{"data":{"id":"sbm312f39446d3bc10ef5835","short_id":35,"created":"2024-10-17T06:18:32.429Z","space_id":"spc2e87423b0413d1fd9c277","project_id":"prj2e872b17b456d5488f86f","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil31da02a9d348b2bbad0f5","zovp5q48":"Corporate Carbon","confirm-that-you_b979c5":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil31da02a9d348b2bbad0f5":{"id":"fil31da02a9d348b2bbad0f5","bucket":"files-au-climate","remote_path":"climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/35_Corporate_Carbon_Redacted.2ba0dd64.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj2e872b17b456d5488f86f/submission/spc2e87423b0413d1fd9c277/35_Corporate_Carbon_Redacted.2ba0dd64.pdf","filename":"35_Corporate Carbon_Redacted.pdf","transcribed":"15 July 2024\nLand, Forest & Blue Carbon Methods Section\nEmissions Reduction Division | Carbon Crediting Branch\nDCCEEW – Department of Climate Change, Energy, the Environment and Water\n\nDear Land, Forest & Blue Carbon Methods Team\n\nRE: Response to the Exposure Draft of the 2024 Environmental or Mallee Plantings Method\nThank you for the opportunity to provide feedback on the recent Draft Reforestation by Environmental or Mallee\nPlantings method 2024. Corporate Carbon appreciates and thanks the DCCEEW team for the excellent work in drafting this new method and the minor changes made to make participation easier.\nAfter discussing the main changes proposed for the new method, we would like to offer the following comments and suggestions for consideration.\n\n1. Proponents can plant both seeds and tube-stock together for linear mixed-species plantings:\na. The determination allows for planting both seeds and tube-stock together for linear mixed-\nspecies plantings. This flexibility is appreciated, but we suggest the method clarifies whether\nthis mix of direct seeding and tube-stock installation will also be allowed for block plantings.\nUnderstanding this will help in better planning and resource allocation for diverse project types.\n\n2. Fruits, nuts, seeds, and leaves from a project can be sold. Only 10% from each tree can be\nharvested each year. Bark, fallen timber and wood cannot be sold.\na. Allowing the sale of non-woody biomass, such as fruits, nuts, seeds, and leaves, is a valuable\naddition that introduces opportunities for new income streams. However, to ensure compliance,\nthe 10% biomass collection limit must be controlled by mechanisms and further regulations. It\nis currently unclear how this 10% limit will be measured or enforced.\nb. To make this more practical, we suggest that the collection of 20% biomass be based on each\nCarbon Estimation Area (CEA) rather than on individual trees. This approach would simplify\nreporting and evidence collection; and support the supply of indigenous seeds to meet the\ngrowing demand for native plantings.\n\n3. Infill planting rules are included:\na. The inclusion of detailed infill planting rules is beneficial for achieving the desired forest cover\ndensity and ecological balance. However, we suggest clarifying specifically, what survival rate\nwill be used as the reference for determining “failed to establish” plantings, and how will this be\nassessed.\nLastly, we emphasise the critical importance of ensuring a seamless transition from the old method to the enforcement of the new one.\n\nThank you for your continued efforts in advancing this method development process in an expedited and participatory manner.\n\nKind regards,\n\nDr Kate Dodds\nGroup Technical Officer\n\nCorporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd\nABN 77 149 699 543  Suite 4, Level 16/25 Bligh St, Sydney NSW 2000\nAFS Licence No: 430199  1300 227 206 info@corporatecarbon.com.au  www.corporatecarbon.com.au","size":156432,"redacted":[],"meta":{"name":"35_Corporate_Carbon_Redacted.2ba0dd64.pdf","local_path":"files/SqxaFQbfbKjAPro2_ea4as38.pdf"},"config":{}}}}}