{"data":{"id":"sbm2f4ae854a9b332bef7eb5","short_id":11,"created":"2024-07-15T05:13:55.625Z","space_id":"spc2e87423b0413d1fd9c277","project_id":"prj2e872b17b456d5488f86f","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil318a898327f162bccbbc3","zovp5q48":"Alinta Energy","confirm-that-you_b979c5":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil318a898327f162bccbbc3":{"id":"fil318a898327f162bccbbc3","bucket":"files-au-climate","remote_path":"climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/11_Alinta_Energy_Redacted.65ffb999.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/11_Alinta_Energy_Redacted.65ffb999.pdf","filename":"11_Alinta_Energy_Redacted.pdf","transcribed":"15 July 2024\n\nACCU Method development team\nDepartment of Climate Change, Energy, the Environment and Water\n\nSubmitted through consultation hub\n\nDraft Reforestation by Environmental or Mallee Plantings Method 2024\n\nAlinta Energy welcomes the opportunity to provide feedback to the Department of\nClimate Change, Energy, the Environment and Water (DCCEEW) on the Draft\nReforestation by Environmental or Mallee Plantings method 2024.\n\nWe are an active investor in energy markets across Australia with an owned and contracted generation portfolio of over 3,300 MW and more than one million electricity and gas customers. We support the Australian Government’s target of net zero emissions by 2050.\n\nOur feedback below pertains to aspects of the:\n• draft Carbon Credits (Carbon Farming Initiative) (Reforestation by\nEnvironmental or Mallee Plantings—FullCAM) Methodology Determination 2024,\nreferred to as ‘the determination,’ and\n• Australian Carbon Credit Unit (ACCU) Scheme simple method guide for\nprojects registered under the Reforestation by Environmental or Mallee\nPlantings Methodology Determination 2024, referred to as ‘the method guide’.\n\nPage/document Relevant text Alinta Energy comment\n\nPage 2/ the It is also possible for existing Alinta Energy suggests that if\ndetermination approved projects to apply to an abatement project is\nmove to a new methodology allowed to move to the\ndetermination under section proposed Integrated Farm\n128 of the Act where their and Land Management\nproject is covered by that new (IFLM) method, the precise\ndetermination. classification of different\nactivity types be maintained.\nThe significantly higher\nbenefits of the Environmental\nPlanning (EP) activity must\nbe recognised under the\nIFLM method over other\nactivities. EP activity has\nhigher costs than other\nabatement activities\nwhereby, it must be\nrecognised distinctively to\nmaintain the premium in\ncarbon credit prices.\n\nPage 7/ the Land management regime is Alinta Energy considers that determination defined to mean a set of the proposed definitions of\nactions including: Land management regime\na) preparation prior to and Management event in\nplanting; the determination are\nb) planting; restrictive and must account\nc) thinning; for other associated\nd) weed control treatment; activities.\nand\ne) the application of For example, Land\nfertiliser; which are management regime can\napplied in a uniform or also include pest and fire risk\nconsistent manner to an management, among\narea of land others.\n\nManagement event is defined Management event may\nto mean a land management include activities related to\nactivity that can be modelled floods and drought\nin FullCAM, such as a planting, management, among\nthinning, harvest, or fire. others.\n\nAlinta Energy recommends\nthat the definitions be\namended as follows:\n\nLand management regime is\ndefined as a set of actions\nincluding, but not limited to:\na) preparation prior to\nplanting;\nb) planting;\nc) thinning;\nd) weed control\ntreatment; and\ne) the application of\nfertiliser; which are\napplied in a uniform\nor consistent manner\nto an area of land\n\nManagement event is\ndefined as a land\nmanagement activity that\ncan be modelled in FullCAM,\nincluding, but not limited to,\nplanting, thinning, harvest, or\nfire.\nPage 36/ the Projects use the version of Alinta Energy considers this method guide FullCAM in force at the end of to be a significant\nthe reporting period. When commercial risk for\nupdated versions of FullCAM abatement projects, which\nare released, projects will be can have very long\nexpected to use those. The operating periods, extending\nEnvironmental Plantings 2024 to over 100 years. Leaving\nFullCAM Guidelines will say abatement projects open to\nwhich version projects must use updates and associated\nto calculate their abatement. reductions in abatement\ncapacity may render them\nProject proponents should be unviable over the project's\naware that FullCAM updates lifetime.\nmay impact their net\nabatement calculations. A Alinta Energy recommends\nproject may have a lower amending the method to\nabatement estimate under a include a maximum\nnew version of the model. This reduction in a project's\nrisk should be taken into abatement potential from its\nconsideration by project baseline abatement at\nproponents in decisions about registration. We recommend\nthe viability of a project. a 2% maximum reduction\nlimit.\n\nAdopting this recommended\namendment would be\nprudent, as significant\nsensitivity to abatement\npotential is incorporated in\nthe existing rules. For\nexample, a project's\nabatement potential is\ncurrently discounted by 5%\nto account for uncertainty.\nAdditionally, for projects\nregistered for 25 years, a\nfurther 20% reduction is\napplied as a permanence\nperiod discount.\n\nPage 9/ the When demonstrating that the Alinta Energy considers the determination primary purpose of the planting statement - “may include\nwas generation of carbon the contracts for the sale of\noffsets, the documentary offsets” – open to\nevidence may include the interpretation and an audit\ncontracts for the sale of offsets and compliance risk.\nand must:\n• be dated no later than 2 The statement permits\nyears after the date the project proponents to\nplantings were provide material that is\nestablished; additional to the\n• show that the carbon requirements supporting their\nrights had been project.\nregistered for the We propose the following\nplantings; and amendment to the method\n• include a statutory text which would achieve\ndeclaration that the the same outcome but\nplantings were entirely remove the interpretation\nprivately-funded. risks:\n\nWhen demonstrating that\nthe primary purpose of the\nplanting was generation of\ncarbon offsets, the\ndocumentary evidence may\ninclude the contracts for the\nsale of offsets and must:\n• be dated no later\nthan 2 years after the\ndate the plantings\nwere established;\n• show that the carbon\nrights had been\nregistered for the\nplantings; and\n• include a statutory\ndeclaration that the\nplantings were entirely\nprivately-funded.\n\nThe proponent may include\nany additional documentary\nevidence necessary to\nsupport the project.\n\nPage 35/ the A failure to establish is when an The method guide is unclear method guide area fails to achieve forest about reintroducing\npotential, or more than 5% of regenerated areas into the\nsaplings in an area die, project Carbon Estimation\nincluding because of a Area (CEA). Alinta Energy\ndisturbance event like a fire. In recommends allowing\nthis case, the failed area of the reintroduction without a\nCEA cannot be rectified by infill ‘project variation\nplanting and must be stratified application process’, which\nout of the CEA. can involve significant\nresources and time, per the\nCarbon Farming Initiative\n(CFI) Act.\n\nPage 27/ the Alinta Energy recommends method guide – that the method guide be\nSection 3.2.4 and amended to include\nPage 14/ the guidance on the proportion determination – of trees and shrubs for major\nPart 3, Division 5, species required per\nSection 21 subregion to estimate the\nproject abatement baseline.\nThe required proportion can\nsignificantly impact the cost\nof project establishment and\ninform the requirements for\necological evaluation and\nfield data selection for a\nspecific calibration.\nFor example, in areas with\nhigh salinity and soil erosion,\nsuch as those in Western\nAustralia, using saltbushes as\nsmall shrubs can significantly\nenhance soil regeneration\nand increase plant survival.\n\nThe method guide requires\nadditional guidance on the\nproportion of saltbushes\nneeded per subregion to\nallow the selection of a\nspecific calibration.\n\nPage 8/ the Ensure you have the consent of The requirement to obtain method guide and anyone with a legal interest in consent from anyone with a\nPage 10/ the the land (eligible interest legal interest in the land method Guide holders). This consent must be before a project applies for\nSection 1.1.3 provided to the Clean Energy registration with the Clean\nRegulator when applying to Energy Regulator could be\nregister a project. interpreted as requiring\nconsent from financial\nand institutions, including\nmortgagees, usually banks.\nYou will need consent from all\neligible interest-holders before This would be onerous and\nyou can submit an offsets inconsistent with current\nreport for your project. These practice, which Alinta\nare stakeholders who hold an Energy considers\ninterest in the land. They may appropriate, requiring\ninclude: consent from the mortgagee\nbefore an offsets report is\n• Any mortgagees — submitted as per Section\ntypically banks. 1.1.3 of the Method Guide.\n\nWe recommend amending\nthe requirements for\nregistering a project to clarify\nthat consent from financial\ninstitutions is not required.\nPage 9/the The project must establish and In our experience, it is\ndetermination maintain a permanent planting possible that a mixed-\nof trees which is one of the species and mallee species\nfollowing: planting is found naturally in\n• a mixed-species a project area.\nenvironmental planting;\nor We understand that both\n• a mallee planting. species can be stratified and\ncalibrated independently in\nOne project must not contain a project for abatement\nboth types of planting. calculations, as stated in the\nsections on Division 4 to\nDivision 9 included in the\ndetermination.\n\nWe are concerned that this\nprovision would exclude that\npossibility.\n\nAlinta Energy recommends\nthe removal of this provision.\n\nThank you for considering our submission. If you want to discuss this further, please get in touch with Karan Sharma .\n\nYours sincerely\n\nGraeme Hamilton\nGeneral Manager, Government & Regulatory Affairs","size":141882,"redacted":[],"meta":{"name":"11_Alinta_Energy_Redacted.65ffb999.pdf","local_path":"files/l4QfC8MVb3W7qxQ4augZ65D9.pdf"},"config":{}}}}}