Draft Reforestation by Environmental or Mallee Plantings method 2024

INPEX Operations Australia Pty Ltd
ACN 150 217 262
22/100 St Georges Terrace Perth
Western Australia 6000
Tel +61 8 6213 6000
INPEX.com.au

Ref: C050-IPX-ACR-LE-70006

12 July 2024

Professor Karen Hussey
Chair
Emissions Reduction Assurance Committee
Department of Climate Change, Energy, the Environment and Water
GPO Box 3090
Canberra, ACT

RE: Draft Reforestation by Environmental or Mallee Plantings method 2024 consultation

Dear Professor Hussey,

We welcome the opportunity to participate in the consultation by the Department of
Climate Change, Energy, the Environment, and Water (DCCEEW) on the draft
Reforestation by Environmental or Mallee Plantings method 2024, and seek to provide feedback and further recommendations regarding some of the proposed changes. We understand this draft is intended to support the replacement of the existing 2014 method.

INPEX CORPORATION (INPEX) is an international energy company, listed on the Tokyo
Stock Exchange, but remains 21.19 per cent owned by the Japanese government. We have been an active member of the Australian business community since 1986 and, as operator of Ichthys LNG, are the largest Japanese investor in the country. Additionally, we hold participating interests in other energy projects including Prelude FLNG, Darwin
LNG, Van Gogh and Ravensworth; and have corporate offices located in Perth and
Darwin.

As noted in our business strategy roadmap INPEX Vision@2022, INPEX aims to provide a stable supply of diverse and clean energy sources including oil and natural gas, hydrogen, and renewable power. Australia has been identified as one of five international regions prioritised by the company for future investment opportunities to help us achieve net zero emissions by 2050.

Of particular relevance to this submission is our carbon farming project Wheatbelt
Connect, a joint venture between INPEX, ANZ and Qantas. The project aims to achieve sustainable land use, primarily in the WA Wheatbelt region, through a combination of revegetation and rehabilitation efforts, while sharing and aligning with the current land uses that include grazing and cropping.

The project recognises the unique nature of each revegetation opportunity and will adapt the plantings to suit the landowner’s needs and farm conditions. The focus of Wheatbelt

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Connect is to establish native reforestation and carbon farming opportunities to generate carbon credits.

In years to come, our goal is to create renewable biofuels from the native mallee biomass feedstock. Our team of experts is currently undertaking feasibility studies to assess the viability of producing sustainable aviation fuel and renewable biodiesel.

INPEX noted positive changes
Firstly, we wish to commend DCCEEW on undertaking a review and proposed update to the current Reforestation by Environmental or Mallee Planting method 2014. We note several positive changes that INPEX believes will be beneficial to increasing and progressing carbon projects across Australia, as a vital component to achieving net zero by 2050. In particular, INPEX supports:

• the relaxation of the interpretation of the newness requirement. This change will
allow for a greater breadth and volume of carbon projects to be established
across Australia.
• the proposed updates to the belt planting calibration specifying the growth
response to narrow versus wide planting belts. This is a positive change and is
substantiated by current research that indicates more biomass is produced per
hectare of narrow belts due to the increased competition on internal rows.1
• the proposed changes that allow mixed-species environmental plantings to
include climate resilient native species that may not have been in the local
vegetation, as long as they are suitable for the area.

INPEX noted considerations for the method
Additionally, INPEX believes there is potential room for improvement under these proposed changes. Below we have outlined a number of components INPEX believes would provide greater clarity, flexibility, and optimisation to the draft method.

Inclusion of greater diversity of mallee species
The mallee component of this proposed method only allows specified mallee species to be planted using the mallee eucalypts calibration. There are five specified taxa from three species: Eucalyptus loxophleba, E. polybractea and E. kochii. INPEX suggests there should be a more liberal application of the mallee calibration to other taxa of mallee that have a proven record of revegetation success in the West Australian Wheatbelt region.

There are around 800-900 known species of the Eucalyptus genus, and it is thought that over half are mallee, yet only three species are permitted under the mallee calibration.
The inclusion of other taxa will allow mallee planting to better match the biophysical and climatic conditions of the potential planting sites.

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Spencer, B., Bartle, J., Abadi, A., Gibberd, M., & Zerihun, A. (2021). Planting configuration affects productivity, tree form and survival of mallee eucalypt in farm forestry plantings. Agroforestry Systems, 95,
71-84.

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Various research conducted across multiple mallee species indicates biomass production
(sequestration rates) can be variable across sites from different species within the same location.2 3 4

Additionally, research conducted found it is important to match species to site conditions, and to consider the management aims of the tree plantings. For example, E.
polybractea had the highest growth and water use of the three species studied and would be better suited to planting in areas with high water availability. E. loxophleba subsp. lissophloia appeared to have some tolerance to subsoil salinity and would therefore be the best suited of the three species to areas with saline groundwater. 5

INPEX suggests where mallee data is available for species calibration, at a minimum other mallee taxa should be included using the mallee eucalypts species calibration. For example:
• E. angustissima is a proven performer in the Great Southern and South Coast
regions of Western Australia. It is tolerant to saline and waterlogged sites.
Currently there are no specified mallee species suitable to this landscape position.

• E. loxophleba subsp loxophleba, E. loxophleba subsp supralaevis and E.
loxophleba subspecies gratiae should be planted across their natural distribution
in preference to E. loxophleba subsp. lissopholia (a specified mallee species).6
Experimental data conducted by INPEX has shown when where both E.
loxophleba subsp lissophloia and E. loxophleba subsp loxophleba have been
planted at the same site, E. loxophleba subsp loxophleba outperforms E.
loxophleba subsp lissophloia. This data can be provided upon request.

Inclusion of generic eucalypt calibration
INPEX would support the inclusion of the generic eucalypt calibration currently in the beta 2023 version of FullCAM in the revised Reforestation by Environmental or Mallee
Plantings method 2024. This would allow a wider variety of tree-form eucalypt species to be planted in marginal agricultural land.

Further clarity on Pilot Plantings
INPEX would like to seek further clarification on the future of the Environmental
Plantings Pilot, which has to date been registered under the existing 2014 method.
Currently, there is no mention of the Pilot in the proposed draft method.

INPEX appreciates the streamlined administrative process that applies to the pilot projects, especially in the absence of independent audits, as these factors can influence whether a project progresses. We note, however, the current requirement to produce evidence that the seed has been collected from within the natural distribution of the

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Eastham, J., Scott, P. R., Steckis, R. A., Barton, A. F. M., Hunter, L. J., & Sudmeyer, R. J. (1993). Survival, growth and productivity of tree species under evaluation for agroforestry to control salinity in the Western
Australian wheatbelt. Agroforestry Systems, 21, 223-237.
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Wildy, D. T., Bartle, J. R., Pate, J. S., & Arthur, D. J. (2000). Sapling and coppice biomass production by alley-farmed ‘oil mallee’ Eucalyptus species in the Western Australian wheatbelt. Australian Forestry, 63(2),
147-157.
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Spencer, B., Bartle, J., Huxtable, D., Mazanec, R., Abadi, A., Gibberd, M., & Zerihun, A. (2019). A decadal multi-site study of the effects of frequency and season of harvest on biomass production from mallee eucalypts. Forest Ecology and Management, 453, 117576
5
Brooksbank, K. (2011). OIL MALLEES: Physiology and growth under variable water availability in low rainfall agroforestry systems, Doctoral dissertation, University of Western Australia
6
Hines, B., and M. Byrne. (2001) Genetic differentiation between mallee and tree forms in the Eucalyptus loxophleba complex. Heredity 87.5: 566-572.

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species can often be difficult if the project application occurs significantly ahead of the commitment of seedling orders. INPEX suggests this evidence should be provided to the
Clean Energy Regulator when seedlings are ordered.

In conclusion, INPEX values the opportunity to provide feedback on the draft
Reforestation by Environmental or Mallee Plantings method 2024. INPEX’s Environmental
Scientist, Dr Beren Spencer, whose research is referenced within this submission, would be happy to provide an update on our current carbon farming project and an overview of
INPEX’s experimental data on mallee species performance if you or relevant team members within DCCEEW would find this valuable.

Please contact John Williams, Government Affairs and Regulatory Approvals Manager, on
or at for further information, or to arrange a briefing with Dr Spencer.

Yours sincerely,

Jodie Wesley
General Manager, Corporate Affairs
INPEX Australia

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