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AUSTRALIAN INTEGRATED CARBON
Adelaide - Perth - Sydney
Level 2B, Building C/114,
120 Old Pittwater Road,
Brookvale NSW 2100
https://aicarbon.com/
10/11/2021
Clean Energy Regulator methoddevelopment@cer.gov.au
Blue Carbon Methodology Feedback Response
Introduction
Australian Integrated Carbon (AIC) welcomes the development of the Blue Carbon methodology.
Several of our team are experienced in tidal restoration flows, including our Chief Operating Officer,
Russell Seaman, who has worked closely on Blue Carbon pilot projects in South Australia utilising the
VCS method.
As a project developer and investor in landscape restoration, AIC rely on accuracy through hands-on
project analyses, development and due diligence. Projects that progress to a commercial footing
undergo due diligence from our internal review process and external investors. Many of our responses
have been considered through this lens.
On the positive, Australian Integrated Carbon supports and welcomes several key elements within the
methodology such as adopting a modelled carbon approach and recognising co-benefits.
Through our experience of developing and implementing commercial projects, we have several
suggestions which may improve the approach and methodology. These are discussed below.
Hydrological assessment
The Clean Energy Regulator’s Emissions Reduction Fund Simple method guide for Blue Carbon projects
registered under the Carbon Credits states, “… need to have an independent person prepare or review
the maps that you create as part of a hydrological assessment…” (Page 21). Independent person is
defined as, ‘a person who: has no financial interest in the project, has knowledge of tidal
hydrodynamics and floodplain inundation, has experience in the provision of floodplain inundation
services…’ in the Carbon Credits (Carbon Farming Initiative – Tidal Restoration of Blue Carbon
Ecosystems) Methodology Determination 2021.
We consider the requirement to have an independent person engaged at this stage of project
development to be a costly addition to project development. From our experiences, there is a lack of
experience and knowledge in developing or reviewing hydrological assessments. Those entities with
experience are large commercial firms or Universities. This creates issues with cost and IP.
The other requirement based on Emissions Reduction Fund Simple method guide for Blue Carbon
projects registered under the Carbon Credits, states that “you will need to have an independent
engineer review your hydrological assessment and project operations...” (Page 21).
Through the development and commercial framing of a project, we will require the expertise of an
engineer to assist in developing a viable project. Requiring AIC to then engage another engineer will
add substantial costs to project development.
Our view is that to develop and implement a viable project, carbon developers will be implementing
sufficient standards across the modelling and engineering components to ensure their investment and
return are secure. We understand that the Regulator requires checks and balances to maintain
integrity and suggest that this can be gained through the audit process. Those carbon developers that
do not have sufficient in-house expertise or not-for-profits without resources to engage consultants
may need to have additional oversight. An assessment of the skill base of project developers and sub-
contractors should be sufficient to maintain integrity. We hope that the Regulator can consider other
options to maintain hydrological and engineering standards without increasing the cost for developing
projects before the Registration process.
Blue Carbon Accounting Model
The Blue Carbon Accounting Model (BlueCAM) is an excellent start to defining carbon yields. However,
we have not been able to test that model and understand how it works in a practical setting. We would
like to understand if a yield curve can be exported, much like the FullCam model. This is essential to
build project commercials. The technical guidance document did not seem to provide a table of default
values for the differing regions expressed as Tonnes per Ha. This would be very useful to assist us to
viability.
Conclusion
AIC is very exited by the opportunities tidal restoration can bring to funding and restoring landscapes.
We do have reservations regarding the cost of implementation during the development stage, this
might prove to be a major barrier, much like the soil carbon method experience. The costs of
hydrological modelling software, obtaining bathymetric data and developing and implementing
engineering solutions will likely be high. The total costs for a project may out way the returns. An
understanding of the default carbon values will also assist in developing easy feasibility assessments.
As data is collected over time, future improvements in model accuracy will be welcome, as will further
functionality. We also recommend that modelling software standards, much like the HIR Stratification
Mapping Guidelines and “accredited software standards” is considered.
Your sincerely,
Russell Seaman
Chief Operating Officer
Australian Integrated Carbon
