{"data":{"id":"sbm2f4b6a397cb37e8233621","short_id":21,"created":"2024-07-15T07:35:48.348Z","space_id":"spc2e87423b0413d1fd9c277","project_id":"prj2e872b17b456d5488f86f","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil318a7f3ac7f1037433d9c","zovp5q48":"Woodside 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":{"fil318a7f3ac7f1037433d9c":{"id":"fil318a7f3ac7f1037433d9c","bucket":"files-au-climate","remote_path":"climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/21_Woodside_Redacted.2d6493fc.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/21_Woodside_Redacted.2d6493fc.pdf","filename":"21_Woodside_Redacted.pdf","transcribed":"Please direct all responses/queries to: Woodside Energy Ltd\nVanessa Tran\nE: ACN 005 482 986\nMia Yellagonga\nRef: AJ631485N10D-1427669912-8670\n11 Mount Street\nPerth WA 6000\nAustralia\n12 July 2024 T: +61 8 9348 4000\n\nDepartment of Climate Change, Energy, the Environment and Water www.woodside.com\nAttn: ACCU Method Development Team\n\nDear ACCU Method Development Team,\n\nFEEDBACK ON EXPOSURE DRAFT REFORESTATION BY ENVIRONMENTAL OR MALLEE PLANTINGS METHOD\n2024\n\nWoodside Energy (Woodside) welcomes the opportunity to provide feedback on the exposure draft of the Carbon\nCredits (Carbon Farming Initiative) Reforestation by Environmental or Mallee Plantings – FullCAM) Methodology\nDetermination 2024 (2024 Method).\n\nWe acknowledge that the 2024 Method is intended to address administrative and technical issues and improve the practical operation of the current Carbon Credits (Carbon Farming Initiative) Reforestation by Environmental or Mallee\nPlantings – FullCAM) Methodology Determination 2014 (2014 Method).\n\nHaving considered the exposure draft and associated materials, Woodside has identified further recommendations that have the potential to improve the clarity of, and ease of participation in the 2024 Method. These recommendations are set out in greater detail in Attachment A (Feedback on 2024 Method), but in summary, they are:\n\n• implementing a two-year grace period before project proponents are required to update to an updated tool such\nas the Full Carbon Accounting Method (FullCAM);\n• allowing for the clearing of woody biomass prior to project registration, with amendments to ensure carbon is\naccounted for;\n• focusing the newness requirement on crediting abatement that occurs after registration;\n• clarifying the requirements when modelling fertiliser events in FullCAM;\n• providing sufficient definition to enable removal of biomass in accordance with traditional Indigenous practices;\nand\n• removing, or expanding, the radius requirements for Carbon Estimation Areas.\n\nIn 2018, Woodside established a business unit to develop an offsets portfolio in support of our climate targets and aspirations. The Woodside Native Reforestation Project commenced in 2020 and aims to create biodiverse tree plantings in Australia. To date, Woodside has planted over 10,000 hectares of native trees and shrubs using the 2014 Method.\nReforestation of the relevant land has not only allowed for increased habitat connectivity through restored landscape linkages, but has also provided employment opportunities for communities.\n\nWoodside looks forward to continued engagement on the 2024 Method and on the Australian Carbon Credit Unit\nScheme generally.\n\nYours sincerely\n\nJayne Baird\nVice President Carbon Solutions\n\nAttached: Feedback on 2024 Method\nAttachment A – Feedback on 2024 Method\n\nItem Relevant Document(s) Context and Feedback Recommendation\nand Provision(s)\nAdoption of Draft Simple Method We support the adoption of robust, updated modeling tools, as Woodside agrees with CCA’s stance that an adjustment of the updated tools such Guide: recommended by the Climate Change Authority (CCA) in its 2023 balance between providing proponent certainty and ACCU as FullCAM Section 4.1.1 FullCAM ACCU Scheme Report. Scheme integrity is required. We support implementing the\nmodelling CCA’s recommendation to introduce a two-year grace period\nThe CCA’s recommendation noted that there is a balance to be before project proponents are required to adopt an updated\nstruck between the ability to confidently invest in carbon projects tool such as FullCAM.\nand the inherent and perceived integrity of a method and the\nAustralian Carbon Credit Unit (ACCU) Scheme. This balance However, this grace period should not preclude voluntary\nshould, however, be shifted towards integrity with respect to adoption. Furthermore, publication of a guidance note on the\nrequiring project proponents to use the latest version of method frequency and likely impacts (including boundaries) of future\ntools. tool updates could provide a greater degree of certainty to\nmarket participants and, consequently, may lead to an optimal\noutcome for ACCU Scheme reform.\nWoody biomass Draft Simple Method Many areas of land within project boundaries contain woody Woodside acknowledges the need for the Method to account removal prior to Guide: biomass that is not native forest, however, under the current and for carbon that is contained within the biomass of woody project registration Section 1.3: proposed Method, removal and replanting is heavily restricted. weeds and non-native vegetation.\n\nWe understand the concern regarding the removal of carbon stock We recommend allowing the clearing of woody weeds and\nprior to planting, however, current practice can involve removal of non-native vegetation when a conservative discount is applied\nthis woody biomass and, thereafter, waiting the appropriate to the abatement associated with planting that area. This\namount of time (for e.g. five or seven years) before planting. could then allow for compensation in relation to the carbon\nloss associated with the removal of the woody weeds or non-\nDuring this waiting period, heavy management of weed load is native vegetation. This discount could be applied before,\nrequired (for e.g. herbicide spray, mechanical removal, burning, during, or after calculation of abatement within FullCAM.\netc.) to ensure weed coverage remains low and does not\nnegatively impact surrounding Carbon Estimation Areas and\nneighbouring properties.\n\nAllowing for the removal of non-native woody biomass and\nplanting a native species mix is aligned with the intent of the\nMethod as it will result in more sequestered carbon overall and\nsignificantly reduce the negative impact of heavy land\nmanagement practices while waiting the allotted time to plant, all\nof which may result in more rapid land regeneration and\nbiodiversity benefits.\nGround Preparation 2024 Method: We appreciate the additions to the 2024 Method that allow for It is recommended that activities leading up to planting,\nSection 62 ground preparation to occur prior to project registration, and for the including ground preparation, should not be excluded on the\nRequirements in lieu of purchase of seed or seedlings prior to an application to register. grounds of newness.\nnewness requirement We understand the distinction between allowing for the purchase\nof seed/seedlings prior to an application, and allowing ground The distinction made in the 2024 Method between ground\npreparation after an application, is due to newness, as ground preparation and plant preparation on the grounds of newness\npreparation is perceived to be a stronger commitment to a project. does not appear to align with the recommendations made in\nboth the Chubb Review and the 2023 CCA Review of the\nHowever, we are of the view that ground preparation does not ACCU Scheme. The recommendation in both reviews was\nrepresent a stronger commitment to initiate a project than the that that newness should be refocused on crediting\npurchase of seed, seedlings or properties. The cost of ground abatement that occurs after registration. Both reviews also\npreparation is relatively small when compared to the overall costs. made a distinction between new abatement and new activity.\nFurthermore, all three activities have the potential to cease prior to It should also be noted that ground preparation for planting\nplanting if the project registration is unsuccessful. Therefore, it is will likely not result in abatement and, it is submitted that, the\nour view that newness is more clearly drawn when planting commencement of abatement under an environmental\noccurs, as this activity firmly initiates a project. planting method project should be considered to begin at\nplanting.\n\nModelling fertiliser 2024 Method: The documents contain four separate sections that provide Consistent guidance is recommended regarding the events in FullCAM Section 5 Definitions conflicting advice regarding the modelling of fertiliser, namely: implementation of fertiliser and weed events within FullCAM.\nSection 60 Use of lime\nor fertiliser 1. Section 60 of the 2024 Method states that a starter\nSimple Method Guide: fertiliser event (initial fertiliser) cannot be used within the\nSection 3.3.4 Use of first 12 months;\nfertiliser 2. Section 3.3.4 of the Draft Simple Method Guide states\nthat the project proponent must not model fertiliser events\nDraft FullCAM in FullCAM;\nGuidelines: 3. Section 2.4.2 of Draft FullCAM Guidelines states that both\nSection 2.5.2 Adding a fertiliser and weed events may not be modelled in\nNew Event FullCAM; and\n4. Section 5 of the 2024 Method states that fertiliser and\nweed events can be modelled in FullCAM.\nRemoval of 2024 Method: Section 57(f) of the 2024 Method states that biomass may be It is recommended that a definition for ‘traditional Indigenous biomass in Section 57 Permitted harvested in accordance with traditional Indigenous practices. practices’ be provided and/or guidance be provided on how a accordance with biomass removals project proponent must evidence these practices.\ntraditional It is understood that this overrules the ‘10% rule’ for permitted\nIndigenous biomass removal. However, it is unclear how “traditional practices Indigenous practices” are defined.\nCEA Stratification 2024 Method: Typically, in mixed-species environmental planting, large areas of It is recommended that the ‘1.5km radius rule’ be removed or\nSection 14 land composed of identical uniformity requirements (soil type, increased.\nRequirements for a species mix, slope/aspect) are planted. Therefore, when a Carbon\ncarbon estimation area Estimation Area (CEA) is composed of multiple polygons, multiple In light of recent guidance regarding centroid placement, the\nCEAs must be created due to the 1.5km radius rule. relative size of a CEA is not a significant factor when\ncalculating carbon yield when uniformity requirements are\nThe recently released “Combined CEAs in Regeneration and met.\nEnvironmental Planting Projects Guidance” states that, when a\nCEA is composed of more than one part, the centroid location\nshould represent the average above ground biomass value for that\nCEA.","size":192446,"redacted":[],"meta":{"name":"21_Woodside_Redacted.2d6493fc.pdf","local_path":"files/SeTlx6R_gWOhNoZHpSUmVJwW.pdf"},"config":{}}}}}