells to the Department, that by following such methodology, it is venturing into a depraved view of life (and possibly all of life) and its value.
Using a single narrow measure of CO2 emissions as the main measure of environmental impact and action is extremely ill founded, forcing aside the development of real sensible environmental programs.
All life on Earth is carbon based, and measuring the value and contribution of life by CO2 emissions, is a slippery slope to a form of moral depravity, and ultimately potential future genocide through the call for population control.
The claim that killing camels for CO2 emission reduction and carbon credits should be a patentable method is also without moral foundation or sense.
What Australia has not done well, but has the opportunity to, is to make the best use of this unique resource, and remarkable animal –the camel. This includes: possible business ventures by, for example, the Australian Aboriginal communities in these areas, with Government Assistance (better placed than spending money on this negative proposal), to develop camel based businesses (food, cheese, tourism, etc).
Section number: [insert section number from methodology eg 3.1] / Comments
3.1 and 3.2 / It is important to recognise that approach outlined is stated to be ‘completely novel’, and should not be accepted as reasonable or appropriate, with no similar schemes anywhere, worldwide.
3.1 “…This methodological approach to determining the emission reduction benefit created by the management of large feral herbivores (camels) is completely novel”.
3.2 “There are no comparable existing methodologies to the one proposed herein.”
.
5.1 / The specific abatement strategies are pure and simply culling – or in plain speak killing the camels at various ages. Let us not let the indirect language used by the proponents of this scheme obfuscate the real method “..the untimely demise of the feral camels (removal),…”.
The four methods outlined either involving shooting to kill, or transport to abattoirs.
The last paragraph is nonsense:
“The project abatement methodology meets the CFI requirements for additionality, permanence, avoidance of leakage, measureable and verifiable emissions reductions, conservative estimation of benefit, is consistent with international accounting procedures, and is well supported by peer-reviewed literature.”
What is described is killing of a camel, pure and simple, and the CO2 reduction is due to it no longer being alive. It is an artifice then, to make such claims, and that such a method “..is well supported by peer-reviewed literature”.
5.2 / The method is killing camels, and it is as simple and unsophisticated as that. The proposal should plainly state this and not disguise and cloak it with false values or make out it is anything more than this, with further obfuscation.
The proposal does not state what percentage or numbers of camels are to be killed, at what ages, or is it all of them??
5.3 / “Context and background to the issue of feral camel population in Australia.”
Whist it is stated that Australia’s approximately 1,000,000 ‘feral’ camels are the 5th largests camel population, it does not put a context to this that the total world population of camels is about 19 million, with Somalia having about 30% of this or about 6 million+, some 6 times Australia’s camel population.
Somalia with over six times the camel population as Australia has a land mass (637,000 sq kms) less than 1/12th of Australia’s, and about 1/6th of the area where camels roam in Australia (about 3.4m sq km).
Thus in context Australia’s camel population is not as extraordinarily large as made out (only 5% of world total), particularly considering our large land mass. What Australia has not done is made the best use of this unique resource, and remarkable animal. The focus on this camel population being ‘feral’ misses the positive opportunity they represent.
This includes, for example, possible business ventures by the Australian Aboriginal communities in these areas, with Govt Assistance (better placed than spending money on this negative proposal), to develop camel based businesses (food, cheese, tourism, etc).
Here, the proposal also mixes two quite unrelated factors: CO2 emissions and environmental degradation etc. It is here where the proposal is most ill-conceived.
Under Point 1 it claims:
“Damage to atmosphere through greenhouse gas emissions. As ruminant animals, the digestive processes camels undergo when consuming food sources leads to the release of methane. Methane is a potent greenhouse gas, with a global warming potential of 21 times the global warming potential of carbon dioxide. Each tonne of methane emitted to the atmosphere causes the same damage as the release of 21 tonnes of carbon dioxide.
To claim that the atmosphere is “damaged” from methane emission from these camels in Australia is complete scientific nonsense.
As noted Australia represents only 5% of the world’s camel population and generate a totally insignificant percentage of total CO2 emissions (equivalent) by all sources in the world.
In Section 9.1 it estimates that by 2020 “The projected greenhouse gas emissions from feral camels in Australia are therefore likely to exceed 1.9 million tonnes of CO2 e per annum”. Thus the current equivalent greenhouse gas emission for camels would be about 1m t. This compares with total CO2e emissions in Australia of about 563m t, with camels representing less than 0.1% of this.
Worldwide, Australia’s camel emissions CO2e would be about 0.001GT/29GT = 0.00003 of human emissions, hardly a statistic which supports the claim made in the proposal that this camel population’s emissions are “damaging” the atmosphere.
A further and critical point missing from this context is that the ‘human activity related emissions’ are a small fraction (about 4.3%) of total CO2’ Carbon transfers on the planet as per the Carbon Global cycle below. Note that Carbon is about 0.27% by atomic weight of CO2 (12/44 =0.27 by atomic weight). Thus CO2 emissions need to be multiplied by 0.27 to get the Carbon equivalent.

(refer NASA http://earthobservatory.nasa.gov/Features/CarbonCycle/printall.php) Units are Gigatonnes (i.e 1000 million tonnes)
Thus the basis of the Proposal that the Australian camel emissions ‘damage’ the atmosphere is clearly scientifically ‘feral’ and nonsense. For this reason alone the proposal should be rejected as meaningless and quite ill conceived.
In regard to the other well-known arguments for culling the camel population relating to environmental degradation, this has nothing to do with killing camels for claimed climate change benefits, which as noted are false. By trying to link that the Co2 emissions ‘damage ‘ the atmosphere to quite unrelated physical ‘environmental damage’ is very misleading. The two claimed ‘damages’ are unrelated.
By conflating two quite separate issues, it prevents appropriate solutions from being developed.
Thus what is required in regard to environmental degradation issues, is a quite separate treatment, based on firstly a proper appreciation (not rejection) of the unique and special qualities of camel, and how these can be made best use of. Killing should be the last recourse not the first. Intelligent environmental and business thinking is required, not just primitive culling.
9.1 Estimating Abatements / The proposal states in regard to total emissions from camels in Australia:
“Under the baseline scenario (ad hoc camel removals, continued presence of feral camel population) the population of camels is expected to grow to beyond 2 million by 2020 (see modelling of feral camel population). The projected greenhouse gas emissions from feral camels in Australia are therefore likely to exceed 1.9 million tonnes of CO2e per annum by 2020 as shown in the equation below”.

What is not stated is that current emissions in 2011 would therefore be about 1 million tonnes CO2e, less than 0.2% of Australia’s total.
Also in methane emissions, the 0.96t of CO2e represents 48kg per camel per annum of methane (using 20:1 multiplier).
To put this in a broader perspective, these methane emissions are less than for cattle at approximately 76kg/cow per annum, i.e approximately 1.2t to 1.5t/annum per cow. Thus methane/CO2e emission per camel/ annum are much less than per cow. There are approximately 27 million cattle in Australia.
REF: Lasers Measures Cow’s methane Emissions (CSIRO study), ABC News May 27 2011.
9.1, 9,2, 9.3 / The mathematics and calculations presented
The rest of the proposal is largely elaborate looking maths, which is really only about calculation of emission reductions based on how many camels are killed and at what age.
There should be no misunderstanding that such ‘sophisticated looking;’ maths disguises nothing more than CO2e reductions by killing camels.
The rest of the equations are simply calculations of what CO2 (etc) emissions arise from the killing process through use of helicopters, transport vehicles etc.
References
1.  Dr Birgit Dörges and Dr Jürgen Heucke; Demonstration of ecologically sustainable management of camels on aboriginal and pastoral land; Natural Heritage Trust, Final report on project number: 200046; March 2003.
2.  Feral Camels in WA, Department of Environment and Conservation;
3.  List of Countries by Carbon Dioxide Emissions. http://en.wikipedia.org/wiki/List_of_countries_by_carbon_dioxide_emissions
4.  Lasers Measures Cow’s methane Emissions (CSIRO study), ABC News May 27 2011; http://www.abc.net.au/news/stories/2011/05/27/3229303.htm
5.  Model Code of Practice for the Welfare of Animals The Camel; Primary Industries Standing Committee, CSIRO, 2006.
6.  Moore P., Confessions of a Greenpeace Drop Out, The Making of A Sensible Environmentalist, Beatty Street Publishing, 2010.
7.  National Greenhouse Gas Inventory, Accounting for the Kyoto Target, December Quarter 2010. Australian National Greenhouse Gas Accounts, Australian Government April 2011.
8.  Reduce Carbon Shoot a camel, Brisbane Times, 14 June 2011. (http://www.brisbanetimes.com.au/national/reduce-carbon-shoot-a-camel-20110614-1g0vt.html
9.  NASA http://earthobservatory.nasa.gov/Features/CarbonCycle/printall.php
10.  Zakaria Faith et al; Camel Dairy in Somalia: Limiting Factors and development Potential, Science Direct, Livestock Science 110 (2007) p187-191). http://camelmilknews.com/wp-content/uploads/2011/04/Camel-dairy-in-Somalia_-limiting-factors-and-development-potential-1.pdf

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