Submission Template

Emissions Reduction Funddraft determination

Carbon Credits (Carbon Farming Initiative- Measurement of Soil Carbon Sequestration in Agricultural Systems) Methodology Determination 2017

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This submission template should be used to provide comments on a draft Emissions Reduction Fund determination
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Where possible, submissions should be lodged electronically, preferably in Microsoft Word or other text based formats, via the email address –
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ERF Governance, ERF Division
Department of the Environment
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CANBERRA ACT 2601

Name of draft determination: Carbon Credits (Carbon Farming Initiative- Measurement of Soil Carbon Sequestration in Agricultural Systems) Methodology Determination 2017

Part A – Overall comments and potential adverse impacts

General/overall comments

Do you consider this determination may have any adverse environmental, economic or social impacts? If yes, are there any existing or new measures that could be adopted to mitigate those impacts?

Part B- Questions on general elements of the draft method

The draft method includes the use of a subsidiary document, the Supplement, which together with the draft legislative instrument, outlines to project proponents the requirements and suggested approaches to implementing the draft method.

Are the draft legislative instruments and the Supplement clear and readable? Could the Explanatory Statement or Supplement be expanded or refined to further clarify anything?

The draft method allows for eligible projects registered under the existing grazing systems method to transfer to the new method.

If you have a project registered under the existing grazing systems method, are you likely to transfer your project to this method? Please provide reasons for why you would or would not transfer.

The draft method is seeking to overcome some of the barriers to implementation of the existing grazing systems method. Stakeholders identified the narrow range of eligible activities and high costs of dry combustion (LECO) as significant barriers to implementing the existing method. To help overcome these barriers,the draft method provides a new measurement option (sensor technology) and increases the range of eligible activities.

a)Is the new draft method likely to increase uptake of soil carbon projects? Please provide reasons for why/why not.
b)What are your expectations of reduced costs, if any, from the proposed new method?
c)If you are a current or potential project proponent, are you likely to use the new measurement option (sensor technology), and if so, is this likely to change your approach to sampling? Alternatively, would you like to suggest an alternative measurement option that is reliable, uses existing technology and would produce verifiable results?

Specific questions relating to the draft’s method’s approach to the permanence period

Projects that elect a 100 year permanence period are required to maintain carbon stocks for the permanence period. Where a 100 year permanence period is elected, projects must continue to measure and report,atintervals of no more than 5 years, for the 75 years over which soil carbon stocks need to be maintained after the 25 year crediting period has ended. This is to provide the Government with confidence that sequestered carbon has not subsequently been lost.

a)If the frequency of reporting during the permanence period was changed from what is currently required to at least every 10 years or at least every 25 years as well as at the end of the project, would this influence your decision to elect a 100 year permanence period?
b)Considering your response to the above question, what approach could be used to give the Regulator confidence that carbon sequestration has been maintained through the 100 year permanence period, should ongoing monitoring and reporting frequency requirements be relaxed? Please provide an explanation for your response.

Specific questions relating to the draft method’s requirement for a Land Management Strategy

The requirement for a land management strategy has been included to control risks both to the landholder and the Government. Risks to the landholder include unrealistic expectations of the degree and scale to which they may be able to influence soil carbon and a lack of understanding of how a soil carbon project may or may not align with broader business objectives. The land management strategy is also intended to ensure landholders are well aware of their obligations in undertaking an ERF soil carbon project, to help manage the risk to Government of project non-compliance.

a)Is the requirement for a Land Management Strategy prepared or reviewed by an independent person an effective means for controlling risks to landholders and the Commonwealth? Please provide any supporting information relevant to your response.
b)Will the land management strategy and the requirement for an independent person to prepare, review or revise the strategy impact on the viability of projects? Please provide any supporting information relevant to your response.
c)Is the independent person appropriately defined for achieving the purposes of controlling risks to landholders and government? Please provide an explanation for your response.
d)Are there alternative safeguards you would like to propose?

Specific questions relating to the draft method’s approach to removing land from the project area (s 9)

Section 9 of the draft method specifies criteria for varying the area of a project. The criterion placed on the removal of CEAs is to ensure only genuine abatement is credited and to limit opportunities to increase net project abatement by removing underperforming CEAs. The criterion on the removal of CEAs seeks to allow for genuine circumstances where a project proponent may need to remove an area from the project.

a)Are the proposed controls on the removal of parts of or whole CEAs sufficient to ensure that areas are not able to be removed for the purpose of increasing carbon credits? Please provide an explanation for your response.
b)Do the proposed controls place barriers to projects removing areas where necessary for genuine reasons? Please provide an explanation for your response.
c)Are alternative controls possible that would lead to the same desired outcomes?

Specific question relating to the allowance of 50 per cent of credits from early sampling

The draft method uses a regression approach to attribute changes in soil carbon stocks to implementation of new management practices. This approach requires a minimum of three sampling rounds, (including baseline) to have been completed before a regression line can be fitted. The draft method allows project proponents to receive an advance of 50 per cent of credits to be issued following two rounds of sampling(including baseline).

a)Does the 50 per cent allowancesufficiently control for the risk that credits are provided for changes in soil carbon stocks which are not due to changes in management actions and therefore are unlikely to be additional, permanent changes? Please provide an explanation for your response.
b)What are the consequences of the 50 per cent allowance for project viability?

Part C- Specific questions on technical elements of the method

Specific questions relating to the draft method’s regression approach to measuring changes in soil carbon

The draft method uses a point in time baseline and regression approach to attribute changes in soil carbon stocks to implementation of new management practices.

Is the point in time baseline and regression approach conservative and likely to measure real changes in soil carbon stocks that are attributable to the implementation of new management activities? Please provide any supporting information including references to reports and peer reviewed scientific literature and demonstration of its application over a range of geographic locations.

Research has shown that in many situations human activity makes a relatively small contribution, compared to climate and soil properties,to changes in soil carbon. Because of this, the draft method sets a 60% probability of exceedance to the regression approach that is used to estimate net abatement. This is designed to minimise the risk of over-crediting.

a)In light of recent scientific literature () highlighting the relatively small contribution of management activity to changes in soil carbon stocks, is the estimation of the net abatement amount using this approach conservative or are additional controls warranted? For example should a higher probability of exceedance (e.g. 80%) be used to estimate soil carbon stock change in early sampling rounds? If not, why not?
c)Is the advance of 50 per cent of credits issued following two rounds of sampling (including baseline) appropriately conservative in reducing the risk that credits are provided for changes in soil carbon stocks which are not due to changes in management actions and therefore are unlikely to be additional, permanent changes?

Specific questions relating to the draft method’s approach to ensure integrity in sampling and analysis

There is a range of proposed controls in the draft method to ensure that sampling and analysis provide for accurate estimates of soil carbon content. These controls are designed to ensure sampling integrity while allowing for flexibility, where possible, and avoiding unnecessary costs. These controls include the use of blind duplicates, which involves providing a duplicate sample to a laboratory that is unaware of which sample it is a duplicate of, to assess the precision of the laboratory.

a)Are there sufficient quality assurance controls around sampling and testing? Please provide an explanation for your response.
b)How important is the analysis of blind duplicates in all laboratory tests to determine the error associated with the laboratory analysis. Please explain your response and provide any supporting evidence including reference to peer reviewed scientific literature.
c)Are there other suitable controls that would lead to accurate estimates?

A correction factor is required to be applied to results obtained using the Walkley-Black sample analysis method, which introduces further uncertainty into soil organic carbon estimates.

a)Do you think it is appropriate to allow for both Walkley-Black and dry combustion methods for sample analysis in ERF projects? Please explain your response and provide any supporting evidence including reference to peer reviewed scientific literature.
b)If you are an existing or potential project proponent, are you considering using the Walkley-Black method?

Part D- Specific comments – please insert your specific comments below, listed against the part of the draft determination to which they apply

Determination reference:[insert name of relevant part of determination] / Comments

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