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Comment on the draft 2021 Plantation Forestry method
Comments by Peter Ritson (FarmWoods)
Date 23 November 2021
Introduction
The following are comments on the consultation documents released in October 2021, i.e.
Draft Carbon Credits (Carbon Farming Initiative—Plantation Forestry) Methodology Determination 2021
Draft Simple Method Guide for the Carbon Credits (Carbon Farming Initiative—Plantation Forestry) Methodology Determination 2021
Draft FullCAM guidelines—Requirements for the use of 2016 FullCAM with the 2021 plantation forestry method
Draft forest management plan guidance
Draft financial assessment guidance
The comments are intended to supplement feedback provided previously through the method co-design processes.
Overview
Overall, the revisions and additions to the Plantation Forestry should improve the method. This should substantially stimulate more plantation forestry activity and consequent abatement.
In particular, the following are welcome as providing more opportunities for increased abatement from plantation forestry.
Retention and some expansion of the scope of activities that can be undertaken under Schedule 1 (New Plantations) and Schedule 2 (Conversion Plantations).
The proposed Schedule 3 (Continuing Plantations) activity.
Allowing plantation forests outside of NPI regions.
The following are some specific comments.
Schedule 4 (transition to not-for-harvest planting)
The inclusion of Schedule 4 (transition to a not-for-harvest) may provide some opportunities for avoided deforestation of plantation forests. However, it is of concern that this will take land use away from commercial harvest plantation forests. The active and on-going land management provides many social, economic and environmental co-benefits, particularly in rural communities struggling to maintain viable populations of people actively managing the land or providing support services for resident landowners and land managers.
Of particular concern is the issue of absentee landowners that are common with permanent plantings which can be ‘plant-and-leave’ operations. Absentee land owners often don’t manage fire, pests, weeds and diseases adequately. As well as exposing the plantings to undue risks, the lack of responsible management can cause problems for neighbouring resident landowners when fire or pests/weeds/diseases from poorly managed plantings spread onto their lands. Rural bush fire brigades, which usually rely on volunteer residents in the community, may struggle to find people willing to share the load in communities with a high proportion of absentee land owners.
The requirement in the draft Plantation Forestry method for Schedule 4 activities to have a Forest Management Plan (FMP) should help the situation. If project proponents are required to follow their FMP, that should help alleviate some of the problems associated with the “plant-and-leave” mentality of some project proponents with permanent plantings.
Draft FullCAM Guidelines
It is appreciated that the draft FullCAM Guidelines are applicable to the 2016 public release FullCAM and that revised guidelines will be provided later for the proposed public release FullCAM 2022.
Some particular concerns with the current draft FullCAM guidelines are as follows.
MSEP option only outside of NPI regions
The draft FullCAM guidelines specify that, ‘if any part of the CEA is located outside an NPI region, you must select the Mixed Species Environmental Planting option’.
However, the Tree Species options for locations outside of NPI regions where plantation forests are being considered usually include a variety of Tree Species options. Presumably, that is because FullCAM has been calibrated for those species at those locations. If the Tree Species calibrations in a location are not considered adequate it seems logical that the calibrations will be removed from the next public release version of FullCAM untill such time as they are considered adequate.
Hence it is requested that, when the FullCAM Guidelines are revised, Plantation Forestry projects outside of NPI regions will be allowed to select from the appropriate Tree Species option for the plantation forest species.
In the case of sandalwood (Santalum species) plantations, where sandalwood is planted with at least one other host species, Mixed Species Environmental Planting (MSEP) may be the appropriate Tree Species option.
In areas where harvest mallee plantations are proposed outside of NPI regions, there are generally calibrations for individual mallee Eucalypt species (v 2016 FullCAM) or a ‘mallee Eucalypts’ group (v2020 FullCAM). This applies, at least, in agricultural areas of Western Australia that are outside the Western Australia NPI region.
Other cases where it would be advantageous for projects outside of NPI regions to select the appropriate Tree Species from those available in FullCAM for the location include proposed plantings of tree form species from the Eucalyptus, Corymbia, Casuarina, or Acacia genera. These may be plantation forests to be harvested for farm timbers (e.g. fence posts), other sawn timbers, or biomass (e.g. for biofuel or domestic firewood). A project would have to select the MSEP option initially if the appropriate Tree Species is not available in FullCAM. However, it could be worthwhile if there was an option of gathering and providing suitable data to the Commonwealth to provide a calibration for FullCAM for the project species in the location/region of the project. The measurements provided could be from mature plantings of the species in the vicinity of the project or progressive measurements of project plantations as they mature.
Coppice simulation
The draft FullCAM guidelines (Section 4.2.1.1) and the draft Determination (Section 22(8)) specify that the coppicing event must be modelled as starting 6 months after clearfelling. The draft FullCAM guidelines also specify that a coppicing event be modelled as a ‘Plant trees; seedlings normal stocking’ event in FullCAM.
Stating the coppicing event 6 months after clearfelling may be appropriate if a FullCAM assumption is that the coppice growth is 6 months old at the time the coppicing event starts. (It is understood that planted seedlings are assumed in FullCAM to have grown for 6 months at the time of planting).
However, an important difference between coppicing and re-planting is that, if coppicing, the stumps and roots of the harvested trees remain alive and do not decay. Research studies on Eucalypts show that, after coppicing, some fine roots may die but the total root biomass will recover to pre-harvest levels in a few years. In a harvest and re-plant system, if the stumps of harvested trees produce coppice regrowth that will generally be treated to kill the stumps and roots.
Hence it is recommended that a FullCAM Standard event for coppicing be included in the next public release version of FullCAM. The method for simulating coppice in the Farm Forestry method is suggested. That method assumes that, after coppicing, the root biomass and carbon stocks remain constant over subsequent coppice rotations (Figure 1).
Figure 1. Example simulation of biomass in a short rotation coppice system
Simulating coppice events as ‘tree planting’ events in plantation forestry projects will give biased underestimates of the predicted long-term average carbon stocks. This will underestimate abatement from project activity such as mallee Eucalypts harvested for leaf oils and/or biomass/biofuel and fuelwood plantations.
Note: As governments legislate to restrict or stop logging in native forests the availability of harvest residues for domestic or industrial firewood use is dwindling. Hence, increasing establishment of plantation forests on farmlands near population and industrial centres is to be expected and the availability of carbon credit revenue should stimulate more planting. The plantations will mostly be on marginal or unproductive farmlands and established by resident mainstream farmers. They will likely be managed in coppice systems.
If coppicing events are simulated as ‘tree planting events’ that will result in underestimates of carbon sequestration from plantation forestry project activities. However, if carbon sequestration from baseline activities (Schedules 2 – 4 in plantation forestry projects) is underestimated that will overestimate project abatement, especially if there is no coppicing in the project activities.
Simple method Guide
Some particular concerns from the Simple Method Guide are as follows.
In lieu of newness
The ‘In lieu of newness” provisions (that some project activities can commence after a complete registration application has been submitted and prior to registration approval) will be very helpful. This will reduce the uncertainty over how long project approval will take.
However, it is not clear if the ‘in lieu of newness’ provisions apply to both the initial application to register a project and any subsequent applications to vary a project by adding project area. It would be most helpful if the latter applies.
Transition from Farm Forestry to Plantation Forestry project
The Simple Method Guide mentions that Farm Forestry method projects will be able to transition to the revised Plantation Forestry method.
However, it is not clear if projects registered under the Farm Forestry method when that was the only possible ERF method will have to complete one offsets report under the Farm Forestry method before transitioning to the Plantation Forestry method now that is available. The following example shows why it would be difficult to complete an offsets report under the Farm Forestry method before transitioning to the Plantation Forestry method.
One of the Farm Forestry method projects that FarmWoods is involved with is a ‘biodiverse sandalwood project’ on two working farms in the Western Australia Wheatbelt. This ERF project was registered under the Farm Forestry method as it was the only possible ERF method at that time. It could not be registered under the Plantation Forestry method as, although commercial harvest of the sandalwood is planned, it is not in an NPI region. Neither could the project be registered under the Environmental Planting method as, although the species mix fitted the requirements for the Environmental Planting method, the landowners wanted the option of commercial harvest in the 25 year permanence period.
Biodiverse sandalwood plantations on other farms were registered under the Plantation Forestry method as they were located inside the Western Australia NPI region. But completion of an offsets report for the project area registered under the Farm Forestry method will be difficult. The main reason is that allometric equations (e.g. to estimate tree biomass from stem diameter measurements) must be developed from field sampling for each species and there are over 20 species in the biodiverse sandalwood plantations. (When the Farm Forestry method was developed in 2014 it was expected that most farm forestry plantations would be single species plantations.)
Following registration of the biodiverse sandalwood project under the Farm Forestry method in 2018, there have been active discussions with the Department of the Environment (now DISER) that when the Farm Forestry method was reviewed (due four years after initial Declaration in 2014) one possible change would be to allow multi-species (generic) allometrics. However that review, due in 2018, has not happened.
Hence the request that projects registered under the Farm Forestry method when that was the only available method, be eligible to transfer to the revised Plantation Forestry method when that is available without completing an offsets report under the Farm Forestry method first.
Model only estimates
It is disappointing that the revised Plantation Forestry method does not allow the option of some measurements of plantation biomass and carbon stocks. Detailed proposals were put to the CER for an optional hybrid measurements and model (FullCAM) approach, i.e. option of measuring Above-Ground Biomass (AGB) and using FullCAM to estimate other carbon pools (roots, debris, forest products) and emissions (fuel, fire). The growth model in FullCAM (Tree Yield Formula) would be calibrated from the AGB growth measurements. This carbon accounting approach, if selected by a project proponent would be an effective means of calibrating FullCAM with project measurements.
Cases where a project proponent might select the hybrid measurements and modelling approach if available include the following.
The project proponent is confident that FullCAM will grossly underestimate abatement from their plantation forestry project.
The project proponent is prepared to invest in management options that will, through optimum management, achieve more growth and abatement than is predicted by FullCAM for ‘run of the mill’ (ordinary) project management. Note: with modelling only approaches there is little incentive (apart from harvest revenues) for good management for more abatement.
Conclusion
The above comments focus on a few remaining areas of concern to the draft 2021 Plantation Forestry method.
However, I would like to commend the CER who, through an effective method co-design process, will achieve a Plantation Forestry method that is more comprehensive and has many significant improvements on the current Plantation Forestry method.
