{"data":{"id":"sbm38de1e76d0f9e473b67ac","short_id":13,"created":"2025-11-03T04:42:19.728Z","space_id":"spc382dafeb34b85b5329242","project_id":"prj371e0e9db9877e9fa53e0","org_id":"org20ee740c8b3c21feb3566","content":{"0hv64c1x":"yes","23zvek0s":"fil3c40fff43f946f2546b88","4ivckqi0":"yes","4lkuslz3":"Reversal risk is predominantly from severe LDS wildfire. Early-dry-season programs materially reduce the frequency and severity of such events. There is no evidence that suggests these projects are at a higher risk of reversal than other projects in the ACCU Scheme (e.g. Environmental Plantings). This is because savanna projects tend to occur over very large areas (average size of currently registered projects is 411,000 ha) lowering the correlation risk (i.e. risk to a single event). On this basis there is no evidence to suggest the buffers should be different to those of other vegetation projects (e.g. Environmental Plantings) and consistency should be preferred.","a8zyi01v":"Support. A 20‑year baseline better captures inter‑annual variability in fire regimes, reduces sensitivity to short anomalous periods, and improves comparability across regions—thereby enhancing integrity and stability of estimates.","gsnanxa1":"The current proposed FullCAM parameters provide an acceptable starting point. However, these should be improved overtime by incorporating new evidence from field measurements across projects. The project measurements should be used to update the M-values in FullCAM on a savanna regional basis and to refine the burn parameters. On a voluntary basis projects should be allowed to use project scale M-values to reconcile project level measurements to biomass to that predicted by FullCAM.","m3yavyyl":"yes","mmf4nfds":"Yes. It recognises First Nations leadership and enables safe, staged adoption of EDS practices without penalising proponents during skill‑building. It supports equitable participation and long‑term integrity by embedding capability before crediting.","qo5c3ymm":"The time frames are generally workable, but for transferring projects the period to manage identified weeds should be extended to cover 6 months following the new project declaration. This is required because the exact timing of the declaration will not be known and weed treatments undertaken before the declaration may not be within the currently required 12 months.","ra27wgan":"Broadly clear and workable. Preserving baselines on transfer, clean separation of project areas, and linked applications reduce ambiguity. The requirement that a transitioning project has submitted an offsets report covering the most recent full calendar year prior to transitioning should be extended to allow the most recent report to cover either the most recent or second most recent calendar year.","ukyyvj9e":"no","v3ccg1pb":"Benefits: greater robustness, reduced volatility, and better alignment with long‑term climate/fire cycles. Challenges: data assembly for legacy areas and clarity for capacity‑building burns—addressed by the draft rules that anchor baselines around the start of capacity‑building periods or registration.","wo7xnuvj":"yes","zovp5q48":"Corporate Carbon","question-3_2644c5":"Yes. Crediting historically-stored carbon is creditable when proponents accept permanence obligations and risk buffers. Transitioning converts past management outcomes into durable climate benefit with liability for reversals; it is additional to business-as-usual because permanence, reporting, and relinquishment obligations did not apply to those stocks under avoidance-only rules.","do-you-consider_439e5b":"Credible and practical with refinements. SavCAM operationalises method formulas, aligns with the National Inventory via FullCAM, and automates complex spatial inputs. Practicality is strong for most users. SavCAM may be improved by having clear pathways for parameter updates, and optional project-level validation/parameterisation (especially of the M-value input layer used in FullCAM).","what-additional_3e58e2":"A short practical guide and template Project Management Plan covering objectives, training milestones, evidence capture (photos/GPS tracks), and a pathway to transition from capacity‑building to crediting; plus dedicated webinars and case studies.","are-the-availabl_55d009":"yes","are-the-proposed_620cb6":"yes","are-the-timefram_bdb880":"no","please-detail-wh_a4f890":"Positive biodiversity and cultural outcomes from reduced LDS fire; economic co‑benefits for remote communities. We support the requirement that transitioning projects require Eligible Interest Holder Consent, including from Traditional Owners. However, additional support is need for these communities to assist them through the consent process. The current support (including funding allocations) is not sufficient.","upload-a-submiss_ecc21b":"fil3c6f714f49973d4620888","what-are-your-vi_f30ea5":"Support. Uncertainty is already addressed through: (a) the emissions-avoidance inter-annual variability buffer; (b) permanence buffers for sequestration; and (c) conservative parameterisation. An extra blanket discount would double‑count uncertainty and needlessly suppress incentives. The FullCAM modelling of savanna projects is no less uncertain than that for other projects types (e.g. Environmental Plantings). In addition, savanna projects are no more risky than other vegetation projects (e.g. Environmental Plantings).","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":{"fil3c40fff43f946f2546b88":{"id":"fil3c40fff43f946f2546b88","bucket":"files-au-climate","remote_path":"climate-au/p/prj371e0e9db9877e9fa53e0/submission/spc382dafeb34b85b5329242/12_b_._Corporate_Carbon_1_Redacted.d1bd04f4.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj371e0e9db9877e9fa53e0/submission/spc382dafeb34b85b5329242/12_b_._Corporate_Carbon_1_Redacted.d1bd04f4.pdf","filename":"12(b). 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