{"data":{"id":"sbm3715784b724329051ed42","short_id":10,"created":"2025-08-06T12:33:59.154Z","space_id":"spc365e242c7e5fd0432f9db","project_id":"prj365e170def5f008c6d07a","org_id":"org20ee740c8b3c21feb3566","content":{"1um02fv1":"Expanding flexibility of harvesting restrictions within the CEA to encourage landholder uptake (e.g. permitting selective timber, seeds and fruit removal for sale) as the impacts of those activities can be easily quantified and accounted for in a measurement based approach and many landholders need to be able to generate multiple revenue streams from their land beyond the carbon credit payments alone to consider carrying out alternative land use activities such as planting trees. See attached response.","23zvek0s":"fil3715772172436dc02afd7","eg4pgonj":"Modernising the measurement and abatement calculation approach to take advantage of the advancements made since the RA method was first written. See attached response.","ku9eckv0":"Yes - the detail of the measurement and abatement calculation approach is better served as a supplement so it can be kept up to date as new technology emerges. See attached response.","m3yavyyl":"It doesn't need to necessarily be a stand alone method in its own right in terms of unique activity and unique carbon pool, but the thing that is most important to be remade is the ability to have a direct measurement pathway to calculating abatement in woody vegetation. See attached response.","mh2xmjhi":"yes","wojt7moq":"Broadening the approach to include (and stack) with nature markets will improve opportunities for landscape scale restoration in the wetter, high biomass, high diversity regions where projects currently struggle to be commercially viable. See attached response.","y6jaqiks":"Allowing resource extraction (eg timber, seeds, fruit) for sale in carbon and nature projects as the impacts of those activities can be measured and built into models. Many landowners like to be able to generate a long term revenue streams from their land beyond the carbon/nature crediting periods. See attached response.","zovp5q48":"GreenCollar","question-3_2644c5":"This should be considered at the very least equal to the REMP scale, however it would be even larger as this method has a broader applicability due to the fact it isn't constrained with having to conform to FullCAM assumptions e.g. can be used in low stem density planting unlike REMP. Incorporating further suggestions such as the ability to selectively harvest woody material, would in turn further increase abatement potential as it would be more attractive to landholders thus resulting in more uptake. See attached response.","question-4_35a33c":"See above two comments a) modernising measurement approach and b) permitting selective harvest of woody materials. See attached response.","evidence-based_ada510":"Yes - as reflected in the decision to recently remake the REMP method noting that this method does have a slightly expanded scope afforded by the non-reliance on FullCAM which constrains eligibility criteria. See attached response.","issues-related_ade35a":"First Nations (for example Jabalbina, representing the Kuku Yalanji in FNQ) support landscape scale restoration as well as ongoing food and fibre harvest that would deliver long term social and economic co-benefits and downstream industries allowing conservation to co-exist with sustainable use. See attached response.","additional-to-b_89ebd3":"Yes, as reflected in the decision to recently remake the 2014 REMP method which shares the same activity (planting). See attached response.","please-indicate_8ae24a":"See attached response.","will-the-method_394aa6":"Modernisation of the surveying requirements should be strongly considered, as discussed in the technical workshop, leveraging from advances in technology like the use of published allometric universal equations, Lidar surveys etc. Also consideration should be given to taking a hybrid measure-model-measure approach to overcome the lumpy cashflow prospect of a pure measurement only approach. But none of these things should be considered as detracting from conservatism, each element can and should be sufficiently couched in appropriate constraints that result in an overall conservative approach for example the use of a discount in the intermediately 'modelled' years in between measurement events. See attached response.","are-you-aware-of_56cd77":"Yes, REMP 2024 has the same activity and could benefit by the RA remake being the additional module/tool/framework/supplement that describes the measurement based option (and thus expanded eligibility criteria) for an alternative abatement calculation approach. The in progress IFLM (DCCEEW led) and IACNR (proponent led - QLD gov) methods both also include a measurement based approach to abatement calculation and also include planting as an eligible activity. See attached response.","describe-environ_940222":"See attached response.","i-describe-the-c_312f27":"It is no more complex than what is already available. See attached response.","if-the-assistant_1a21c3":"GreenCollar has an interest in actively participating in the remake process. In terms of suggesting an appropriate 'lead' I think all methods are going to be better received if they are not being overtly 'led' by 'industry. See attached response.","if-there-are-con_70f389":"Measurement of actual biomass would enhance method integrity. See attached response.","ii-please-also-d_a62a64":"The method does need appropriate constraints for planting inappropriate plantings e.g. monocultures in areas that naturally should be mixed species, plantings in low water availability regions that cannot support them or would lead to material competition for adjacent natural vegetation. See attached response.","measurable-and-v_99c354":"Yes - more so than a FullCAM only method. See attached response.","project-emission_5f811a":"Yes it should as per all other vegetation based ACCU methods. See attached response.","upload-a-submiss_ecc21b":"fil371577bb9f02d51fb8623","upload-supportin_b2bc9a":"fil371577db1d0272c52f799","would-you-like-t_08a393":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil371577bb9f02d51fb8623":{"id":"fil371577bb9f02d51fb8623","bucket":"files-au-climate","remote_path":"climate-au/p/prj365e170def5f008c6d07a/submission/spc365e242c7e5fd0432f9db/20240419_GreenCollar_Remake_of_the_Environmental_Plantings_Method.e5f5bd4d.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj365e170def5f008c6d07a/submission/spc365e242c7e5fd0432f9db/20240419_GreenCollar_Remake_of_the_Environmental_Plantings_Method.e5f5bd4d.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\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\nNerida Bradley\nChief Impact Officer\nP: +61 414 966 129\nE: nerida.bradley@greencollar.com.au\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 current Environmental Plantings method.\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\nActivities is defined as: scale. The future demand for seed will be difficult to meet from wild harvest alone1.\na 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\nseeds, or material used for fencing or as craft inhibit secondary recruitment, i.e. permanence, and/or inhibit the attainment of forest cover.\nmaterials, if those things are not removed for\nsale; or The removal of biomass associated with fruit, nut and seed collection is generally considered to be\nimmaterial in relation to the net carbon stock change. Likewise, additional revenue obtained from\nss1.4 Kind of project to which this fruit, nut and seed collection is not so great as to challenge the additionality of the project.\nDetermination applies….\nOne option to addressing risk of perverse environmental outcomes from commercial seed\n(a) the establishment of a permanent\nharvesting is to require seed be collected by a relevant State/Territory certified and/or licensed\nplanting that could reasonably be\nexpected to result in eligible carbon seed collector. Regulation generally required certified collectors to leave sufficient seed to enable\nabatement; or the forest to self-regenerate. There are also guidelines, such as the Flora Bank Guidelines2 that\nprovide information on ethical collection practices. This would be supported by the existing\nss2.2 Project mechanism monitoring requirements and track of forest cover attainment over the course of the crediting\nThe project must establish by planting, and period.\nmaintain, the following types of permanent\nTo enable this change, options include:\nplantings:\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\nss3.46 Other permitted removals of the REMP - remove reference to the term ‘permanent plantings’ and refer directly to the specific definitions\nmethod – Biomass may be harvested: (c) to of mallee plantings and mixed-species environmental plantings as provided in the existing\nremove fruits, nuts, seeds, or material used for Environmental Plantings Method, which for the latter, is also the same definition of an\nfencing or as craft materials, if those things are environmental planting as defined in the CFI Rule.\nnot removed for sale\nIt is important to note that Native Title holder rights can include the right to collect resources for\nany purpose and care should be taken to ensure that the fruit, nut and seed restrictions in carbon\nfarming methods do not impact these rights in accordance with s301 of the CFI Act.\n\n1\nHancock, N., Gibson-Roy, P., Driver, M., Broadhurst, L. (2020). Australian Native Seed Sector Survey Report, Australian Network for Plant Conservation, Canberra.\n2\nFlorabank Guidelines, FLORABANK-GUIDELINES_collection-methods.pdf (greeningaustralia.org.au)\n\n1\nSummary of feedback items with the current Environmental Plantings method.\n\n# Item Category Relevant Method Section/s Feedback\nWe also note that ss1.4 and ss2.2 would need to refer to the new definition (if opted for) and\nsubsection ss3.46(c) would need to be removed.\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\nrequirements could be added to Part 2 of the newness and final financial investment. To do this, it would be beneficial to provide further clarity\nnew Environmental Plantings method. by way of additional examples of ‘planning’ activities that do not constitute a final financial\ninvestment.\n\nPre-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\nproject registration list’ on the CER website. As such there is some ambiguity regarding these\nactivities.\n\nThe Method and/or guidance material would benefit from further clarity and/or an exception\nregarding these types of activities, given the significant lead times and narrow seed harvesting\nand/or planting windows associated with Environmental Planting projects. To enable this change,\noptions include:\n- include additional guidance material giving more detail on what ‘planning’ activities are\nintended to be permitted and under what circumstances they would or would not be considered\nfinal financial investments; or\n- include an ‘in lieu of newness’ provision to allow for certain activities prior to project Declaration\ncould be added to Part 2 of the new Environmental Planting Method. Similar to the ‘in lieu of\nnewness’ provision in ss35 of the 2022 Plantation Forestry method, however in this instance it\nwould be beneficial to extend the timing of such a provision beyond the period between project\napplication and declaration, for example 12 months prior to project application.\n\n3 Newness Need to address inability to conduct ground preparation activities between s22 project application\nand s27 declaration issuance. To do this, it would be beneficial to create a ‘in lieu of newness’\nprovision within the new Environmental Plantings method, to allow for certain pre-planting\nactivities (e.g. weed control, soil ripping) prior to project Declaration.\n\nPlanting windows and the associated preparation works are highly seasonal and can be narrow and\nrequire significant planning lead times. The CER may take up to 90 days from either project\n\n2\nSummary of feedback items with the current Environmental Plantings method.\n\n# Item Category Relevant Method Section/s Feedback\napplication or RFI, meaning there can be significant delay to a planned ground preparation or\nplanting activity.\n\nTo 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\ndate) could be added to Part 2 of the new Environmental Plantings Method. Similar to the in lieu of\nnewness provisions in ss35 of the 2022 Plantation Forestry Method, and ss16 of the 2021 Soil\nCarbon 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\nspecies implemented – land must not contain woody cleared’ are restricted to only weed species that are on declared national or state government lists,\nbiomass or an invasive native scrub species that or is flexible to accommodate more localised instances of weeds.\nneed to be cleared in order for planting to\noccur, other than known weed species The current Environmental Plantings Method does not provide a definition for ‘known weed\nrequired or authorised by law to be cleared. species’ nor does it cross-reference the definition provided for ‘known weed species’ in the CFI\nRule. The clause related to weeds as it currently stands, is potentially prohibitive to the removal of\nundesirable vegetation (that are unlikely to yield significant or permanent carbon stocks) that could\nbe replaced by mixed environmental plantings species more reflective of the landscape.\n\nThe new Environmental Plantings Method should cross reference the CFI Rule’s definition of ‘known\nweed species’ to provide clarity and also could consider including a ‘note’ indicating some flexibility\nat the regulators discretion around species that are known by LLS or equivalent, but not yet listed\non 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\nproject ‘forest cover’ weed species’ prior to planting, even if they have formed forest cover. Currently ss2.3(4) presents a\nmechanism is barrier to developing environmental planting projects on degraded lands that are dominated by\nimplemented 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\nimplemented – project area must have been permanent and ecologically desirable species mix.\nclear of forest cover for at least 5 years before\nthe 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\nto wait 5 years until a project application can be submitted.\n\nIn cases where a wildfire has killed non-native vegetation (e.g. Pinus radiata) on an area of land that\nhad reached forest cover prior to the wildfire, the method currently does not allow for the timely\nnative restoration of this land that was previously covered in non-native vegetation. To enable this\n\n3\nSummary of feedback items with the current Environmental Plantings method.\n\n# Item Category Relevant Method Section/s Feedback\nchange, the words ‘native vegetation that has achieved’ could be added before ‘forest cover’ in\nss2.3(4) of the new Environmental Plantings Method to ensure ss2.3(3) and ss2.3(4) work in tandem\nto allow the removal of known weed species prior to project start regardless of the forest cover\nstatus of the known weed species. This addition would also provide a solution for the non-native\nforest cover vegetation that may have been impacted by wildfire and unable to regenerate naturally\nexample.\n\nConsideration should also be given to, in the case of deliberate removal of a weed species that\nprovided forest cover in any of the 5 years prior to the project, if a deduction of weed species\ncarbon stock is required via either a project emission deduction or initial carbon stock deduction.\nConsideration for such a deduction should be based on both materiality and perceived permanence\nof weed species carbon stock, i.e. would it have been at risk of removal in the BAU scenario due to\nNRM plan adherence?\n\nFurther consideration should be given to the approval of environmental planting projects where\nevidence can be provided to the Regulator that demonstrates wildfire has removed non-native\nforest cover within 5 years of the application date, and natural regeneration has not or is not likely\nto 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\nproject implemented – land must not contain woody unable to regenerate any native vegetation in the absence of the project activities. It is understood\nmechanism is biomass or an invasive native scrub species that the assumption for eligible land under the Environmental Planting Method, is that the land is\nimplemented that need to be cleared in order for planting to unable to spontaneously regenerate native vegetation i.e. a ‘zero baseline’ carbon stock.\noccur, other than known weed species required\nor 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\nss2.3(4) Land on which project mechanism is Environmental Planting method could consider an additional eligible land criteria that would require\nimplemented – 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\nclear of forest cover for at least 5 years before land is not ‘abandoned’ but possessing in situ native seed stock at project start.\nthe 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\nAreas as exclusion areas due to a specific requirement in the CFI Mapping Guidelines. This is particularly\nss3.2.2 of CFI Mapping Guidelines Defining and to woodland plantings that have large trees (and slow growth) with significant canopies (also slow\nmapping Exclusion Areas that states: Areas of growth) whereby tree spacing is typically larger than plantings for other ecosystems.\nland without forest cover must be identified as\n\n4\nSummary of feedback items with the current Environmental Plantings method.\n\n# Item Category Relevant Method Section/s Feedback\nExclusion Areas: features greater than five As a model-based method, ensuring the accuracy of the CEA polygon boundaries is critical to the\nmetres in width. correct application of the model for estimating eligible abatement. The understood intent behind\nthe CFI Mapping Guidelines requirements for excluding features without forest cover greater than\n5m is to ensure that CEA boundaries do not include significant area that should not be modelled.\nHowever, in some cases the canopy expansion (at maturity) of the given species may mean the\nstems are planted more than 5m apart, which then results in unnecessary CEA proliferation.\n\nTo enable a change that still embodies the intent of the original restriction, the CFI Mapping\nGuidelines exclusion area wording could be adjusted to ‘features greater than five metres in width\nwhere the project activity cannot be applied (e.g. rocky outcrops, access road, infrastructure etc).\nSuch that features greater than 5m are not considered in the above if it can be demonstrated that\nthey can meet forest cover potential at the required scale.\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\nrequirements area - A carbon estimation area must: (a) have FullCAM modelling sensitivities. As per 2023 CER Guidance on combined CEAs in regeneration and\nuniform site characteristics in relation to the environmental planting projects, “representativeness, above centrality, is the primary factor in the\nfollowing... selection and placement of a model point”. This guidance defines representativeness as able to be\ndemonstrated by using the location closest to the mean or median maximum biomass value within\nSs3.8(2)(a) - Re-stratification of a carbon a CEA, due to the maximum biomass (M) layer being the primary input to determining carbon\nestimation area – a CEA must be re-stratified if abatement in RMT and FullCAM.\nthe site characteristics in the area are no\nlonger uniform. Consideration should be given regarding incorporating this concept into the uniformity\nrequirements of the CEA in the new Environmental Plantings Method, for example ss3.3(2)(a) could\nbe changed to ‘have uniform site characteristics such that any model point location within the CEA\nis representative of the broader CEA polygon/s for modelling purposes with respect to reasonable\nassumptions 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\nrequirements estimation area – polygon radius for a mixed fit within a 1.5km radius creates unnecessary CEA proliferation, particularly when the requirements\nspecies environmental planting – 1.5 for uniformity under ss3.3(2) and exclusion areas under ss3.7 are already safeguarding against\nkilometers. variation within a CEA. The suggested changes described in Item 8 above would further negate the\nneed for a defined radius. To enable this change, options include:\n1) Remove 3.3(3)(a), or\n2) Increase the radius size for environmental plantings.\n\n5\nSummary of feedback items with the current Environmental Plantings method.\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\nstratification implemented – Project trees will have the anticipated crown cover at maturity. The current Environmental Planting method is not captured\nrequirements 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-\npotential the total area of the stratum in which the determined forest cover attainment date and associated gateway checks are not applicable to\nproject trees are located. Environmental Planting projects. These requirements were introduced to regeneration projects to\nsafeguard against a concern that there may be a deviation between biomass achieved on the\nss3.6(3) CEA planting requirements – the ground versus what is assumed /estimated by FullCAM.\nplanting in the CEA must still have forest\npotential no later than12 months after the The existing equivalent safeguards for alignment between FullCAM assumptions and on ground\nplanting date. accumulation are dispersed throughout the current Environmental Planting method under various\nforest potential requirements (see previous column). However, it remains unclear how the method\nss3.8(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\nmust be re-stratified if parts of a planting cover at maturity’ has been reached in the event that stocking density based on ‘anticipated crown\nwithin the area fail to achieve forest potential. cover at maturity’ is used to satisfy ongoing forest potential throughout the project.\n\nss4.16(a) Data collection – a project proponent Stocking density and anticipated crown cover at maturity could be improved with either:\nmust collect and record data on forest a) Biomass inventory data, or\npotential. b) crown diameter measurements (either on-ground or spatial analysis when possible),\nwithin the carbon estimation areas to demonstrate growth is continuing to occur prior to achieving\nss5.5(a)(i) Forest management records – A forest cover.\nproject proponent must collect and maintain\nrecords for each CEA evidence of forest\npotential including estimated stocking density\nand anticipated crown cover at maturity.\n\nTable 1 of the explanatory statement –\nguidance on the ratio of trees to crown cover\nfor 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\nstart date the current EP method (with default emissions prior to the planting date. There is uncertainty around current provisions for differences between\nproject values from FullCAM used with a monthly emissions from a 'cool burn’ vs burn windrowing vs wildfire?\nemissions timestep).\n(fire) The new Environmental Planting Method should clarify the requirements for modelling and\ndeduction of GHGe associated with all ground prep activities including ‘cool burns’ but\n\n6\nSummary of feedback items with the current Environmental Plantings method.\n\n# Item Category Relevant Method Section/s Feedback\nss5.8(c) The first offsets report requires the consideration should be given that the magnitude of GHGe from cool grass fires is likely less than\ntotal emissions due to biomass burning for the windrowing burning or wildfire.\nproject to be deducted which suggests that to\nsome extent 'cool burning' for site preparation A review of FullCAM defaults may be required to accommodate cool burns for site preparation.\nor 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,\ny planting carbon estimation area, the date on which species diversity and/or structural composition, where required. Currently CEA stratification is\nplanting last occurred within the carbon dictated by the last date of planting. If there are areas which elect to carry out supplementary\nestimation area. planting for reasons other than to satisfy ongoing forest potential, according to the definition of\nplanting date in s1.3, the note in s3.3 and 4.6(b), this would delay the planting date for the whole\nss3.3 Note. Project proponents may optionally CEA and/or incur onerous CEA stratification.\nstratify carbon estimation areas based on\nplanting 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\nss4.6(b) FullCAM input date requires the last would help to clarify the difference between the two types of supplementary planting:\nplanting date.\nInfill planting means the establishment of planting (direct seeding and/or tubestock planting) to\nsupplement existing a planting and ensure forest cover potential.\n\nEnrichment planting means the establishment of planting (direct seeding and/or tubestock\nplanting) to supplement an existing planting for purposes other than forest cover potential (e.g.\nbiodiversity outcomes or erosion control).\n\nOur understanding of the CER’s current approach to supplementary plantings for purposes other\nthan forest cover potential i.e. ‘enrichment plantings’ would not require a carbon estimation area/s’\nmodelling commencement date to restart. This could be formally recognised by the new\nEnvironmental Plantings Method.\n\nAdditionally, a revised definition of planting date could provide further clarity, for example:\n\nplanting date means for a carbon estimation area, the date on which planting to achieve forest\ncover potential occurred within the carbon estimation area, including infill planting.\n\n7","size":325753,"redacted":[],"meta":{"name":"20240419_GreenCollar_Remake_of_the_Environmental_Plantings_Method.e5f5bd4d.pdf","local_path":"files/H5Ho67wNlhCgnvXwVrLFuzOO.pdf"},"config":{}},"fil371577db1d0272c52f799":{"id":"fil371577db1d0272c52f799","bucket":"files-au-climate","remote_path":"climate-au/p/prj365e170def5f008c6d07a/submission/spc365e242c7e5fd0432f9db/20240715_GreenCollar_feedback_on_the_2024_Environmental_Plantings_Method_Exposure_Draft_FINAL_1_.d411a751.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj365e170def5f008c6d07a/submission/spc365e242c7e5fd0432f9db/20240715_GreenCollar_feedback_on_the_2024_Environmental_Plantings_Method_Exposure_Draft_FINAL_1_.d411a751.pdf","filename":"20240715 GreenCollar feedback on the 2024 Environmental Plantings Method Exposure Draft_FINAL (1).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 rachel.chiswell@greencollar.com.au 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: +61 414 966 129\nE: nerida.bradley@greencollar.com.au\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":326391,"redacted":[],"meta":{"name":"20240715_GreenCollar_feedback_on_the_2024_Environmental_Plantings_Method_Exposure_Draft_FINAL_1_.d411a751.pdf","local_path":"files/gmWIKbHTIqTmUbLX4SqHddl8.pdf"},"config":{}},"fil3715772172436dc02afd7":{"id":"fil3715772172436dc02afd7","bucket":"files-au-climate","remote_path":"climate-au/p/prj365e170def5f008c6d07a/submission/spc365e242c7e5fd0432f9db/20250805_Response_to_RA_consultation_FINAL_signed.b8e73747.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj365e170def5f008c6d07a/submission/spc365e242c7e5fd0432f9db/20250805_Response_to_RA_consultation_FINAL_signed.b8e73747.pdf","filename":"20250805 Response to RA consultation FINAL signed.pdf","transcribed":"6 August 2025\n\nACCU Secretariat\nThe Department of Climate Change, Energy, the Environment and Water\nJohn Gorton Building\nKing Edward Terrace\nCanberra email ACCUSecretariat@dcceew.gov.au\n\nDear ACCU Secretariat,\n\nRE: GreenCollar submission to Reforestation and Afforestation 2.0 method 2015: Sunsetting review\n\nThank you for the opportunity to comment on the approach to sunsetting the Reforestation and\nAfforestation (RA) 2.0 Method 2015. This submission builds on GreenCollar’s 19 April 2024 and 15\nJuly 2024 submissions on the remake of the Reforestation by Environmental or Mallee Plantings\nFullCAM 2014 methodology (included as part of this submission) and our 31 January 2025 submission to the consultation on sunsetting methods and also includes information prepared by KIPES Pty Ltd.\n\nOverall\nA remake of the sunsetting Reforestation and Afforestation (RA) 2.0 method 2015 is vital to ensure there is a measurement-based option for accounting for carbon sequestration in woody vegetation.\nWithout a remake of the RA method as either a stand-alone method or as a measurement based tool within other methods, options for abatement generation and calculation are currently restricted to the FullCAM only Reforestation via Environmental and Mallee Planting (REMP)1 or Plantation Forests\n(PF)2 Methods.\n\nConsideration should therefore be given to whether the RA method should be remade as a stand alone method or if it is better applied as a measurement-based approach module of, or tool for incorporation within other related methods such as the existing REMP and PF methods and/or the currently in development Integrated Farm Land Management (IFLM) and Improved Avoided Clearing of Native Regrowth (IACNR) methods, both of which propose to incorporate planting as an eligible activity to restore native forest on supressed land.\n\nConsideration should also be given to both;\na) modernising the measurement and abatement calculation approach to take advantage\nof the advancements made since the RA method was first written, including but not\nlimited to;\ni. increasing cost effectiveness of above ground biomass (AGB) measurement\n\n1\nCarbon Credits (Carbon Farming Initiative) (Reforestation by Environmental or Mallee Plantings—FullCAM) Methodology\nDetermination 2024 accessed from https://www.legislation.gov.au/F2024L01473/asmade/text\n2\nCarbon Credits (Carbon Farming Initiative—Plantation Forestry) Methodology Determination 2022 accessed from https://www.legislation.gov.au/F2022L00047/latest/versions\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n1\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nii. published generalised (universal tree & universal shrub) allometric equations3\niii. LiDAR survey methods\niv. A hybrid measure-model-measure approach as an alternative to either FullCAM\nonly or measurement only approaches to abatement calculation.\n\nb) expanding flexibility of harvesting restrictions within the CEA to encourage landholder\nuptake (e.g. permitting selective timber, seeds and fruit removal for sale) as the impacts of\nthose activities can be easily quantified and accounted for in a measurement based approach\nand many landholders need to be able to generate multiple revenue streams from their land\nbeyond the carbon credit payments alone to consider carrying out alternative land use\nactivities such as planting trees.\n\nPlease note this submission uses information prepared by KIPES Pty Ltd for their submission to this consultation.\n\nCurrent context\nTo date4 there have only been 18 projects registered under the RA method, 8 of which have since been revoked, with only 7 unrevoked projects actively crediting – total of ~254,000 ACCUs issued to date. With only 3 unrevoked projects registered since 2016, the methods historical cost base versus credit price and scope overlap with the more cost-effective Reforestation via Environmental or\nMallee Plantings (REMP) method are the primary factors for limited uptake of the method.\n\nIn making decisions on sunsetting and remaking methods the Department should give due consideration on the barriers to use and the likelihood of future method viability with market adjustments. RA is an example of a method that has had low uptake (see above), largely due to the costs of planting (particularly upfront costs), which is likely to increase in viability once the cost of an\nACCU reaches a certain point. This can be observed by the relatively recent uptick in REMP project registrations4, which have shared the same historic cost base versus credit price constraints as the RA method.\n\nAdditionally, historically low method uptake may also be attributable to a perception of complexity around the measurement requirements contained within the previous RA method. Incorporation of advancements in AGB measurement approaches in a remake will assist in overcoming this perception. Particularly consideration of a measure-model-measure hybrid approach to abatement calculation will facilitate uptake on the high biomass/high diversity/high rainfall regions where projects are small, data is poor and growth rates variable. Thereby opening up new opportunities where commercial viability has historically been and is currently low.\n\nLimitations of current model-only approaches within related methods (REMP & PF)\nFullCAM guidelines for REMP and PF methods require generalised Tree Yield Formula (TYF) options\n\n3\nPaul K.I., Roxburgh, S.H., Chave, J., England, J.R., et al. (2016). Testing the generality of total aboveground biomass allometry across plant functional types at the continent scale. Global Change Biology 22, 2106-2124.\n4\nClean Energy Regulator ACCU project and contract register accessed from https://cer.gov.au/markets/reports-and- data/accu-project-and-contract-register with data as at COB 30/06/2025\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n2\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nbased on previous calibrations5,6 to estimate carbon drawdown and its distribution across carbon pools7,8. While cost-effective, this approach has key limitations:\n\n1. Inflexibility: application is restricted to the planting types and stocking densities used in its\ncalibration, excluding many potential project scenarios due to limited calibration data.\n2. Low project-scale precision: Calibration prioritises broad applicability over accuracy, with\nprediction efficiencies often < 60%5,6.\n3. Risk of bias: ACCU estimates may be over-predicted if on ground project conditions differ\nfrom the conditions represented in the generalised calibrations.\n\nUpdating the RA and/or other methods to incorporate the RA inspired measurement based approach with more cost-effective measure-model-measure approaches would broaden eligible projects, unlock co-benefits, and improve confidence in the ACCU Scheme. Noting that GreenCollar has extensive experience with over ten years using measurement based approaches operating as a project proponent of profitable carbon vegetation projects.\n\nAdvantages of continuing a measurement-based approach\nSince the RA method was developed in 2015, research into uncertainties in measuring above-ground woody biomass (AGB) has led to significant improvements in the cost-effectiveness of AGB measurement. RA uses traditional plot-based inventories that record stem diameters and apply allometric models, while recent studies show that, to maximise the accuracy of stand-level AGB estimates, resources are better allocated to improving sampling design and intensity (i.e. stem diameter inventories) rather than sampling trees to develop or validate new allometric models.9,10\nExisting generalised allometric models are typically sufficient for this purpose11.\n\nThe RA Method is a measurement-based method for accounting for carbon sequestered in woody biomass and debris of planted trees. Although this option could remain ‘as is’ in a revised RA method, modernising the method through incorporation of AGB measurement advancements since 2015 and enabling a measure-model-measure hybrid approach would greatly increase cost-effectiveness (and therefore uptake), while also provide a means for on-going model improvements and consistency with Australia’s National Greenhouse Accounts.\n\nSignificant lessons have been learnt in recent years by project proponents through the applications of technology such as LiDAR that provides the ability for detailed and accurate survey measurement\n5\nPaul., K.I., and Roxburgh, S.H. (2020). Predicting carbon sequestration of woody biomass following land restoration. Forest\nEcology and Management, 460, 117838.\n6\nPaul, K.I., Roxburgh, S.H., England, J.R. (2022). Sequestration of carbon in commercial plantations and farm forestry.\nTrees, Forests and People, 9, 100284\n7\nWaterworth, R.M., Richards, G.P., Brack, C.L., Evans, D.M.W. (2007). A generalised hybrid process-empirical model for predicting plantation forest growth. Forest Ecology and Management, 238, 231-243.\n8\nForrester, D.I., England, J.R., Paul, K.I., Rosauer, D.F., Roxburgh, S.H. (2024). Modelling carbon flows from live biomass to soil using the full Carbon Accounting Model (FullCAM). Environmental Modelling and Software, 177, 106064.\n9\nPaul, K.I., Radtke, P., Roxburgh, S.H., Larmour, J.S., Waterworth, R., Bulter, D., Brooksbank, K., Ximenes, F. (2018a).\nValidation of existing allometric models: How to have confidence in the application of existing. Forest Ecology and\nManagement, 412, 70-79.\n10\nRoxburgh, S.H, Paul, K.I. (2024). Comprehensive propagation of errors for the prediction of woody biomass. Methods in\nEcology and Evolution, 16, 197-214.\n11\nPaul K.I., Roxburgh, S.H., Chave, J., England, J.R., et al. (2016). Testing the generality of total aboveground biomass allometry across plant functional types at the continent scale. Global Change Biology 22, 2106-2124.\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n3\n3 Hickson Road, The Rocks, NSW 2000 | T. (02) 9252 9828 | W. greencollar.com.au\nnoting that some of these newer technologies are still undergoing rigorous verification processes.\nHence, it is suggested that there will be a need for specific guidelines for measurement potentially in the form of a supplement, starting with traditional (plot inventories and allometry), and building on this to include newer techniques such as LiDAR sampling over time. Such an approach would also have the potential to broaden the applicability of the RA method and/or other methods incorporating the same framework into geographic areas not covered by other ACCU Scheme vegetation methods.\n\nGreenCollar would welcome the opportunity to provide more detail on measurement based approaches and/or to meet and discuss over the coming months.\n\nFor further information related to this submission please contact Rachel Chiswell at rachel.chiswell@greencollar.com.au\n\nAgain, thank you for the opportunity to provide these responses and comments.\n\nYours sincerely\n\nJames Schultz\nChief Executive Officer\nE: james.schultz@greencollar.com.au\nW: www.greencollar.com.au\n\nTerra Carbon Pty Limited (ABN 69 154 094 470)\n4\n3 Hickson Road, The Rocks, NSW 2000 | T. 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