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Submission to independent review of ACCUs
NAILSMA September 2022
Mr Barry Hunter a
Mr Ricky Archer b
Dr Justin Perry c
Executive Carbon manager NAILSMA, Chair ABCF
CEO NAILSMA
Research Manager NAILSMA
This submission will focus on the how the current system “contributes to regional economies and the broader community; and whether appropriate processes are in place to avoid adverse impacts” with a specific focus on the “broader impacts of activities incentivised under Australia’s carbon crediting framework”.
Firstly, we note that the current ERF framework was explicitly designed to delivery lower-cost abatement. The focus of the regulated methods is to deliver ACCUs not to deliver social and environmental benefits. In the absence of specific core-benefit frameworks the incentive is to achieve least cost abatement, where greatest economic benefit is accrued through optimising the activities within the constraints of the methodologies being applied.
For example, for the Savanna Burning Methodology, demonstrating area burnt before the regulated date (e.g August 1) compared with the base line area burnt. The delivery of this outcome does not need to include Indigenous participation or the delivery and demonstration of social, cultural or environmental benefits. The primary issue with the current system is that co-benefits are assumed to be accrued by projects operating on Indigenous land. In the absence of specific management objectives and processes that promote the leadership and participation of Traditional Owners (i.e those individuals who have cultural obligations for specific traditional lands and features within a larger estate) the assumed co-benefits are not accrued.
For biodiversity co-benefits, specific fire management activities are required i) at scales that are meaningful for the elements of biodiversity that are being targeted for protection, ii) are cognisant of the functional changes to ecosystem elements following a change in fire regime (e.g. timing and abundance of flowering events, diversity and abundance of grasses producing seeds for granivores, changes to the structure of vegetation that support habitat different habitat preferences for particular species), and iii)acknowledge the significant lags in response to altered management regimes.
Currently, a biodiversity benefit is thought to be achieved through the application of general carbon abatement practices and changes in fire timing and extent are presented as proxies for biodiversity benefit. For other methods such as tree planting, vegetation change, measured using remote sensing, is thought to provide a useful proxy for habitat condition. Where land clearing and altered land use (e.g. horticulture and intensive agriculture) is dominant this approach is useful and reflects a coarse representation of habitat condition. However, where the land use change has not involved broad scale land clearing which includes most of northern Australia, more nuanced methods are required to account for biodiversity benefits. Fire regimes can lead to long term changes to plant diversity (both too much or too little fire depending on the vegetation type) that are more subtle and manifest over decades. Changed fire regimes and other management that reduces threats (e.g removal of cattle and buffalo) can lead to positive changes, however, measurable change to elements of biodiversity may take a very long time to emerge and require specific monitoring methods to detect. Current approaches tend to use community level rapid monitoring methods that are unlikely to have the statistical power to report meaningful change.
Because of the lack of proven methods for assessing biodiversity change there has been reticence from project holders to support regulated approaches outside of carbon accounting. If the regulated method is lacking, significant resources will be expended, requiring specialised skill sets that are external to most Indigenous organisations, with no evidence that the methods will detect change or help organisations adapt their management regimes to achieve the desired co-benefit. For current methods, the incentive is placed on collecting data which is more likely to measure the ability of a practitioner to apply a biodiversity assessment method rather than demonstrating biodiversity impact.
Recommendation: Social, cultural and biodiversity benefits require specific activities before a co-benefit is assumed.
We recommend that social, cultural and biodiversity benefits are not seen as co-benefits associated with the production of ACCUs. Our experience is that organisations that create other benefits using carbon revenues, do so through very specific investment in activities that provide these benefits that are separate from the application of regulated carbon methods. Incentives for producing social, cultural and environmental benefits should not be overly prescriptive but should promote adaptive processes that incentivise investment for innovation in the delivery of management regimes that specifically aim to improve or maintain the values that have identified as important. Being explicit about the values that are being protected and developing approaches that aim to manage and monitor these values, provides a more meaningful approach then generic monitoring methods that rely on untested universal proxies to measure change.
Review of code of conduct around eligible consent holder
Indigenous Leaderships and growth has developed significantly.
NAILSMA, Indigenous Carbon Industry Network (ICIN) and Aboriginal Carbon Foundation (ABCF) are providing a strong voice into industry and Indigenous involvement.
Often these groups are the first respondents and advice sought from these entities on matter relating to indigenous people’s involvement. CER should recognise this growth and support through senior positions that reflect and deal with the growth around policy and indigenous engagement.
Greenwash is a real issue relating to co-benefits (also referred to as Core Benefits), the environmental, social and cultural outcomes of a carbon project. Certification of these benefits is required. For example, organic producers require certification which provides trust in the market for consumers who are seeking to purchase organic products. The Qld government, through the Land Restoration Fund (LRF), has accepted the ABCF Core Benefits process as a means of accepting verification of Core Benefits. If we encourage and have proper mechanism that verify the processes that have been used to create an ACCU, then the production of high integrity ACCU’s will result.
The creation of Indigenous jobs through the Carbon industry particular New and emerging industry has been a highlight, in particular and predominately the Savanna Burning Methodology. This should be encouraged and supported. Firstly, the direct jobs related to projects are easily demonstratable, it is also the support industry jobs that are now being coming prevalent and require some form of support.
Native Title and Eligible Interest Holder Consent
We are seeing confusion around dealing with eligible interest holders consent particularly relating to native title. Defining and spending resource on the process to streamline and make this easier for parties is strong required.
Recommendation: Senior Position and Policy to reflect indigenous involvement and engagement in the industry and actively deal with issues such as Native Title.
