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This submission is written from the perspective of farmers who this year have registered a
carbon project (as part of an aggregated project with a carbon service provider). Our farm is
a mixed sheep and beef operation in Tasmania that now includes agroforestry as well.
Our carbon project is mostly conversion of a short-term planation area (Eucalyptus nitens) to
a long-term plantation (Pinus radiata), with some additional area being converted from non-
forested land to plantation (P. radiata).
Many of the major issues we identified during the application process have been addressed
with the proposed methodology changes.
We are pleased to see that it is now possible for some activities to commence after the
application is submitted but prior to approval being received. This was one of our greatest
frustrations with the 2017 methodology.
Whilst we appreciate that to avoid misuse of the carbon credit process there is a need for the
additionality requirement, it needs to be understood that very rarely do farmers undertake
any activity for one sole purpose. The current wording around additionality and newness has
the potential to be confusing and may discourage landowners from participating.
There are some broader issues that we acknowledge are beyond the scope of this
consultation process. However, one of these issues we felt warranted mentioning as it relates
strongly to the bigger picture of encouraging practices that result in more carbon
sequestration. As mentioned in Appendix 2 a current limitation to the overall carbon farming
policy is that projects can only use a single methodology so for landowners who might be
looking to undertake activities that fit across multiple methodologies it is currently limiting.
In our case when we were looking at options for tree plantings, we identified areas that would
be suitable for plantation species, we also identified some areas that would be suited to
native revegetation plantings. As the two planting types come under different methodologies,
and the revegetation area was not sufficiently large enough to warrant registering as a
separate project, we decided to focus only on the plantation areas. The native revegetation
will likely get planted at some point but possibly not for several years when we have
additional areas and are able to register it as a project. This delay to tree planting goes against
our preferred approach to tree planting which is that the best time to plant a tree was
yesterday. We look forward to seeing how this may change as part of the 2022 method
priorities.
To encourage the uptake of trees on farms the process and requirements need to be able to
be applied to projects of all sizes. At present the work required to register a project may put
off those looking to undertake smaller projects as the potential financial benefit may not
warrant the work required (even when using a carbon service provider).
To maximise the potential carbon sequestration activities on farms it is critical that any policy
or process be fit-for-purpose, suitable for the timelines and best-practice for tree plantings,
and in-line with good agricultural practices.
