{"data":{"id":"sbm2f4abf621b19726ef26bd","short_id":9,"created":"2024-07-15T04:29:12.091Z","space_id":"spc2e87423b0413d1fd9c277","project_id":"prj2e872b17b456d5488f86f","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil318a8270dcf18dcb8b2e5","zovp5q48":"GreenCollar","confirm-that-you_b979c5":"yes","upload-supportin_b2bc9a":"fil2f4abf2a2519091afd02f"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil318a8270dcf18dcb8b2e5":{"id":"fil318a8270dcf18dcb8b2e5","bucket":"files-au-climate","remote_path":"climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/09_GreenCollar_Redacted.db43379f.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/09_GreenCollar_Redacted.db43379f.pdf","filename":"09_GreenCollar_Redacted.pdf","transcribed":"15 July 2024\n\nEmissions Reduction Division\nDepartment of Climate Change, Energy, the Environment and Water via email: ACCUMethods@dcceew.gov.au\n\nDear Method Development Team,\n\nRE: Public consultation on the draft Reforestation by Environmental or Mallee Plantings method 2024\n\nGreenCollar appreciates the opportunity to provide feedback on the exposure draft of the Carbon\nCredits (Carbon Farming Initiative) Reforestation by Environmental or Mallee Plantings Methodology\nDetermination 2024 (the ‘Draft Environmental Planting Method’).\n\nWe strongly support the decision to remake the 2014 Environmental Plantings Method and commend the Department for the changes made to the 2014 version in the 2024 exposure draft and for hosting the information session on 4 July 2024.\n\nIn addition to the feedback provided to the Department on 19 April 2024 (copy attached for reference),\nTable 1 below outlines GreenCollar’s specific feedback which we hope is constructive in the finalisation of the Draft Environmental Plantings Method.\n\nWe would welcome the opportunity to discuss the content of this document or our previous submission with the Department to further clarify how our suggestions could improve the Method and maintain alignment with the Offsets Integrity Standards.\n\nIf you have any questions or would like to discuss the submission further, please contact Rachel Chiswell at or me at any time.\n\nThank you again for the opportunity to provide input into this process and for considering our feedback.\nYours sincerely,\n\nNerida Bradley\nChief Impact Officer\nP:\nE:\nW: www.greencollar.com.au\n\nI acknowledge and pay my respects to the Widjabal people of the Bundjalung Nation on whose land I live and work. GreenCollar respectfully acknowledges all Traditional Owners and Custodians of the Country on which we work.\nSummary of feedback items with the Draft Environmental Plantings Method (“the Draft Method”).\n# Item Relevant Method Section/s Feedback\n1 Definition of s5 Definition of ‘permanent planting’, which is There appears to be conflict between the definition of permanent planting in the\n‘permanent planting’ defined as: method (which we note is also defined in the CFI Rule), the subsequent reference to\ndisagrees with a planting: the term ‘permanent plantings’ (in sections 7 and 9) and the permitted biomass\npermitted biomass (a) that is not harvested other than:…. removal provisions described in section 57, which may create some confusion.\nremovals later in the (iii) to remove firewood, fruits, nuts, seeds,\nmethod or material used for fencing or as craft materials, While the simple method guide and explanatory statement are clear in\nif those things are not removed for sale; or… communicating the intent (that the Draft Method will allow for limited (<10% for the\ncalendar year) commercial harvest of seeds, fruits, nuts and leaves), sections 7 and 9\ns7 Reforestation by Environmental or Mallee refer to the definition of ‘permanent planting’ which states a blanket restriction on\nPlanting projects any harvesting ‘for sale’.\nFor the purposes of paragraph 106(1)(a) of the\nAct, this Determination applies to an offsets To avoid potential confusion and improve comprehension, we suggest incorporating\nproject if the project involves the establishment reference to section 57 into the definition of ‘permanent planting’ provided in section\nof a permanent planting that could reasonably 5 of the Draft Method – potentially via a note similar to the note accompanying the\nbe expected to result in eligible carbon ‘stem’ definition.\nabatement.\n\ns9 Permanent planting types\nThe project must establish by planting, and\nmaintain, permanent plantings that are:\n(a) all mixed-species environmental plantings; or\n(b) all mallee plantings.\n\ns57 Permitted biomass removals\nBiomass may be harvested: (d) to remove fruits,\nnuts, seeds, or material used for fencing or as\ncraft materials (other than woody products),\nprovided no more than 10% of any fruits, nuts,\nseeds or leaves present on a tree or shrub are\nharvested in a calendar year (whether for\npersonal or commercial use)\n# Item Relevant Method Section/s Feedback\n2 Definition of ‘planting s5 Definition of ‘planting date’ means, for a GreenCollar understands the incorporation of new section 61 ‘Infill planting’ aims to\ndate’ in reference to carbon estimation area, the date on which provide clarity on the approach the CER currently employs in relation to infill planting.\nunderstood intent of planting last occurred within the carbon\nnew infill planting estimation area. Our understanding of the CER’s current approach to infill plantings for ecological\nsection purposes after the end of the first reporting period (i.e. ‘enrichment plantings’) is that\ns14(2) Note. Project proponents may optionally the CER would not require a carbon estimation area/s’ modelling commencement\nstratify carbon estimation areas based on date to restart. This has not been captured by s61 meaning that ecological infill\nplanting date. planting is potentially substantially disincentivised by the Draft Method. This is due to\nthe requirement to input the date of last planting into the FullCAM event queue –\ns61 Infill planting essentially re-starting the biomass accumulation from the point of infill planting.\n\ns68(b) FullCAM input date requires the last To fully incorporate the CER’s approach to ecological infill planting, avoid confusion\nplanting date. and increase readability, we suggest that both:\n(a) reference to s61 is incorporated into the definition of ‘planting date’ provided in\ns5 of the Draft Method, and,\n(b) expansion of s61 to cover treatment of ‘planting date’ by FullCAM modelling in\nthe instance of ecological in fill planting after the end of the first reporting period.\n\n3 Transition window for s6 Factors and parameters from external sources GreenCollar supports in principle the general approach of requiring adoption of\nthe adoption of new (1) If a calculation in this determination includes updated and improved tools over time. This aligns broadly with recommendation 1 of\nexternal factors and a factor or parameter that is defined or the Climate Change Authority’s 2023 Review of the Carbon Credits Act 20111\nparameters calculated by reference to another instrument or\nwriting, the factor or parameter to be used for a However, there are two critical aspects which need to be clarified in the Draft\nreporting period is the factor or parameter Method, explanatory statement and method guide:\nreferred to in, or calculated by reference to, the (a) the “factor or parameter” (ie. revised technology/dataset/factor) must be\ninstrument or writing as in force at the end of demonstrated to provide increased confidence if it is proposed to be applied to\nthe reporting period. prevent continued use of superseded tools over the crediting life of a project\n(albeit after a transition period); and\n(b) the provisions need to provide for the CCA’s recommended 2-year transition\nwindow for the application of updated tools (“require application of updated\n\n1\nhttps://www.climatechangeauthority.gov.au/sites/default/files/documents/2023-\n12/2023%20Review%20of%20the%20Carbon%20Credits%20Act%202011%20-%20publication.pdf\n# Item Relevant Method Section/s Feedback\ntools within two years of their making, unless the Carbon Abatement Integrity\nCommittee advises otherwise”.\n\nBoth these aspects are critical to balance investment certainty and proper project\nplanning with the need to require use of improved information and data as that\nbecomes available through the life of a project.\n\nIn relation to (a):\n• The explanatory material must make clear that a requirement to transition to use\nof any new tool can only occur where that tool has been confirmed to\ndemonstrably improve accuracy and provide increased confidence\n• Increasing confidence and accuracy is a necessary pre-condition to be applied if\ncontinued use of superseded tools over the crediting life of a project (albeit after\na transition period) is proposed.\n\nIn relation to (b):\n• In relation to FullCAM in particular - while the explanatory statement confirms\nthat FullCAM Guidelines will dictate which version of FullCAM is ‘in force’ for a\ngiven reporting period, the example provided suggests that subsequent versions\nof the FullCAM guidelines associated with future FullCAM releases would not\nnecessarily provide a transition window that dictates when a particular version of\nFullCAM would ‘come into force’. This is important to clarify as there are\nsignificant impacts for project development, risk assessment and investment.\n• Making clear a 2-year transition period for registered projects is in line with the\nCCA’s recommendations and allows project proponents an appropriately limited\ntime to renegotiate commercial terms of credit offtake agreements if required,\nwithout having to completely pause or disrupt a reporting and crediting schedule\nthat is already underway, while still resulting in the mandatory adoption of new\ntools.\n• Noting the significant potential ramifications of requiring transition to new\nFullCAM releases (when compared to the historical use of grandfathering\nprovisions on new FullCAM releases) we suggest that additional examples should\nbe provided in the explanatory and/or simple method guide around the\n# Item Relevant Method Section/s Feedback\npossibility of transition windows being a component of when a future FullCAM\nrelease comes into force.\n\n4 Known weed species s10 Land on which project is implemented The Draft Method does not provide a definition for ‘known weed species’ nor does it\nnot defined within the (2) The land must not contain woody biomass or cross-reference the definition provided for ‘known weed species’ in the CFI Rule.\nmethod an invasive native scrub species that need to be\ncleared in order for planting to occur, other than As currently drafted, the clause related to weeds potentially prohibits the removal of\nknown weed species required or authorised by undesirable vegetation (that are unlikely to yield significant or permanent carbon\nlaw to be cleared. stocks) that could be replaced by mixed environmental plantings species more\nreflective of the landscape.\n\nWe suggest the Draft Method cross reference the definition of ‘known weed species’\nin the CFI Rule to provide clarity. It should also be considered as to whether a note\ncould be included to indicate some flexibility (at the Regulator’s reasonable\ndiscretion) around species that are known by local land services or equivalent, but not\nyet listed on the declared registers.\n\n5 Remaining uncertainty s10 Land on which project is implemented Both the 2014 version and the Draft Method are unclear as to whether land\non the ability to (2) The land must not contain woody biomass or containing weed species authorised by law to be cleared but which also provided\nremove weed species an invasive native scrub species that need to be forest cover (>20% crown cover from stems >2m tall) at any point in the preceding 5\nthat have met the cleared in order for planting to occur, other than years can be included within the CEA.\ndefinition of ‘forest known weed species required or authorised by\ncover’ in any of the 5 law to be cleared. GreenCollar suggests considering adding the words ‘native vegetation that has\nyears preceding (3) For at least 5 years before the date of the achieved’ before ‘forest cover’ in subsection 10(3) of the Draft Method to ensure\nproject application under section 22 of the Act in relation subsections 10(2) and 10(3) work to allow the removal of weed species authorised by\ncommencement. to the project, the carbon estimation area must law to be cleared prior to project start regardless of the forest cover status of the\nhave been clear of forest cover. known weed species authorised by law to be cleared. In addition to recommendations\n#6, this suggestion may also provide a solution for any other non-native forest cover\nvegetation that may have been impacted by catastrophic wildfire and subsequently\nunable to regenerate.\n\nGreenCollar also notes that given the ‘currency’ of an ACCU project is carbon/GHG\nemissions and the removal of non-native woody vegetation will still result in the loss\n# Item Relevant Method Section/s Feedback\nof carbon stock and release of GHG emissions, consideration should also be given to\nwhether a deduction of carbon stock and emissions is required i.e. starting the project\nin a carbon ‘debt’.\n\nConsideration for such a deduction should be based on;\n(a) whether the removal of non-native forest cover was reasonably within control of\nthe project participant (wildfire versus deliberate removal of weeds);\n(b) materiality of carbon stock removed; and\n(c) perceived likelihood of removal occurring in the business as usual scenario, e.g.\nwould removal of weeds authorised by law to be cleared happen in the BAU\nscenario due to NRM plan adherence?\n\nIf the above suggestions are unable to be incorporated into the Draft Method, we\nsuggest a clarification note be added to section 10 to make it clear that each sub-\nsubsection of section 10 must be satisfied independently.\n\n6 Risk that business as s10 Land on which project is implemented In order to be eligible land under the Environmental Planting Method, land is unable\nusual scenario would to spontaneously regenerate native vegetation i.e. a ‘zero baseline’ carbon stock.\nresult in material\ncarbon sequestration. In addition to s10(2) and s10(3), we suggest considering whether an additional eligible\nland criteria could be included that requires demonstration that the land;\n(a) was managed under a non- forest land use during the baseline period; and\n(b) is not in an abandoned state possessing in situ native seed stock at project\ncommencement.\n\n7 Requirements for an s18 Requirements for an exclusion area As a model-based method, ensuring the accuracy of the CEA polygon boundaries is\nexclusion area Land in each project area on which permanent critical to the correct application of the model for estimating eligible abatement. The\ndescribed by CFI plantings are not to be established must be understood intent behind the CFI Mapping Guidelines requirements for excluding\nMapping Guidelines defined and mapped as an exclusion area in features without forest cover greater than 5m is to ensure that CEA boundaries do\nprohibit the ability to accordance with the CFI Mapping Guidelines. not include significant area that should not be modelled. However, in some cases the\nplant large canopy canopy expansion (at maturity) of the given species may mean the stems can be\nstems in low stem 3.2.2 of CFI Mapping Guidelines Defining and planted more than 5m apart at a relatively lower stem density and still satisfy forest\ndensity plantings such mapping Exclusion Areas that states: Areas of potential, which then results in unnecessary CEA proliferation and exclusion of the\nas those seeking to land without forest cover must be identified as bare earth between rows of stems which should be part of the CEA.\n# Item Relevant Method Section/s Feedback\nreplicate natural Exclusion Areas: features greater than five\ntemperate open metres in width. We note that updates to the CFI Mapping Guidelines were not included in the public\nwoodlands consultation documentation pack and suggest consideration be given to an update\nthat still meets the intent of the original restriction such that features greater than 5m\nare not considered as exclusion areas if they can be demonstrated that they can meet\nforest cover potential at the required scale.\n\n8 Risk of deviation s10(4) Land on which project mechanism is The current Environmental Planting Method is not covered by the 2019 CER guidance\nbetween modelled implemented – Project trees will have the on stratification, evidence and records, nor does s9AA of the CFI Rule apply to\nbiomass and observed potential to obtain a height of 2 meters or more Environmental Planting projects as they are not ‘regeneration projects’. As such, a\nbiomass and a crown cover of at least 20% over the total pre-determined forest cover attainment date and associated gateway checks are not\narea of the stratum in which the project trees applicable to Environmental Planting projects. These requirements were introduced\nare located. to regeneration projects to safeguard against a concern that there may be a deviation\nbetween biomass achieved on the ground versus what is assumed /estimated by\ns17(3) CEA planting requirements – the planting FullCAM.\nin the CEA must still have forest potential no\nlater than 12 months after the planting date. Existing equivalent safeguards for alignment between FullCAM assumptions and on\nground accumulation are dispersed throughout the Draft Method under various\ns19(2)(c) Re-stratification of a CEA – a CEA must forest potential requirements (see previous column). However, it remains unclear\nbe re-stratified if parts of a planting within the how the Draft Method ensures forest cover will be attained prior to crediting period\narea fail to achieve forest potential. end i.e. that the ‘anticipated crown cover at maturity’ has actually been reached.\n\ns79(a) Data collection – a project proponent We suggest that stocking density and anticipated crown cover at maturity could be\nmust collect and record data on forest potential. complimented with a requirement to undertake either:\n(a) biomass inventory surveys; or\ns85(1)(a) Forest management records – A project (b) crown diameter measurements (either on-ground or spatial analysis when\nproponent must collect and maintain records for possible),\neach CEA evidence of forest potential including within the carbon estimation areas to demonstrate growth is continuing to occur i.e.\nestimated stocking density and anticipated progress towards mature crown diameter is being made prior to achieving forest\ncrown cover at maturity. cover.\n\nTable 1 of the explanatory statement – guidance\non the minimum number of trees per hectare to\nachieve 20% crown cover in a stand of trees\n# Item Relevant Method Section/s Feedback\n\n9 Typos on equation s51 Calculating probable limits of error for tree We believe references to Equation 8 and Equation 7 for ERi and Ri respectively should\nreferences in proportion be referencing Equations 9 and 8 respectively.\ncalculating probable\nlimits of error for tree\nproportion\n\n10 Typos on equation s52 Calculating conservative estimate of tree We believe references to Equation 7 and Equation 9 for Ri and sRI respectively should\nreferences in proportion be referencing Equations 8 and 10 respectively.\ncalculating\nconservative estimate\nof tree proportion\n\n11 Method for s57 Permitted biomass removals GreenCollar supports the intent to allow a modest commercial harvest of fruits,\ndemonstrating Biomass may be harvested: seeds, nuts and leaves to occur and agrees that restricting the quantum of harvested\npermitted biomass (a) to remove up to 10% of fallen timber in a products to percentage threshold of what is available within a calendar year is an\nremovals do not calendar year for personal use; or appropriate measure to ensure any harvesting will not impede the biomass\nexceed permissible (d) to remove fruits, nuts, seeds, or material used accumulation in a material way.\nthresholds not for fencing or as craft materials (other than\nprovided woody products), provided no more than 10% of However it is noted that there is a lack of guidance within the Draft Method, draft\nany fruits, nuts, seeds or leaves present on a explanatory statement and draft simple method guide that outlines what methods\ntree or shrub are harvested in a calendar year will be considered acceptable for demonstrating that the percentage threshold has\n(whether for personal or commercial use) not been exceeded. It is important for proponents to have a clear understanding of\n(e) to remove up to 10% of woody products to evidentiary requirements associated with this new permitted activity to assess\nbe used for fencing or as craft materials in a commercial feasibility in a way that is compliant with the requirements of the method\ncalendar year for personal use and the Offset Integrity Standards.\n\n12 Inability to account for s5 the definition of ‘modelling We query whether there is a conflict between the requirement to start a FullCAM\nthe emissions commencement’ means the commencement event queue with the planting event and the requirement to account for emissions\nassociated with site date used for modelling forest growth in due to biomass burning. If a cool burn is conducted as part of the site preparation,\npreparation events – FullCAM, and is the planting date for each there is no way to model this in a compliant way to try and account for the burn\nparticularly cool burns carbon estimation area. emissions.\n\ns60 Use of lime or fertilizer\n# Item Relevant Method Section/s Feedback\n(3) an initial fertilizer application must not be\nmodelled as a management event in FullCAM\n\ns65 and Schedule 1 includes the GHGs associated\nwith fire (planned or unplanned).\n\ns88(c) The first offsets report requires the total\nemissions due to biomass burning for the\nproject to be deducted).\n\ns2.5.1.1 of the Draft FullCAM Guidelines states\nthat “All project modelling must commence with\na Plant Trees event”\n\ns2.5.2 of the Draft FullCAM Guidelines states\n“Note that forest treatment activities, such as\nweed control or fertilisation, must be undertaken\nin accordance with the requirements and\nrestrictions of the Determination. However, these\nevents may not be modelled in FullCAM. This is\nbecause the calibration data sets for FullCAM\n2020 did not isolate the impact of these\nmanagement activities. The effects of forest\ntreatment activities are assumed to be\nrepresented within the calibrations applicable in\nthis guideline.”\n\n13 Transitioning project s62(3) transitioning project means means a Both the draft simple method guide and previous CER guidance for scheme\ndefinition – possible project that meets the following requirements: participants impacted by the expiry of an ACCU Scheme method2 confirm\ntypo GreenCollar’s understanding that only projects that had already started their\n\n2\nhttps://cer.gov.au/document/guidance-accu-scheme-participants-impacted-expiry-or-sunsetting-accu-scheme-\nmethod#:~:text=Projects%20that%20are%20registered%20under,to%20the%20Clean%20Energy%20Regulator.\n# Item Relevant Method Section/s Feedback\n(a) the project area or the project areas for the crediting period prior to method expiry date would eligible to transition to a\nproject are identical to the project area or the replacement method.\nproject areas described in the section 27\ndeclaration for an eligible offsets project (the However item (b) within the definition of transitioning projects within section 62 of\ninitial project) to which the Carbon Credits the Draft Method conflicts with this understanding. This needs to be clarified.\n(Carbon Farming Initiative) (Reforestation by\nEnvironmental or Mallee Plantings—FullCAM)\nMethodology Determination 2014 (the initial\ndetermination) applied;\n(b) the start time of the crediting period for the\ninitial project had not occurred before or on the\ndate the initial determination expired or was\nrevoked;\n(c) the Regulator has revoked the section 27\ndeclaration in relation to the initial project under\nregulations or legislative rules made for the\npurposes of section 33 or 35 of the Act.","size":322890,"redacted":[],"meta":{"name":"09_GreenCollar_Redacted.db43379f.pdf","local_path":"files/lTV4UY_lIz9kODp4sDO65vUF.pdf"},"config":{}},"fil2f4abf2a2519091afd02f":{"id":"fil2f4abf2a2519091afd02f","bucket":"files-au-climate","remote_path":"climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/20240419_GreenCollar_Remake_of_the_Environmental_Plantings_Method.2527b734.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/20240419_GreenCollar_Remake_of_the_Environmental_Plantings_Method.2527b734.pdf","filename":"20240419 - GreenCollar - Remake of the Environmental Plantings Method.pdf","transcribed":"19 April 2024\nEmissions Reduction Division\nDepartment of Climate Change, Energy, the Environment and Water via email: ACCUMethods@dcceew.gov.au\n\nDear Method Development Team,\n\n\nRE: Feedback on the redevelopment of the Reforestation by Environmental or Mallee Plantings –\nFullCAM Method\n\nGreenCollar thanks you for the opportunity to provide feedback on the Carbon Credits (Carbon Farming\nInitiative) (Reforestation by Environmental or Mallee Plantings—FullCAM) Methodology Determination\n2014 (the ‘Environmental Planting Method’) which is currently scheduled to expire on 1 October 2024.\n\nDCCEEW recently announced an intention to make a subsequent version of the Environmental Planting\nMethod and invited public feedback on the ‘remake,’ particularly feedback which would improve the practicality of the Method.\n\nGreenCollar strongly supports the decision to remake the Environmental Plantings Method and\nDCCEEW’s action in promptly seeking public feedback and commencing consultation.\n\nGreenCollar’s feedback is set out below in Table 1 and we note we have also engaged with other organisations in the consideration of these issues. We trust this feedback is helpful in processes to remake the Method\n\nIf you have any questions or would like to discuss the submission further, please contact Rachel Chiswell at Rachel.chiswell@greencollar.com.au or me at any time.\n\nThank you again for the invitation to provide input into this process and for considering our feedback.\n\nYours sincerely,\n\n\n\n\nNerida Bradley\nChief Impact Officer\nP: +61 414 966 129\nE: nerida.bradley@greencollar.com.au\nW: www.greencollar.com.au\n\n\n\nI acknowledge and pay my respects to the Widjabal people of the Bundjalung Nation on whose land I live and work. GreenCollar respectfully acknowledges all Traditional Owners and Custodians of the Country on which we work.\n\f Summary of feedback items with the current Environmental Plantings method.\n\n\n# Item Category Relevant Method Section/s Feedback\n1 Restricted ss1.3 Definition of ‘permanent planting’, which Shortage of supply of native seed is a potential barrier to establishment of restoration plantings at\n Activities is defined as: scale. The future demand for seed will be difficult to meet from wild harvest alone1.\n a planting:\n (a) that is not harvested other than:…. Consideration should be given to lifting the restriction on the harvesting of seeds, nuts and fruits for\n (iii) to remove firewood, fruits, nuts, sale under the method. Any change to permit this needs to be on the basis that collection does not\n seeds, or material used for fencing or as craft inhibit secondary recruitment, i.e. permanence, and/or inhibit the attainment of forest cover.\n materials, if those things are not removed for\n sale; or The removal of biomass associated with fruit, nut and seed collection is generally considered to be\n immaterial in relation to the net carbon stock change. Likewise, additional revenue obtained from\n ss1.4 Kind of project to which this fruit, nut and seed collection is not so great as to challenge the additionality of the project.\n Determination applies….\n One option to addressing risk of perverse environmental outcomes from commercial seed\n (a) the establishment of a permanent\n harvesting is to require seed be collected by a relevant State/Territory certified and/or licensed\n planting that could reasonably be\n expected to result in eligible carbon seed collector. Regulation generally required certified collectors to leave sufficient seed to enable\n abatement; or the forest to self-regenerate. There are also guidelines, such as the Flora Bank Guidelines2 that\n provide information on ethical collection practices. This would be supported by the existing\n ss2.2 Project mechanism monitoring requirements and track of forest cover attainment over the course of the crediting\n The project must establish by planting, and period.\n maintain, the following types of permanent\n To enable this change, options include:\n plantings:\n (a) a mixed-species environmental planting; or - amend the definition of ‘permanent planting’ in the new Environmental Plantings Method and\n (b) a mallee planting. the CFI Rule; or\n - create a new definition in the new Environmental Plantings method; or\n ss3.46 Other permitted removals of the REMP - remove reference to the term ‘permanent plantings’ and refer directly to the specific definitions\n method – Biomass may be harvested: (c) to of mallee plantings and mixed-species environmental plantings as provided in the existing\n remove fruits, nuts, seeds, or material used for Environmental Plantings Method, which for the latter, is also the same definition of an\n fencing or as craft materials, if those things are environmental planting as defined in the CFI Rule.\n not removed for sale\n It is important to note that Native Title holder rights can include the right to collect resources for\n any purpose and care should be taken to ensure that the fruit, nut and seed restrictions in carbon\n farming methods do not impact these rights in accordance with s301 of the CFI Act.\n\n\n\n\n 1\n Hancock, N., Gibson-Roy, P., Driver, M., Broadhurst, L. (2020). Australian Native Seed Sector Survey Report, Australian Network for Plant Conservation, Canberra.\n 2\n Florabank Guidelines, FLORABANK-GUIDELINES_collection-methods.pdf (greeningaustralia.org.au)\n\n 1\n\f Summary of feedback items with the current Environmental Plantings method.\n\n\n# Item Category Relevant Method Section/s Feedback\n We also note that ss1.4 and ss2.2 would need to refer to the new definition (if opted for) and\n subsection ss3.46(c) would need to be removed.\n\n\n\n2 Newness CFI Act ss27(4A)(a)(ii) in lieu of newness Need to address perceived restriction on purchasing seed/ tube stock prior to declaration regarding\n requirements could be added to Part 2 of the newness and final financial investment. To do this, it would be beneficial to provide further clarity\n new Environmental Plantings method. by way of additional examples of ‘planning’ activities that do not constitute a final financial\n investment.\n\n Pre-purchase of seed/ tube stock including seed harvesting, is not included on either the list of\n ‘activities not permitted prior to project registration’ or the list of ‘activities permitted prior to\n project registration list’ on the CER website. As such there is some ambiguity regarding these\n activities.\n\n The Method and/or guidance material would benefit from further clarity and/or an exception\n regarding these types of activities, given the significant lead times and narrow seed harvesting\n and/or planting windows associated with Environmental Planting projects. To enable this change,\n options include:\n - include additional guidance material giving more detail on what ‘planning’ activities are\n intended to be permitted and under what circumstances they would or would not be considered\n final financial investments; or\n - include an ‘in lieu of newness’ provision to allow for certain activities prior to project Declaration\n could be added to Part 2 of the new Environmental Planting Method. Similar to the ‘in lieu of\n newness’ provision in ss35 of the 2022 Plantation Forestry method, however in this instance it\n would be beneficial to extend the timing of such a provision beyond the period between project\n application and declaration, for example 12 months prior to project application.\n\n\n3 Newness Need to address inability to conduct ground preparation activities between s22 project application\n and s27 declaration issuance. To do this, it would be beneficial to create a ‘in lieu of newness’\n provision within the new Environmental Plantings method, to allow for certain pre-planting\n activities (e.g. weed control, soil ripping) prior to project Declaration.\n\n Planting windows and the associated preparation works are highly seasonal and can be narrow and\n require significant planning lead times. The CER may take up to 90 days from either project\n\n\n 2\n\f Summary of feedback items with the current Environmental Plantings method.\n\n\n# Item Category Relevant Method Section/s Feedback\n application or RFI, meaning there can be significant delay to a planned ground preparation or\n planting activity.\n\n To enable this change, an ‘in lieu of newness’ provision to allow for certain pre-planting activities\n (e.g. weed control, soil ripping) prior to project Declaration (but not prior to the project application\n date) could be added to Part 2 of the new Environmental Plantings Method. Similar to the in lieu of\n newness provisions in ss35 of the 2022 Plantation Forestry Method, and ss16 of the 2021 Soil\n Carbon Method.\n4 Known weed ss2.3(3) Land on which project mechanism is Need to address ambiguity regarding ‘known weed species required or authorised by law to be\n species implemented – land must not contain woody cleared’ are restricted to only weed species that are on declared national or state government lists,\n biomass or an invasive native scrub species that or is flexible to accommodate more localised instances of weeds.\n need to be cleared in order for planting to\n occur, other than known weed species The current Environmental Plantings Method does not provide a definition for ‘known weed\n required or authorised by law to be cleared. species’ nor does it cross-reference the definition provided for ‘known weed species’ in the CFI\n Rule. The clause related to weeds as it currently stands, is potentially prohibitive to the removal of\n undesirable vegetation (that are unlikely to yield significant or permanent carbon stocks) that could\n be replaced by mixed environmental plantings species more reflective of the landscape.\n\n The new Environmental Plantings Method should cross reference the CFI Rule’s definition of ‘known\n weed species’ to provide clarity and also could consider including a ‘note’ indicating some flexibility\n at the regulators discretion around species that are known by LLS or equivalent, but not yet listed\n on the declared registers.\n\n5 Land on which ss1.3 Definitions of ‘native vegetation’ and Consideration should be given to whether proponents should have the ability to remove ‘known\n project ‘forest cover’ weed species’ prior to planting, even if they have formed forest cover. Currently ss2.3(4) presents a\n mechanism is barrier to developing environmental planting projects on degraded lands that are dominated by\n implemented ss2.3(4) Land on which project mechanism is weed species that may be providing forest cover, thus preventing the ability to plant a more\n implemented – project area must have been permanent and ecologically desirable species mix.\n clear of forest cover for at least 5 years before\n the date of project application. Additionally, ss2.3(4) also requires that project land that had forest cover but has been recently\n (within 5 years) impacted by wildfire and has not, or is not likely to regenerate naturally, is required\n to wait 5 years until a project application can be submitted.\n\n In cases where a wildfire has killed non-native vegetation (e.g. Pinus radiata) on an area of land that\n had reached forest cover prior to the wildfire, the method currently does not allow for the timely\n native restoration of this land that was previously covered in non-native vegetation. To enable this\n\n\n 3\n\f Summary of feedback items with the current Environmental Plantings method.\n\n\n# Item Category Relevant Method Section/s Feedback\n change, the words ‘native vegetation that has achieved’ could be added before ‘forest cover’ in\n ss2.3(4) of the new Environmental Plantings Method to ensure ss2.3(3) and ss2.3(4) work in tandem\n to allow the removal of known weed species prior to project start regardless of the forest cover\n status of the known weed species. This addition would also provide a solution for the non-native\n forest cover vegetation that may have been impacted by wildfire and unable to regenerate naturally\n example.\n\n Consideration should also be given to, in the case of deliberate removal of a weed species that\n provided forest cover in any of the 5 years prior to the project, if a deduction of weed species\n carbon stock is required via either a project emission deduction or initial carbon stock deduction.\n Consideration for such a deduction should be based on both materiality and perceived permanence\n of weed species carbon stock, i.e. would it have been at risk of removal in the BAU scenario due to\n NRM plan adherence?\n\n Further consideration should be given to the approval of environmental planting projects where\n evidence can be provided to the Regulator that demonstrates wildfire has removed non-native\n forest cover within 5 years of the application date, and natural regeneration has not or is not likely\n to occur.\n\n6 Land on which ss2.3(3) Land on which project mechanism is Strengthening the safeguards within the method to ensure eligible land only includes land that is\n project implemented – land must not contain woody unable to regenerate any native vegetation in the absence of the project activities. It is understood\n mechanism is biomass or an invasive native scrub species that the assumption for eligible land under the Environmental Planting Method, is that the land is\n implemented that need to be cleared in order for planting to unable to spontaneously regenerate native vegetation i.e. a ‘zero baseline’ carbon stock.\n occur, other than known weed species required\n or authorised by law to be cleared. In addition to ss2.3(3) and ss2.3(4), and given other suggestions above and below, the new\n ss2.3(4) Land on which project mechanism is Environmental Planting method could consider an additional eligible land criteria that would require\n implemented – project area must have been the land to have been used as a non- forest land use during the baseline period, and also that the\n clear of forest cover for at least 5 years before land is not ‘abandoned’ but possessing in situ native seed stock at project start.\n the date of project application.\n\n7 Exclusion ss3.7 Requirements for an exclusion area Need to address incorrect classification of areas that have >5m spaces between trees within a CEA\n Areas as exclusion areas due to a specific requirement in the CFI Mapping Guidelines. This is particularly\n ss3.2.2 of CFI Mapping Guidelines Defining and to woodland plantings that have large trees (and slow growth) with significant canopies (also slow\n mapping Exclusion Areas that states: Areas of growth) whereby tree spacing is typically larger than plantings for other ecosystems.\n land without forest cover must be identified as\n\n\n\n 4\n\f Summary of feedback items with the current Environmental Plantings method.\n\n\n# Item Category Relevant Method Section/s Feedback\n Exclusion Areas: features greater than five As a model-based method, ensuring the accuracy of the CEA polygon boundaries is critical to the\n metres in width. correct application of the model for estimating eligible abatement. The understood intent behind\n the CFI Mapping Guidelines requirements for excluding features without forest cover greater than\n 5m is to ensure that CEA boundaries do not include significant area that should not be modelled.\n However, in some cases the canopy expansion (at maturity) of the given species may mean the\n stems are planted more than 5m apart, which then results in unnecessary CEA proliferation.\n\n To enable a change that still embodies the intent of the original restriction, the CFI Mapping\n Guidelines exclusion area wording could be adjusted to ‘features greater than five metres in width\n where the project activity cannot be applied (e.g. rocky outcrops, access road, infrastructure etc).\n Such that features greater than 5m are not considered in the above if it can be demonstrated that\n they can meet forest cover potential at the required scale.\n\n\n8 Uniformity ss3.3 (2) Requirements for a carbon estimation Requirement for uniform site characteristics within a CEA should be more explicitly linked to the\n requirements area - A carbon estimation area must: (a) have FullCAM modelling sensitivities. As per 2023 CER Guidance on combined CEAs in regeneration and\n uniform site characteristics in relation to the environmental planting projects, “representativeness, above centrality, is the primary factor in the\n following... selection and placement of a model point”. This guidance defines representativeness as able to be\n demonstrated by using the location closest to the mean or median maximum biomass value within\n Ss3.8(2)(a) - Re-stratification of a carbon a CEA, due to the maximum biomass (M) layer being the primary input to determining carbon\n estimation area – a CEA must be re-stratified if abatement in RMT and FullCAM.\n the site characteristics in the area are no\n longer uniform. Consideration should be given regarding incorporating this concept into the uniformity\n requirements of the CEA in the new Environmental Plantings Method, for example ss3.3(2)(a) could\n be changed to ‘have uniform site characteristics such that any model point location within the CEA\n is representative of the broader CEA polygon/s for modelling purposes with respect to reasonable\n assumptions around growth dynamics, for example; soil type, aspect and slope’.\n\n9 Uniformity ss3.3(3)(a) – Requirements for a carbon Remove the requirement to break up CEAs into areas with 1.5km radius. Requiring CEA polygons to\n requirements estimation area – polygon radius for a mixed fit within a 1.5km radius creates unnecessary CEA proliferation, particularly when the requirements\n species environmental planting – 1.5 for uniformity under ss3.3(2) and exclusion areas under ss3.7 are already safeguarding against\n kilometers. variation within a CEA. The suggested changes described in Item 8 above would further negate the\n need for a defined radius. To enable this change, options include:\n 1) Remove 3.3(3)(a), or\n 2) Increase the radius size for environmental plantings.\n\n\n\n 5\n\f Summary of feedback items with the current Environmental Plantings method.\n\n\n# Item Category Relevant Method Section/s Feedback\n10 Re- ss2.3(5) Land on which project mechanism is Forest cover attainment requirements could go beyond reporting on stem density based on\n stratification implemented – Project trees will have the anticipated crown cover at maturity. The current Environmental Planting method is not captured\n requirements potential to obtain a height of 2 meters or by the 2019 CER guidance on stratification, evidence and records, nor does ss9AA of the CFI Rule\n – forest more and a crown cover of at least 20% over apply to Environmental Planting projects as they are not ‘regeneration projects’. As such, a pre-\n potential the total area of the stratum in which the determined forest cover attainment date and associated gateway checks are not applicable to\n project trees are located. Environmental Planting projects. These requirements were introduced to regeneration projects to\n safeguard against a concern that there may be a deviation between biomass achieved on the\n ss3.6(3) CEA planting requirements – the ground versus what is assumed /estimated by FullCAM.\n planting in the CEA must still have forest\n potential no later than12 months after the The existing equivalent safeguards for alignment between FullCAM assumptions and on ground\n planting date. accumulation are dispersed throughout the current Environmental Planting method under various\n forest potential requirements (see previous column). However, it remains unclear how the method\n ss3.8(2)(c) Re-stratification of a CEA – a CEA ensures that forest cover is attained prior to crediting period end i.e. that the ‘anticipated crown\n must be re-stratified if parts of a planting cover at maturity’ has been reached in the event that stocking density based on ‘anticipated crown\n within the area fail to achieve forest potential. cover at maturity’ is used to satisfy ongoing forest potential throughout the project.\n\n ss4.16(a) Data collection – a project proponent Stocking density and anticipated crown cover at maturity could be improved with either:\n must collect and record data on forest a) Biomass inventory data, or\n potential. b) crown diameter measurements (either on-ground or spatial analysis when possible),\n within the carbon estimation areas to demonstrate growth is continuing to occur prior to achieving\n ss5.5(a)(i) Forest management records – A forest cover.\n project proponent must collect and maintain\n records for each CEA evidence of forest\n potential including estimated stocking density\n and anticipated crown cover at maturity.\n\n Table 1 of the explanatory statement –\n guidance on the ratio of trees to crown cover\n for a given crown diameter.\n\n11 Pre-project ss4.3 Fire (planned or unplanned) is included in FullCAM is currently unable to model and deduct GHGe from ‘cool burns’ as part of site preparation\n start date the current EP method (with default emissions prior to the planting date. There is uncertainty around current provisions for differences between\n project values from FullCAM used with a monthly emissions from a 'cool burn’ vs burn windrowing vs wildfire?\n emissions timestep).\n (fire) The new Environmental Planting Method should clarify the requirements for modelling and\n deduction of GHGe associated with all ground prep activities including ‘cool burns’ but\n\n\n 6\n\f Summary of feedback items with the current Environmental Plantings method.\n\n\n# Item Category Relevant Method Section/s Feedback\n ss5.8(c) The first offsets report requires the consideration should be given that the magnitude of GHGe from cool grass fires is likely less than\n total emissions due to biomass burning for the windrowing burning or wildfire.\n project to be deducted which suggests that to\n some extent 'cool burning' for site preparation A review of FullCAM defaults may be required to accommodate cool burns for site preparation.\n or site maintenance has been considered\n (Division 5.4 Offset report requirements, 5.8\n (c), page 47).\n\n12 Supplementar ss1.3 Definition of planting date means for a Supplementary planting is common practice for planting projects in order to increase stem density,\n y planting carbon estimation area, the date on which species diversity and/or structural composition, where required. Currently CEA stratification is\n planting last occurred within the carbon dictated by the last date of planting. If there are areas which elect to carry out supplementary\n estimation area. planting for reasons other than to satisfy ongoing forest potential, according to the definition of\n planting date in s1.3, the note in s3.3 and 4.6(b), this would delay the planting date for the whole\n ss3.3 Note. Project proponents may optionally CEA and/or incur onerous CEA stratification.\n stratify carbon estimation areas based on\n planting date. It should be considered that there are two types of supplementary plantings: ‘infill planting’ and\n 'enrichment planting’. Adding the following definitions to the new Environmental Planting Method\n ss4.6(b) FullCAM input date requires the last would help to clarify the difference between the two types of supplementary planting:\n planting date.\n Infill planting means the establishment of planting (direct seeding and/or tubestock planting) to\n supplement existing a planting and ensure forest cover potential.\n\n Enrichment planting means the establishment of planting (direct seeding and/or tubestock\n planting) to supplement an existing planting for purposes other than forest cover potential (e.g.\n biodiversity outcomes or erosion control).\n\n Our understanding of the CER’s current approach to supplementary plantings for purposes other\n than forest cover potential i.e. ‘enrichment plantings’ would not require a carbon estimation area/s’\n modelling commencement date to restart. This could be formally recognised by the new\n Environmental Plantings Method.\n\n Additionally, a revised definition of planting date could provide further clarity, for example:\n\n planting date means for a carbon estimation area, the date on which planting to achieve forest\n cover potential occurred within the carbon estimation area, including infill planting.\n\n\n\n 7\n\f","size":325753,"redacted":[],"meta":{"name":"20240419_GreenCollar_Remake_of_the_Environmental_Plantings_Method.2527b734.pdf","local_path":"files/IZbdZ7q1myRhT6U15-BVFt2S.pdf"},"config":{}}}}}