Independent Review of Australian Carbon Credit Units: Call for submissions

PO Box 40222
Casuarina NT 0810
ABN: 81 166 922 569

ALFA (NT) Limited (ALFA) thanks the expert panel for the opportunity to provide a submission to the
Independent Review of Australian Carbon Credit Units (ACCUs). ALFA is an Aboriginal-owned carbon business created by, and working in partnership with, Traditional Owners and Aboriginal ranger groups over more than 80,000 km2 of Aboriginal freehold land (under the Aboriginal Land Rights Act
(NT) 1976) in Arnhem Land in the Northern Territory of Australia.
ALFA provides information to the integrity review within the context of its leading role in the carbon market as a significant producer of high-quality ACCUs generated by an Aboriginal-owned company through the engagement of Traditional Owners and Aboriginal ranger groups in the Savanna Fire
Management (SFM) method.
In this submission, ALFA provides background information on the innovation and involvement of
Arnhem Land landowners in the development of the carbon industry in northern Australia. We then focus on four key areas as they relate to integrity: the Savanna Fire Management (SFM) method;
ALFA’s performance and operations under the SFM method; challenges and adverse consequences that have arisen during engagement with the SFM method; and finally, broader scheme policy and governance issues in relation to SFM methods. ALFA provides details of additional relevant supplementary material in Attachment 1.

Executive summary

ALFA considers the Savanna Fire Management methods to be of the very highest integrity due to:
• the environmental and cultural aspirations that led to its development
• the breadth of scientific research on which the method is based
• it’s simple and conservative focus on carbon accounting
• the active application of fire management as the eligible activity
• the uptake across a broad range on land tenures in northern Australia to address
environmental and cultural goals
• the ability for the eligible activity, fire management, to be independently and publicly
verified on the North Australian Fire Information (NAFI) service
• the transparency with which SFM projects operate given their abatement claims can be
verified by the public at any time and at no cost using SavBAT
ALFA considers that its operation and performance under the SFM methods produce high integrity
ACCUs that maximise co-benefits including environmental, social, cultural, and economic benefits.
• ALFA is an Aboriginal-owned, not for profit company initially created by the Aboriginal
ranger groups operating the WALFA project
• ALFA generates ACCUs from five registered SFM projects, the sale of which provides funding
to Aboriginal ranger groups to support and enhance the fire management rights and
obligations of Traditional Owners
• ALFA projects have been successful in reducing the frequency and extent of severe fires as
well as facilitating more heterogenous patches of vegetation, managing long-unburnt
patches in the landscape and creating significant greenhouse gas abatements
• The WALFA and CALFA projects (that each produce more than 100,000 tonnes of abatement
each year) are independently audited annually
• The use of the SFM method uncertainty buffer within the ALFA projects is rare
• The ALFA projects achieve significant co-benefits both from the application of fire
management and from the reinvestment of revenue to support community-led priority
projects
ALFA recommends that the CER address an immediate and significant opportunity to further increase co-benefits by introducing ERF exit fee concessions for long term, fixed delivery, ERF contracts where all parties are charities registered with the Australian Charities and Not for Profit
Commission (ACNC)
ALFA considers that addressing the widespread misunderstanding of the SFM method, and fire management more broadly, is critical to the ongoing integrity of this method. Now more than ever,
Australian’s deserve quality information and research to inform climate and environmental policy in complex landscapes. Increased investment is required as current levels of government funding and grants are insufficient to carry out projects to the level required to make sufficient impacts nor to undertake critical monitoring and evaluation. The SFM methods cannot carry the weight of responsibility for reversing, managing, and monitoring all threatening processes in the tropical savanna landscape. Climate change is already creating escalating challenges for SFM projects.
Worsening fire weather conditions will drive an even greater need for investment and expertise in active fire management to reduce risk and manage for biodiversity.
ALFA considers that broader policy and governance issues are critical to upholding the integrity of
ACCUs. Key mechanisms have acted to support the integrity of ACCU production within the SFM method. These include
• SFM method development prior to the CFI through WALFA as a pilot project
• funding to facilitate information exchange, planning and consultation which was
instrumental in building capability within Indigenous organisations
• method mechanisms to encourage incremental learning and investing in method activities
(like savanna fire management) to which landowning and management groups aspire
• the ability to build long term partnerships with external organisations, such as the critical
partnerships between researchers and Traditional Landowners in the development of
WALFA
Ongoing method development needs to include resourcing to continue to unlock new opportunities in existing methods. Recognition is required that the crediting periods for some methods may need to be maintained on an ongoing basis for those methods in which an activity can never become business-as-usual. The differentiation of method specific ACCUs in the market has been a welcome development recognising that not all ACCU’s are created equally. Active, climate-change fighting methods such as savanna fire management which requires the annual application of resource intensive work to produce hard-won but significant abatement as well as other environmental, cultural and social outcomes should be recognised, supported and valued accordingly.

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Arnhem Land and the role of Traditional Owners in the development of the carbon industry in northern Australia
Aboriginal people have been using fire to manage the Australian landscape for thousands of years.
Following European colonisation and the displacement of Aboriginal people from their clan estates,
Aboriginal fire management began to break down across much of northern Australia. Due to the absence of people on country undertaking fire management in the early dry season, fire regimes became dominated by wildfires in the late dry season. Large and environmentally destructive, these wildfires also contribute significantly to Australia’s greenhouse gas emissions.
As senior Landowner Dean Yibarbuk describes, “Wildfires were always controlled because there were people all around us, but when people left the country, nobody was there looking after it and managing fire”.
“Our elders said we want to bring our people back on the landscape once again and live and manage this country as we have before”.
In the late 1990s, Aboriginal Traditional Owners from western and central Arnhem Land and non-
Aboriginal scientists began talking about fire in the landscape. These discussions led to the development of a vision of people living on healthy country and ultimately to the innovative program of fire management now known as the Western Arnhem Land Fire Abatement (WALFA) project (Myers et al. 2004; Altman et al. 2020).

The WALFA project commenced pilot operation in 2006 as a partnership between Traditional
Landowners, the five Aboriginal ranger groups with responsibility for most of western Arnhem Land, the Northern Territory Government, the Northern Land Council, Northern Territory based research scientists, and ConocoPhillips ( an oil and natural gas multinational corporation). The goal was to reinstate Aboriginal-led fire management regimes over the remote Arnhem Plateau in part to offset greenhouse gas emissions from the ConocoPhillips owned Liquefied Natural Gas (LNG) plant in
Darwin Harbour (Russell-Smith et al. 2009; Altman et al. 2020).

Traditional Landowners and the five Aboriginal ranger groups involved in the WALFA project developed ways of emulating customary Aboriginal fire management using modern tools and research scientists worked to develop a method that was able to quantify the greenhouse gas abatements produced through the reintroduction of seasonal fire management. Funding to pilot the reintroduction of fire management was provided by ConocoPhillips from 2006 (Russell-Smith et al.
2009).

Whilst WALFA demonstrated what is achievable from a western scientific carbon accounting perspective, more significantly, it allowed Traditional Owners and Aboriginal ranger groups the opportunity to realise their own long-held aspirations for the people and country of Arnhem Land.
This opportunity was embraced and successful, proving to themselves and others that Traditional
Owners could bring about significant outcomes if financially resourced to do so (Altman et al. 2020).
In doing so, they were able to reverse the destructive wildfire regimes identified as a key threatening process to the biodiverse landscapes of Arnhem Land (Russell-Smith et al. 2009).
With the advent of the Commonwealth Government’s Carbon Credits (Carbon Farming Initiative) Act
2011 (CFI Act) and subsequent Emissions Reduction Fund (ERF) legislation, the WALFA project became the landscape-scale model upon which the approved savanna burning method was based.
Today, there are over 70 registered savanna burning projects in northern Australia. These registered savanna burning projects cover a broad range of land tenures and all utilise the method developed in Arnhem Land to produce carbon credits through the management of fire.

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1. The Savanna Fire Management (SFM) method

ALFA considers the Savanna Fire Management methods to be of the very highest integrity due to the environmental and cultural aspirations that led to its development, the breadth of scientific research on which the method is based, its simple and conservative focus on carbon accounting, the active application of fire management as the eligible activity, the uptake across a broad range on land tenures in northern Australia to address environmental and cultural goals; the ability for the eligible activity, fire management, to be independently and publicly verified and; the transparency with which SFM projects operate given their abatement claims can be verified by the public at any time and at no cost.
As described above, the development of the SFM method in western Arnhem Land predates the introduction of the Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act) by several years. A
Traditional Landowner initiative, the method itself was created to solve a previously intractable cultural and environmental problem – how to reinstate Aboriginal fire management practices across a vast remote landscape subject to uncontrolled mainly non-anthropogenically ignited fires.
The carbon accounting for the SFM method is built on decades of published peer-reviewed research.
This includes: vegetation population dynamics; quantifying vegetation fuel types, fuel accumulation, fuel consumption and fire patchiness; measuring combustion and emissions from fuel classes; methods for mapping and verifying fire extent (Russell-Smith et al. 2009; Murphy et al. 2015).

The method itself focuses on carbon accounting and does not currently prescribe how, when or where fire management should occur within a project area. Rather it stipulates that a project proponent must undertake some planned burning in a designated project area each calendar year.
The proponent must also demonstrate a pattern of burning that meets the objective of reduced emissions relative to the baseline period. Within this broad scope, the methodology allows projects the flexibility to undertake fire management appropriate for that project area in accord with landowner priorities (Calnan et al. 2020).

Importantly, projects only generate an abatement if they are successful at reducing emissions of methane and nitrous oxide compared to emissions from their actual pre-project baseline. Each project year that an SFM project achieves an abatement, results in a permanent emissions reduction with no risk of reversal. As a further conservative measure, an uncertainty buffer is also built into the
SFM method, whereby the CER collects and holds 5% of the projects baseline emissions to manage for any negative abatement years.

Currently there are 79 registered SFM projects that have produced over 11.25 million ACCUs. This represents just under 10% of all ACCUs produced in Australia (see ERF Project register). Of the
ACCUs produced under the SFM methods, over 73% have been produced by Aboriginal operated
SFM projects. Key to the successful uptake of savanna burning projects by Aboriginal groups on
Aboriginal land tenures has been the alignment of the method with landowner aspirations, the ability to leverage a highly skilled ranger work force in situ, and the flexibility in the method to accommodate diverse land management and cultural heritage protection goals (Calnan et al. 2020).
Recent research summarising these goals in Arnhem Land include the desire to continue the healthy fire management of country; see fewer wildfires; protect biodiversity; protect culturally important sites; maintain and transfer knowledge; and to be able to create a carbon abatement to fund management activities (Ansell et al. 2020).

The SFM methods are also able to be independently verified using publicly available information technology. The savanna fire management methods rely on satellite derived fire scar maps to

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underpin the calculation of emissions avoided through the application of planned burning in the early dry season. Registered ERF project area locations are publicly available from the Emissions
Reduction Fund project register and the successful application of savanna fire management by individual projects is clearly evident on the North Australian Fire Information (NAFI) website in the form of mapped fire scars in the early dry season. The online Savanna Burning Abatement Tool
(SavBAT) is also able to provide estimates of abatement success given an underlying public vegetation map and annual fire scar mapping. The transparency with which SFM projects operate and the integrity of their abatement claims can be verified by the public at any time and at no cost.

2. ALFA performance and operations under the SFM method

ALFA is an Aboriginal-owned, not for profit company initially created by the Aboriginal ranger groups operating the WALFA project. ALFA generates ACCUs from five registered SFM projects the sale of which provides funding to support and enhance the fire management rights and obligations of Traditional Owners. The ALFA projects can be characterised as occurring on large project areas, requiring significant operational costs and producing a high number of ACCUs. The ALFA projects are operating with transparency and integrity under the method. ALFA’s large projects, that produce in excess of 100,000 tonnes of abatement each, are independently audited annually and the use of the methods uncertainty buffer is rare. The ALFA projects achieve significant co-benefits both from the application of fire management and from the reinvestment of revenue to support community-led priority projects. An immediate and significant opportunity to further increase co- benefits exists in reviewing ERF exit fee provisions for long term, fixed delivery, ERF contracts where all parties are charities registered with the Australian Charities and Not for Profit
Commission (ACNC).
ALFA (NT) Limited is an Aboriginal-owned, not for profit company initially created by the Aboriginal ranger groups operating the WALFA project. Since then, the company has expanded to support other fire projects throughout Arnhem Land. All ALFA projects are located on inalienable freehold
Aboriginal Land in Arnhem Land vested by the Aboriginal Land Rights Act (NT) 1976 in the land trusts managed by statutory land councils. As prescribed under this legislation, the section 19 land use agreement process gives Traditional Owners an opportunity to consider, develop terms and conditions and the right to consent to or reject proposals on their land and seas. Using this process,
Traditional Owners are given the opportunity to make an informed decision in accordance with their traditional decision-making processes (see https://www.nlc.org.au/our-land-sea/aboriginal-land- legislation). ALFA was granted and holds Section 19 Land Use Agreements by the Northern Land
Council following extensive consultations and negotiations with Traditional Owners (Altman et al.
2020).
ALFA is the registered project proponent for five eligible offsets projects which generate Australian
Carbon Credit Units (ACCUs) through the SFM (2015) method under the Carbon Credits (Carbon
Farming Initiative) Act 2011 (CFI Act). The resulting fire management, providing work opportunity for hundreds of Traditional Owners in Arnhem Land, is considered to be one of the very best examples of savanna fire management in the world.
ALFA resources its Aboriginal partners to undertake sophisticated, landscape-scale fire management that utilises customary skills and knowledge in tandem with contemporary technology. This resource intensive work is financed exclusively through engagement with the Australian carbon market and the SFM method. The five ALFA projects are operated by nine Aboriginal ranger groups in Arnhem
Land. Their annual works program includes planning and consultation with hundreds of Traditional
Owners, the coordinated delivery of early dry season planned burning using both on ground and

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aerial fire management techniques and the active suppression of wildfires during the extreme fire weather conditions in the late dry season (ALFA 2022).
The scale and cost of these operations are considerable. For example, in any given year in Arnhem
Land, undertaking planned aerial burning alone requires Traditional Owners and Aboriginal rangers to fly over 60,000 linear kms in helicopters. Wildfire suppression is also becoming an increasingly applied fire management strategy. Over the last decade, rangers in Arnhem Land have adopted and refined a variety of mostly helicopter based firefighting tactics to suit the rugged and remote landscape. These firefighting tactics depend on the expert use of contemporary and traditional knowledge of fire behaviour and landscapes to use existing landscape features and existing fire scars from earlier planned burning to support wildfire suppression. In 2019, the Warddeken Indigenous
Protected Area (IPA) alone fought 53 wildfires that required over 4,400 personnel hours and 862 helicopter flying hours (WLML 2020).
The joint strategies of reinstating customary fire regimes and active fire suppression across Arnhem
Land through the operation of the fire projects has been successful in reducing the frequency and extent of severe fires as well as facilitating more heterogenous patches of vegetation, managing long-unburnt patches in the landscape and creating significant greenhouse gas abatements (Ansell et al. 2020, Evans and Russell-Smith 2020; Penton 2022). In the last five financial years (FY2017 to
FY2021), ALFA has expended an average of over $3 million per annum directly to core fire management operations within the ALFA project areas (see ALFA ACNC reporting). As a result of this extensive planned fire management, ALFA produces ACCUs in line with Savanna Fire Management
Emissions Avoidance Method. Over the last decade, the ALFA projects have produced over 4.9 million ACCUs with a recent average annual production of 630,000 ACCUs per year (for the period
2016 – 2021). Annual production is highly variable and is heavily dependent on seasonal fire weather conditions (Ansell et al. 2020).
Abatement in Arnhem Land is both permanent and conservative. For the suite of five registered
ALFA projects, over 95,000 tonnes of abatement (the equivalent of over 95,000 ACCUs) have been held permanently by the CER as an uncertainty buffer. This is abatement that whilst achieved, is not recognised to the ALFA projects as ACCUs and is instead held permanently by the CER to account for the possibility of negative abatement years. The uncertainty buffer is dynamic for the life of the method and is “topped up” if ever used to manage for negative abatement years. For the SFM projects in Arnhem Land, the occurrence of negative abatement years is very rare, occurring on only three occasions in the last decade, because of extreme fire weather conditions in the late dry season. The total amount of negative abatement from these three events amounted to less than
10,500 tonnes of CO2-e, 11% of the held accumulated risk of reversal buffers.
It is very important to recognise that SFM projects have become an important source of additional revenue for Aboriginal organisations which underwrites environmental, social and cultural outcomes that were previously unachievable (Calnan et al. 2020). It is also important to recognise that the capacity of SFM projects to address the scale of aspirational outcomes is severely resource limited.
As in other remote areas of Australia, Aboriginal people in Arnhem Land remote live in deep poverty
(Altman et al.2020). Socio-economic data for the region is stark with only three in ten adults in paid employment, a high dependence on state income support and more than 50 per cent of the population living below the poverty line (Markham and Biddle 2018). Existing funding from government and non-government sources does not cover the high operational costs of programs in remote Australia nor provide access to opportunities that the wider Australian public would consider basic essential services.
It is in this socio-economic environment that ALFA operates as a charity registered with the
Australian Charities and Not-for-profits Commission (ACNC). All income from the sale of carbon credits is reinvested to support ALFA’s charitable objects, with a particular focus on reinvestment to

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fund culturally appropriate fire management. ALFA’s Aboriginal partner organisations, who are themselves charitable entities registered with the ACNC, are the recipients of all funding and undertake land management activities that will protect, preserve and care for the environment and which are consistent with Aboriginal traditional rights and obligations. ALFA also supports broader charitable outcomes through funding community identified projects that address disadvantage in aged care and education and alleviate poverty, sickness, suffering, distress, misfortune, destitution and helplessness.
As a result, ALFA seeks to maximize returns to ALFA’s partner organisations whilst upholding the objects for which the company was created. In the 8-year period from June 2014 – June 2022, ALFA has generated $56.9 million dollars from the sale of ACCUs. Of this income 93% has been directly reinvested to ALFA’s Aboriginal project partners, the remainder funding ALFA’s operations and maintaining cash operational reserves. This income has been used to resource and successfully undertake culturally responsive fire management at a vast landscape scale as well as funding to support community identified projects and priorities. These include, the establishment of independent Aboriginal land management organisations, funding contributions to develop, register and run independent remote homelands-based schools, ecological monitoring and research, reconnecting Traditional Owners with ‘orphaned’ (depopulated) estates as well as infrastructure and capital items to increase the capacity of Aboriginal ranger groups to support Traditional Owners to manage the land and sea country of Arnhem Land.
An immediate and significant opportunity to further increase co-benefits exists in reviewing ERF exit fee provisions for long term, fixed delivery, ERF contracts where all parties (the carbon abatement contract holder and project proponent) are charities registered with the Australian Charities and Not for Profit Commission (ACNC). Given the size of ALFAs current Carbon Abatement Contracts, the proposed administrative exit fee required to be paid by ALFA annually is a substantial amount, over
$2.5 million annually. This is a significant sum of additional revenue which the Clean Energy
Regulator will currently earn annually from a registered charity established to support Traditional
Aboriginal Owners in Arnhem Land, who are amongst the poorest and most disadvantaged people in
Australia.

3. Challenges and adverse consequences that have arisen during engagement with the SFM
method

ALFA considers that addressing the widespread misunderstanding of the SFM method, and fire management more broadly, is critical to the ongoing integrity of the SFM methods. Now more than ever, Australian’s deserve quality information and research to inform climate and environmental policy in complex landscapes. Increased investment is required as current levels of government funding and grants are insufficient to carry out projects to the level required to make sufficient impact nor to undertake critical monitoring and evaluation. The SFM methods cannot carry the weight of responsibility for reversing, managing and monitoring all threatening processes in the landscape. Climate change is already creating larger challenges for SFM projects.
Worsening fire weather conditions will drive an even greater need for investment and expertise in active fire management to reduce risk and manage for biodiversity.

The development of savanna fire management into an industry able to earn and sell carbon credits has not been met with a sufficient shift in public understanding of fire management and SFM method operations. Common critiques question not only the positive environmental outcomes of fire management (of which there is a growing body of both Aboriginal and western scientific evidence) but also the use and value of Aboriginal customary knowledge. The publication of

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unqualified opinion and misinformed research by the media and in the academic literature, sensationalises critical issues and acts to undermine project outcomes and method integrity regardless of its authenticity. In this period of rapid climate change and policy development, now more than ever the Australian public deserves quality information and research to inform climate policy in complex landscapes. ALFA strongly recommends that authors work collaboratively with researchers, stakeholders, fire practitioners and industry participants on the ground in Northern
Australia who understand the context of the complex landscapes in which the SFM projects operate, many of whom are Traditional Aboriginal custodians.

Since colonisation, uncontrolled fire is recognised as a key threat to biodiversity in many of
Australia’s landscapes. As a result, many Australians equate fire with fear, destruction and an absence of control over the landscape. In northern Australia, contemporary fire management regimes are also a major factor affecting the ecological function and biodiversity of all ecosystems
(Myers et al. 2004). In the context of savanna fire management, it is important to note that desirable fire management practices will vary with the desired management outcomes, and the climate, terrain and flora and fauna assemblages present, as well as the scale of the ecosystem mosaic
(Myers et al. 2004). For example, some elements of savanna ecosystems are resilient to variations in fire regime, others are sensitive to fire intensity and/or sensitive to fire interval.
Given the responses of individual species to different components of fire regimes vary, and because differentially sensitive species are co-located in landscapes, then no single fire regime can optimise all biodiversity outcomes (Penton 2022). The most recent research in northern Australia focused on native fauna indicates that the presence of long-unburnt vegetation at the appropriate scale is more important for fauna than heterogeneous patches (Penton 2022). However, it is impossible to manage for long-unburnt patches in northern Australia without strategic fire management. In
Arnhem Land, with the current level of income generated from ACCUs, savanna fire management projects have been successful in reducing the frequency and extent of severe fires as well as facilitating more heterogenous patches of vegetation and increasing long-unburnt patches in the landscape (Ansell et al. 2020, Evans and Russell-Smith 2020). Improvements, particularly in fine-scale ground burning, which relies on many more people living on country at remote homelands is something to which the projects in Arnhem Land aspire, if the funding to support such resource intensive activity can be sourced.
It is also important to note that inappropriate fire regimes are not the only threat to biodiversity and without integrated and funded threat management plans (i.e. managing weeds, feral herbivores and feral cats) many faunal populations may never adequately recover (Penton 2022). Dealing with multiple threats at the landscape scale requires funding from multiple sources. However, current levels of government funding and grants are insufficient to carry out programs to the level they are required to ensure more desirable impacts. The ability to implement recovery plans is also contingent on long-term monitoring data for which there is also little to no funding available outside of government or university institutions. Of special note is the genesis of one of the largest landscape scale monitoring projects in the Northern Territory, the Warddeken IPA Biodiversity
Monitoring Program, which has been funded through the reinvestment of ACCU income generated through the WALFA project and philanthropic funds generated through the Karrkad Kandji Trust (KKT
2022).
The income generating potential of SFM projects also receives attention within the broader
Australian community. A common misconception is that the SFM method pays projects to burn their project areas, and that burning must occur in a particular way and during a specified time of the year. However, the SFM method is a simple method that accounts for methane and nitrous oxide emissions given whatever fire regime is applied to the project area in a given year. The method stipulates that the project proponent must undertake savanna fire management by undertaking

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planned burning in each project area each calendar year. The proponent must also demonstrate a pattern of burning that meets the objective of avoiding the emission of methane and nitrous oxide from the burning of savannas, compared to the emissions during the baseline period. For arguments sake, if the sole purpose of fire management was to maximise carbon credits (a common misconception in itself), a project would actually be aiming to burn as little as possible in any given year as too much fire in either season will negate any avoided emissions.
The recent publication of research that suggests savanna fire management projects are responsible for increasing the extent of fire and thus increasing smoke pollution in and around Darwin is another example of published misunderstanding. Smoke pollution in Darwin from fire has been the topic of research for many decades (Johnson et al. 2002). The advent of the SFM method was never established to address the smoke pollution issue created from the positioning of a major city,
Darwin, in its north-westerly location on Larrakia country where prevailing dry season winds blow smoke across the Top End. Results from Arnhem Land fire management clearly shows a general decreasing trend in the total area burnt, a significant decrease in the area of late dry season fire and early dry season fires have become smaller and more numerous (indicators of patchy fire) as a result of operating the fire projects (Ansell et al. 2020). The example of adequately resourced, planned fire management such as that occurring in Arnhem Land is widely identified by key stakeholders in the
NT as part of the solution to address identified fire management challenges in the broader Darwin region (Fisher & Altman 2020; Bushfires NT 2020).
When discussing either the positive or negative outcomes from savanna fire management, it is important to also recognise that no two registered SFM projects are alike. They differ across a range of characteristics such as rainfall, size, vegetation, geomorphology, tenures, fire history, baseline period, capability and fire management objectives. The method does not prescribe a fire management objective. As described previously, the SFM method works so effectively across all these different projects because it is simply a method to account for carbon and that simplicity allows projects the flexibility to undertake fire management to the best of their ability and appropriate for that project area. As a result, projects are registered and decisions about fire management are made by individual projects for a range of reasons. In Arnhem Land, ALFA only contracts and funds partner Aboriginal Ranger Groups to work with Traditional Owners – making sure that Traditional Owners are engaged and that activities support and enhance the fire management rights and obligations of Traditional Owners (Ansell et al. 2020, ALFA 2022). Indigenous
Protected Area Management Plans and Healthy Country Plans across Arnhem Land focus specifically on the prioritisation of management and monitoring of natural and cultural assets through the management of fire (Ansell et al. 2020).
ALFA notes that the complexity of the SFM methods is increasing over subsequent iterations as it attempts to account for and incorporate a range of external factors (such as weed, threatened species and Aboriginal heritage site management) and the possibility that these may change over time. Whilst this finetuning is intended to continue to ensure the integrity of the methods, the method should continue to maintain a priority focus on carbon accounting and external factors should only be included where there is the potential for them to create a material change in abatement calculations and it is within the proponent’s ability to effect change. ALFA welcomes increased investment in these important areas as they pose significant threats outside the scope of savanna fire management projects.
Not included to date are processes to ensure that the SFM methods are able to adapt to the reality of a changing climate. The baseline conditions for some current SFM projects date back to the mid-
1990s – a time in which the climate and fire weather conditions were significantly milder. The unfortunate reality is that with increasing fire danger weather due to climate change, the complex landscape scale balancing act of when and where to burn whilst meeting environmental and cultural goals is an ongoing and constantly evolving challenge. It is ironic that the very issue that Traditional

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Owners and Aboriginal rangers are actively fighting to prevent through their engagement with the
SFM method – climate change – will be one of the greatest challenges to the ongoing viability of the
SFM method. The ability to manage fire in the landscape is highly dependent on seasonal fire weather conditions. Bushfires need three elements to enable combustion: fuel – in the form of cured grasses and other organic dead and living biomass, oxygen and heat. All three of these elements will be influenced by climate change in the monsoonal north of Australia.
The Bureau of Meteorology climate projections for the monsoonal north of Australia are sobering in regard to changing fire weather conditions (Moise 2015). They include higher temperatures, hotter and more frequent hot days (greater than 35 degrees Celsius), an annual rainfall that may undergo large increases or decreases (which will alter vegetation growth and available fire fuels), a likely increased intensity in heavy rain events and increased evaporation rates and reduced soil moisture
(Moise 2015). In particular, these factors will increase fire intensity by increasing ambient heat, changing the size of available fuel loads, changing the curing of available fuels and with increases in overnight temperatures, reducing or eliminating entirely the annual window in which a dew point is reached. Importantly, whilst creating larger challenges for SFM projects these worsening fire weather conditions will drive a greater need for investment and expertise in active fire management to reduce risk and manage for biodiversity.
Currently, land managers in northern Australia (both Aboriginal and non-Aboriginal) use the annual wet season cycle of grass growth and gradual curing to implement low intensity burns in the early dry season whilst the vegetation is still moist, nighttime temperatures remain low and there is a strong dew point which acts to extinguish these planned low intensity fires overnight. These low intensity fires are used to reduce fuel loads and create a mosaic of burnt and unburnt country which operate as fire breaks that reduce the spread of high intensity fires that occur in the extreme fire weather conditions of the hottest late dry season.
It is highly likely that this planned and controlled early dry season fire management will become increasingly difficult and resource intensive under the influence of climate change. Indeed, the 2018,
2019 and 2020 fire seasons in northern Australia were the first to provide an indication of the scale of such climatic impacts. Traditional Owners in Arnhem Land are very concerned about the impacts of climate change on their ability to sustain remote livelihoods and the ability of future generations to live on and manage their traditional clan estates. The SFM projects are unique in that they are both a tool to reduce greenhouse gas emissions and a crucial action to mitigate the impacts of climate change through directly reducing impacts and maintaining resilient landscapes.
Finally, the ongoing funding uncertainty for the online North Australian Fire Information (NAFI) service is a key threat to the integrity of the SFM methods. Without NAFI, SFM projects face the impossible prospect of trying to undertake sophisticated landscape scale fire management in the absence of critical remotely sensed fire information, including past fire history and the success of planned burns in remote areas (through hotspot detection and up to date mapping of fire scars as they occur). As previously described, NAFI also provides a critical public information service which acts to verify and validate SFM project outcomes and provide integrity assurance.

4. Broader scheme policy and governance in relation to SFM methods

ALFA considers broader policy and governance issues critical to upholding the integrity of ACCUs.
Key mechanisms have acted to support the integrity of ACCU production within the SFM method.
These include SFM method development outside of the CFI through WALFA as a pilot project, funding to facilitate information exchange, planning and consultation which was instrumental in building capability within Indigenous organisations, and method mechanisms to encourage incremental learning and investing in method activities (like savanna fire management) to which

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landowning and management groups aspire. Method development needs to include resourcing to unlock new opportunities in existing methods. Recognition is required that the crediting periods need to be maintained on an ongoing basis for some methods in which an activity can never become business-as-usual. The differentiation of method specific ACCUs in the market has been a welcome development recognising that not all ACCUs are created equally. Active, climate-change fighting methods such as savanna fire management which requires the annual application of resource intensive work to produce hard-won but significant abatement as well as other positive environmental, cultural and social outcomes should be recognised and valued accordingly.

The current process of method prioritisation, development, approval and review requires greater transparency and more coordination across departments, agencies and the Emissions Reduction
Assurance Committee (ERAC). ALFA notes that in addition to prioritising new abatement opportunities, ongoing resourcing needs to be allocated to unlocking new emissions reduction opportunities in existing methods through frequent amendments and reviews.
ALFA notes and agrees with recent recommendations in the King Review (DISER, 2020) regarding the provision of processes to provide third parties with the opportunity to propose and prepare ERF methods and a process for pilot projects to test new method ideas and expedite method preparation. As previously discussed, the SFM method was developed slowly in a collaborative environment prior to its recognition as a methodology under the CFI. The WALFA project was the pilot project in which the method application was trialled and tested.
When the SFM method was initially established as a method under the CFI, there were also provisions to ensure Aboriginal engagement and participation. Key amongst these were mechanisms and funding to facilitate information exchange, planning and consultation. ALFA considers that these mechanisms were integral to ensuring the subsequent integrity of carbon projects and ACCU production generated on Aboriginal land as they focused on building capability within Indigenous organisations. The mechanisms included a transition period between the end of the baseline period and the start of the registered project in which proponents could undertake developmental and pilot activities (including during the often-lengthy periods of project consultation and planning) without affecting the baseline, a significant factor in determining if a project will be financially viable over the life of the crediting period. ALFAs experience with Aboriginal savanna fire management projects has clearly shown that it takes time to develop capacity. Mechanisms to encourage incremental learning and investing in method activities (like savanna fire management) to which landowning and management groups aspire should continue to be supported.
Currently provisions within the CFI Act only allows one crediting period, which for each of the current 2018 SFM methods (and previous methods) is 25 years. There is a discretion for this crediting period to be extended once, with the extended duration uncertain until this occurs.
However, an important feature of savanna burning projects, which is evidenced across the north of
Australia, is that, without support, the scale of landscape level burning undertaken under a method does not become business as usual. This is due to a combination of factors, the most significant being the annual environmental processes that drive tropical fire regimes and the high cost of undertaking landscape level fire management, which is currently prohibitive without the income derived through the sale of carbon credits. The application of a 25-year crediting period is both arbitrary, and inconsistent with the achievement of long-term emissions reductions. In order to recognise the ongoing and permanent emissions avoidance that can be achieved through the management of fire in northern Australia, it is important that opportunities are explored to increase the crediting period of the SFM methods.
ALFA welcomes the recent co-design process for the prioritisation of the 2023 SFM methods.
Previously, subsequent amendments to the SFM methods have failed to maintain the levels of collaboration that characterised the industry at the early stages and ensured that the cross-cultural

11
application of the methodology was strengthened. For example, the release of the 2018 SFM methods were highly anticipated and encouraged by the savanna burning industry as it represented the first opportunity to account for the sequestration of carbon occurring as a result of undertaking fire management. However, uptake of this method was severely limited due to significant issues and discrepancies within the method and the CFI Act which exacerbate uncertainty and undermine stakeholder confidence. Whilst these issues were highlighted at the method consultation stage and then post release with the ERF and CER, there had been no resolution in the four years following the release of the method until SFM method prioritisation was announced in late 2021.
Whilst an unintended outcome of recent questioning into ACCU method integrity, the differentiation of method specific ACCUs in the market has been a welcome development. There is now growing recognition that whilst one ACCU equals one tonne of carbon dioxide equivalents across all methods, not all ACCUs are created equally. Active, climate-change fighting methods such as savanna fire management which requires the annual application of resource intensive work to produce hard-won but significant abatement as well as other positive environmental, cultural and social outcomes should be recognised and valued accordingly. Similarly, it should be recognised that such co-benefits are maximised on Aboriginal land when Aboriginal people own and operate eligible offsets projects.

12
References
ALFA (NT) Limited (2022) ALFA Annual Report 2021
Altman J, Ansell J & Yibarbuk D (2020): No ordinary company: Arnhem Land Fire Abatement
(Northern Territory) Limited, Postcolonial Studies, DOI:10.1080/13688790.2020.1832428
Ansell J, Evans J, Adjumarllarl Rangers, Arafura Swamp Rangers, Djelk Rangers, Jawoyn Rangers,
Mimal Rangers, Numbulwar Numburindi Rangers, Warddeken Rangers, Yirralka Rangers and Yugul
Mangi Rangers (2020) Contemporary Aboriginal savanna burning projects in Arnhem Land: a regional description and analysis of the fire management aspirations of Traditional Owners. International
Journal of Wildland Fire, 29, 371–385. https://doi.org/10.1071/WF18152
Bushfires NT (2020) Overview of Top End Fire Season 2019. Presentation to the Savanna Fire Forum.
https://www.savannafireforum.net/_files/ugd/a62efc_11ed16d7e6ff447ea5e41ca93c2ce71e.pdf
Calnan T, Altman J, Ansell J & Grace P (2020) Still smouldering: Growing Indigenous engagement in the low carbon economy. Australian Environment Review. September 2020.
Evans J & Russell-Smith J (2020) Delivering effective savanna fire management for defined biodiversity conservation outcomes: an Arnhem Land case study. International Journal of Wildland
Fire, 29. https://doi.org/10.1071/WF18126
Fisher R & Altman J (2020) The world’s best fire management system is in northern Australia, and it’s led by Indigenous land managers. The Conversation. https://theconversation.com/the-worlds-best- fire-management-system-is-in-northern-australia-and-its-led-by-indigenous-land-managers-133071
Jones P, Furlaud J, Williamson G, Johnston F & Bowman D (2022) Smoke pollution must be part of the savanna fire management equation: A case study from Darwin, Australia. Ambio.
https://doi.org/10.1007 /s13280-022-01745-9
Johnston F, Kavanagh A, Bowman D & Randall S (2002) Exposure to bushfire smoke and asthma: an ecological study. Med J Aust 176 (11): 535-538. doi: 10.5694/j.1326-5377.2002.tb04551.x
KKT (2022) Karrkad Kanjdji Trust Annual Report 2021. https://www.kkt.org.au/reports/?url=/reports
Markham F & Biddle N (2018) Income, Poverty and Inequality. Centre for Economic Policy Research
2016 Census Paper 2, Australian National University https://openresearch- repository.anu.edu.au/bitstream/1885/145053/1/CAEPR_Census_Paper_2.pdf
Moise A (2015) Monsoonal North Cluster Report, Climate Change in Australia Projections for
Australia’s Natural Resource Management Regions. CSIRO and Bureau of Meteorology, Australia.
https://www.climatechangeinaustralia.gov.au/media/ccia/2.2/cms_page_media/168/MONSOONAL
_NORTH_CLUSTER_REPORT_1.pdf

Murphy B, Edwards A, Meyer M & Russell-Smith J (2015) Carbon Accounting and Savanna Fire
Management. CSIRO Publishing, Melbourne.
Myers, B., Allan, G., Bradstock, R., Dias, L., Duff, G., Jacklyn, P., Landsberg, J., Morrison, J., Russell-
Smith, J., & Williams, R. 2004, Fire Management in the Rangelands, Tropical Savannas CRC, Darwin.
https://apo.org.au/sites/default/files/resource-files/2004-01/apo-nid153036.pdf
Russell-Smith J, Whitehead P & Cooke P (2009) Culture, Ecology and Economy of Fire Management in north Australian Savannas: Rekindling the Wurrk Tradition. CSIRO Publishing, Melbourne.

13
Penton C (2022) Warddeken Land Management Limited Submission 10 to Faunal Extinction Crisis.
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communi cations/ExtinctionCrisis/Submissions
WLML (2020) Warddeken Land Management Limited Annual Report 2019-2020.
https://www.warddeken.com/_files/ugd/982814_5ecf6390c85d4a7dad781c763fc65940.pdf

Attachments
The following documents are attached to this submission as supplementary information

1. ALFA (NT) Limited (2022) ALFA Annual Report 2021
2. Jon Altman, Jennifer Ansell & Dean Yibarbuk (2020): No ordinary company: Arnhem Land
Fire Abatement (Northern Territory) Limited, Postcolonial Studies,
DOI:10.1080/13688790.2020.1832428
3. Jennifer Ansell, Jay Evans, Adjumarllarl Rangers, Arafura Swamp Rangers, Djelk Rangers,
Jawoyn Rangers, Mimal Rangers, Numbulwar Numburindi Rangers, Warddeken Rangers,
Yirralka Rangers and Yugul Mangi Rangers (2020) Contemporary Aboriginal savanna burning
projects in Arnhem Land: a regional description and analysis of the fire management
aspirations of Traditional Owners. International Journal of Wildland Fire, 29, 371–385.
https://doi.org/10.1071/WF18152
4. Fire with Fire (2015) https://www.youtube.com/watch?v=Ev27t5xgmWc

14

Arnhem
Land
Fire
Abatement
ALFA (NT) Limited
Annual Report 2021
Arnhem Land
Fire Abatement
Arnhem Land Fire Abatement — ALFA (NT)
Limited — is an entirely Aboriginal-owned,
ALFA (NT) Limited
ABN 81 166 922 569
PO Box 40222
not-for-profit carbon farming business.
Casuarina NT 0810

Established in 2015 by Aboriginal Traditional
0437 272 043 ceo@alfant.com.au alfant.com.au

Owners from Arnhem Land to support their
engagement with the carbon industry, ALFA
currently supports Traditional Owners and
their affiliate ranger programs to deliver
five registered fire projects across an area
of over 80,000 km2.
Front cover: Students perform burning under the guidance and instruction of
ASRAC rangers at ASRAC’s Djilpin Fire
Camp. Photo by Chrystal Burgher.

Right: Aerial imagery illustrates the difference between burnt and unburnt country, on the right showing a cool early dry season burn that has gone out overnight. Photo © Matthew Abbott.

Back cover: Firefighting essentials including backpack blowers and fuel are loaded into a sling, ready to be dropped into a wildfire. Photo courtesy of Warddeken Land Management.

1 — Jon Altman, Jennifer Ansell and Dean
Yibarbuk (2020) No ordinary company:
Arnhem Land Fire Abatement (Northern
Territory) Limited, Postcolonial Studies,
23:4, 552-574

This report is printed on Envirocare 100%
Recycled. It is manufactured entirely from waste paper without the addition of optical brighteners. It is made in a facility that is
ISO 14001 accredited and with process chlorine free pulps; thereby helping to reduce harmful by-products.

Design — rodeo.com.co
Copywriting — Georgia Vallance

1
At the onset of the dry season, Traditional Owners Today, ALFA’s partner groups use customary
and rangers responsible for the remote tropical knowledge in tandem with modern technologies to
savannas of Arnhem Land apply customary fire deliver fire management programs that address
knowledge and skills to strategically burn their critical environmental solutions at local, country. These highly sophisticated landscape scale national and global levels.
fire management practices have been performed
since time immemorial. In a landscape that has evolved through the
deliberate and nuanced use of fire, the vital work
performed annually by rangers across Arnhem
Land is resourced through their participation in
the carbon economy.

ALFA facilitates this engagement with the carbon
industry, supporting Traditional Owners and
rangers to deliver best-practice fire management
projects that generate environmental, cultural
and social benefits, producing carbon credits
of the highest integrity.

Drip torches are used to efficiently ignite dried grass and
vegetation as rangers traverse country. Photo © Renae Saxby.

2 3
Nine Aboriginal ranger groups consisting —W est Arnhem Land Fire Abatement of Traditional Owners and their families (WALFA) project operate a total of five ALFA fire projects, — C entral Arnhem Land Fire Abatement which generate Australian Carbon (CALFA) project
Credit Units (ACCUs) through the — S outh East Arnhem Land Fire
Savanna Burning Methodology. Abatement (SEALFA) project
— S outh East Arnhem Land Fire
Abatement 2 (SEALFA2) project
Map of project areas — N orth East Arnhem Land Fire
Abatement (NEALFA) project

Collectively, these groups manage an area
of over 80,000 km2 encompassing rugged
sandstone escarpments, monsoon rainforest,
NEALFA
intact riparian ecosystems, floodplains,
remote coastal regions and vast expanses
WALFA CALFA

SEALFA
of savanna.

SEALFA
Stage 2

NT

N

4 5
Values

The following values represent the objectives for which ALFA was established.
All income generated through the sale of carbon is spent in line with these objectives.

To protect, preserve and care for the environment through
abatement of the level of global greenhouse gas emissions by
means of bushfire management activities.

To preserve and conserve native Australian fauna and flora
through bushfire management activities that accord with
Aboriginal traditional rights and obligations and Australian law.

To collaboratively pursue the investigation, development and
implementation of other activities which will protect, preserve
and care for the environment and which are consistent with
Aboriginal traditional rights and obligations and Australian law.

In relation to Aboriginal persons who have a traditional Aboriginal
connection with any part of the project area, to provide for
the relief of poverty, sickness, suffering, distress, misfortune,
Children from communities across ALFA project areas are introduced
destitution, helplessness or the aged.
to fire at a young age, and taught to responsibly harness fire as a landscape
management tool.

Tyson Maralngurra has grown up immersed in customary fire practice at his homeland
in \western Arnhem Land. He has also grown up participating alongside his family in land
and cultural management activities facilitated by the local Warddeken rangers, such as
To provide for advancement of education of Aboriginal
bushwalks, culture camps, rock art and biodiversity monitoring surveys and Anbinik
(Allosyncarpia ternata) protection. Photo © Matthew Abbott.
persons who have a traditional Aboriginal connection with
any part of the project area.

6 7
Governance In rugged terrain such as the Arnhem
Plateau, helicopters are essential to

ALFA (NT) Limited has eight membership classes,
deliver fire management. Photo ©
Matthew Abbott.

representing the operational areas of the
ranger groups and organisations who operate
each of the eight fire projects.
“The specific Indigenous form of participatory governance that guides ALFA’s
operations, always cognisant of Landowner authority, is fundamental to ALFA’s ability
to support forms of Aboriginal-led development focused on conservation.” 1

Fire ecologist, ALFA board member and cultural leader Dr Otto Campion
speaks at the 2021 pre-season meeting. Photo © David Hancock.

Membership of the ALFA is open to Aboriginal people Board of Directors and Staff as at with customary responsibilities for those parts of 30th November 2021
Arnhem Land under active bushfire management as Adjumarllarl — Shaun Namarnyilk, Anderson Nalorlman one of the eight registered projects. ASRAC — Gladys Malibirr, Otto Campion
Bawinanga — Victor Rostron, Felina Campion
ALFA is governed by 16 Aboriginal Directors. Jawoyn — Tony Walla, Steven Andrews
Two Directors are elected from each of the eight Mimal — Alfred Rickson, Leon Lawrence membership classes. SEAL — Clarry Rogers, Clive Nunggarrgalu
Warddeken — Conrad Maralngurra, Terrah Guymala
The Company also employs a Chief Executive Officer, Yirralka — Lirrpiya Mununggurr, Shane Wuthara a Chief Financial Officer, a Capacity Development and Wunungmurra
Training Manager, a Bushfire Project Officer, and a
Seasonal Bushfire Officer (as required). CEO — Jennifer Ansell
CFO — John O’Brien
Capacity Development and
Training Manager — Mark Desailly
Bushfire Project Officer — Stephanie Rouse
Governance Facilitators — Paul Josif, Sally Clifford

8 9
Traditional Landowners ALFA Membership
Partners

DJE LK

Bawinanga Warddeken Adjumarllarl Mimal Jawoyn ASRAC SEAL Yirralka
Directors

Victor Rostron Conrad Shaun Alfred Rickson Tony Walla Gladys Malibirr Clarry Rogers Lirrpiya
Maralngurra Namarnyilk Mununggurr

Felina Campion Terrah Guymala Anderson Leon Lawrence Steven Andrews Otto Campion Clive Shane Wuthara
Nalorlman Nunggarrgalu Wunungmurra

10 11
ALFA staff

Contract Governance Facilitators

Top left to right: Jennifer Ansell (CEO), John O’Brien (CFO),
Traditional Owners from Mamadawerre in the Warddeken
IPA light up the edges of the community’s airstrip as the
(Capacity Development and Training Manager), sun sets. Asset protection burns are often performed Stephanie Rouse (Bushfire Project Officer), Paul Josif (Governance Facilitator), collaboratively between Traditional Owners and rangers. Sally Clifford (Governance Facilitator).
Photo © Matthew Abbott.

12 13
2021 has been an exceptional year for ALFA on many fronts.

Jennifer Ansell
CEO

Every year, ALFA’s partner Aboriginal ranger groups and knowledge – realising this long-held aspiration of Initiative Act in 2011. Over the years the savanna Landowners. These incredible organisations are each across Arnhem Land coordinate highly sophisticated Aboriginal rangers in Arnhem Land. Over the next three methods have been updated many times to incorporate cornerstones of their communities and work tirelessly projects that support and enhance the fire years, ALFA will work with our partners to develop and advances in carbon accounting science. In 2021, we to improve the health of their country and the lives of management rights and obligations of Traditional deliver a model of accredited fire management training welcomed the announcement by the Clean Energy their people.
Owners. This model of Traditional Owner led project that combines on the job training and mentoring, and is Regulator that the savanna methods would be ownership and delivery, the founding principle for specific to the needs and cultural environment in which prioritised for an update in 2022 to include further Finally, once again, I wish to acknowledge and thank which ALFA was created, continues to deliver incredible Aboriginal rangers in Arnhem Land operate. carbon pools. The continued development of these ALFA’s small team of staff members who work with results for people, for country and, through the methods represents a significant opportunity for the dedication and enthusiasm to support the operation production of significant greenhouse gas abatements, In 2021, ALFA and project partners worked with the ALFA projects to significantly increase not only of the fire projects and the continued capacity for climate change mitigation. In 2021, the five Northern Land Council (NLC) to undertake planning the economic returns generated from the fire projects development of project partners.
ALFA projects abated just under 700,000 tonnes and consultation for a new fire abatement project in but also the environmental, cultural and social returns of greenhouse gas emissions generating almost north-west Arnhem Land. Many years in the making, from investment in the fire project areas. On behalf of ALFA’s Board of Directors, I am very proud
700,000 ACCUs. the formalisation of the consultation process was an to present the ALFA Annual Report and celebrate the
important milestone for Traditional Owners. ALFA looks The global focus on international climate policies many achievements from Arnhem Land in 2021.
In 2021, the operationalisation of new projects has seen forward to supporting the three project partners – the in the lead up to the 26th Conference of the Parties
ALFA build capacity to further support the growing Garngi, Mardbalk and Adjumarllarl rangers, who will in November 2021 saw the Australian carbon price needs of our partner Aboriginal organisations. coordinate the project with Traditional Owners – with strengthen significantly, rising to record prices. As
their first year of fire operations to begin in 2022. we go to press with this Annual Report in 2022, I am
The first of these is the addition of accredited fire excited about what the future holds for our project management training capability within ALFA. This will The Savanna Fire Management Methods have been partners, the Aboriginal ranger groups and their host enable rangers to continue to build their capacity an important contributor to emissions reduction in organisations who coordinate and undertake all of whilst creating a framework to recognise existing skills Australia since the inception of the Carbon Farming the fire management operations with Traditional

14 15
Core strategic actions of Left to right: Bawinanga rangers and Landowners discuss early dry season
(EDS) burning plans for the Djelk IPA; An ASRAC ranger uses a drip torch to
perform on ground burning; SEALFA rangers prepare to take to the skies

ALFA customary fire management
for aerial prescribed burning (APB); Warddeken rangers maintain a firebreak
around fire sensitive Anbinik (Allosyncarpia ternata) forests; Warddeken
rangers back burn from a rock art site after clearing detritus from the floor
of the shelter; Emerging generations of Traditional Owners are taught to
respect and harness fire as a tool for managing country.

1. 2. 3. 4. 5. 6.

Engage the right people Burn early in the dry season Burn strategically, using Protect fire sensitive Protect sacred sites, rock Teach the next generation of
for country in the planning at times of heavy dew and natural breaks such as moist ecological communities, art galleries, burial sites Traditional Owners to master
and delivery of all fire little wind, so that fires ground along creeks, cliff flora and fauna by utilising and other sites of cultural customary fire management
management activities. burn slow and cool, and go lines and tracks to leave cool burning and creating significance by creating skills and knowledge,
out overnight. patches of unburned country early-burned breaks. early-burned breaks. preparing them to take over
surrounded by burned breaks. the project in the future.

16 17
The story of ALFA begins with the ground-breaking and late dry season fires for a range of vegetation
West Arnhem Land Fire Abatement (WALFA) project, communities. A group of Indigenous fire experts and
the first savanna burning abatement project anywhere non-Indigenous scientists continued working together
in the world. to explore and define the relationship between
customary burning and emission reductions; this early
In the mid 1990s, senior Aboriginal Landowners research went on to become the foundation of the
from western Arnhem Land and a small group of current Savanna Burning Methodology.
non-Aboriginal scientists began a conversation
about the importance of fire in the landscape. Despite these exciting developments, for the
Elders and leaders explained that before the Traditional Owners and rangers of west Arnhem
depopulation of the Arnhem plateau and surrounding Land, managing fire at the scale necessary remained
Above: Warddeken Chairperson and ranger Conrad Maralngurra conducts burning in the early evening with children from the areas, fire was the key tool used to care for their estates. beyond their financial capability. In 2006, after years of community. Photo © Matthew Abbott. They spoke of “orphaned country”, whose Landowners negotiation, a trailblazing solution was reached when
Opposite right: Attendees at one of the first meetings to bring had been drawn to missions and settlements, and ConocoPhillips entered into the West Arnhem Fire together Landowners from across west and central Arnhem Land to discuss fire management, held at Weemol in 2005. Many of the
were concerned that without customary management, Management Agreement (WAFMA) with the Northern leaders in this image are now deceased, though their legacy lives especially of fire, the physical and spiritual Indigenous Territory Government. This first-of-a-kind agreement on. Image courtesy of Peter Cooke. estate was sick. saw ConocoPhillips support Landowners to restore
fire management over more than 28,000 km2 of west
Satellite fire histories corroborated Traditional Owner’s Arnhem Land (the WALFA project area) to offset GHG
concerns, showing fire regimes across the region emissions from their newly established Darwin Liquified
dominated by late dry season wildfire, often burning Natural Gas (DLNG) plant.
intensely over thousands of square kilometres and
A homegrown success story
only extinguished with the coming of the annual wet The WALFA project proved to be an innovative and
season rains. effective solution to securing long term funding to
support fire management, and immediately allowed

The history of fire projects
These discussions led to the development of a vision Traditional Landowners and Aboriginal rangers to
of people again living on healthy country, and of fire get back out on country, initiating fire management
management as a key contributor to this vision. programs that reconnected people to country and
brought back strategic, cool early dry season burning

in west Arnhem Land
Over the next decade, Indigenous ranger groups in at a landscape scale.
Arnhem Land used the limited resources available to
them to refine their ability to manage fire at a landscape It is difficult to overstate the impact of the WALFA
scale, developing ways of emulating customary fire project on today’s carbon market. As the landscape
management using modern tools. scale model upon which the government-approved
Savanna Burning Methodology was based, WALFA
Meanwhile, scientists developed methods to measure has provided a template for every current and future
the extent of fires, and calculate the seasonal differences savanna burning fire management project across
in greenhouse gas (GHG) emissions between early northern Australia.

18 19
The origin of ALFA

“From a Western ecological perspective, fire management in Arnhem
Land resourced through ALFA’s engagement with the carbon industry, has
successfully addressed the prevalence of hot, widespread and destructive
wildfires in the landscape – a threat to the environmental assets of
northern Australia recognised in both Aboriginal and Western science
knowledge systems.” 1

Following the introduction of carbon legislation in Currently, nine Aboriginal ranger groups consisting
Australia in 2011, the five ranger groups partnered in of Traditional Owners and their families, undertake the WALFA project decided they wanted to transition all operational aspects of the landscape scale fire the then voluntary WALFA project to an eligible offsets management that occurs across the five ALFA project, which would allow them to earn and sell ACCUs. project areas. Membership of ALFA is open to any
Extensive Landowner consultations ensued, focusing Traditional Owner of land where an ALFA project on how to create an Aboriginal-owned company to operates – as such, ALFA is at once an alliance and a represent them collectively in their engagement with collaboration between Traditional Owners and their the carbon market. affiliated ranger groups.

In 2013, WALFA Limited was established for this purpose, In developing ALFA, Traditional Owners were clear and in 2015 the name of the company was changed in their directive that the company should be to ALFA (NT) Limited, to reflect its growth throughout not-for-profit, and that all revenue from the sale of ACCUs
Arnhem Land. ALFA registered WALFA as an eligible must be reinvested back into the Aboriginal ranger offsets project in late 2014, and since then the company groups to provide local employment while preserving has grown to support Traditional Owners to register culture and the environment. ALFA continues to operate and operationalise projects in central, south-east and under this directive, operating with minimal overheads north-east Arnhem Land. Together, these projects cover such that 95 per cent of all income generated is paid Yugul Mangi ranger Winston a significant and contiguous area of almost 80,000 km2 to the ranger groups for the purpose of supporting Thompson surveys an early burn
creeping through savanna of Arnhem Land. and improving fire management activities across the woodland. Photo courtesy of
project areas. Northern Land Council.

20 21
Savanna Burning
Methodology
“95 per cent of all income generated is paid to the
ranger groups for the purpose of supporting and improving
fire management activities across the project areas.” 1

A chopper ferries rangers from the fire line. Photo © Matthew Abbott.

All savanna fires emit greenhouse gases, in particular Net abatement is determined by measuring the
methane and nitrous oxide. The Savanna Burning difference between methane and nitrous oxide
Methodology uses strategic fire management to reduce emissions from a project’s baseline period against
the emission of methane and nitrous oxide from the each subsequent project year. The difference between
burning of savannas, compared to the emissions from baseline and annual project emissions reflects the
a baseline period. change resulting from a change in fire management
practices, and in Arnhem Land, the reintroduction of
Each carbon credit unit generated under the Savanna customary burning. Importantly, projects only generate
Burning Methodology represents one tonne of carbon credits if they are successful in avoiding
carbon dioxide equivalent net abatement achieved emissions of methane and nitrous oxide compared to
Josephine Austral of Mimal rangers blows out by undertaking planned fire management within the their baseline period.
a flaming drip torch. Photo © Renae Saxby. project area.

22 23
Australian Carbon Credit Producing ACCUs
Units (ACCUs) Generation How is success measured?

How does it work?

Total amount of carbon
abated by ALFA projects since
company began

4,886,774
*Total for all projects.
1 tonne carbon dioxide
equivalents (CO2-e)
=
1 Australian Carbon
Credit Unit (ACCU)

Warddeken ranger Zacharia Namarnyilk watches a cool fire trickle through The production of Australian Carbon Credit Units All five ALFA fire projects operate under the approved
savanna woodland on mother’s country at Makkalarl. Photo © Matthew Abbott. is highly regulated to ensure that emissions Savanna Fire Management method. This method was
reductions are genuine, additional to business-as- one of the first to be approved and is considered to
usual, can be counted towards Australia’s emissions be one of the highest integrity methods.
reduction targets, are measurable and verifiable,
The Clean Energy Regulator issues Australian Carbon ALFA’s five offsets projects generate carbon credits evidence-based, account for project emissions and are An important feature of this method, is that the eligible
Credit Units (ACCUs) for greenhouse gas abatement through Federal Government legislation focused on conservative – these are the principles of the Offsets activity – landscape scale fire management – is never able activities undertaken as part of the Emissions Reduction carbon farming. The issuance of ACCUs is governed by Integrity Standard. to become “business as usual”. The application of planned,
Fund, a federal scheme that provides financial the Carbon Farming Initiative Act (CFI) 2011, the Carbon fire management at a landscape scale, which needs to incentives to organisations and individuals to reduce Credits (Carbon Farming Initiative) Regulations 2011 There are a number of requirements that must be occur every year for the project to remain eligible, is their greenhouse gas emissions and improve their (CFI Regulations 2011) and the Carbon Credits (Carbon satisfied before a project can be formally declared an incredibly resource intensive. The funds derived from energy efficiency. Farming Initiative) Rule 2015 (CFI Rule 2015). ‘eligible offsets project’, and there are ongoing, annual the sale of ACCUs are required to finance the eligible
requirements in undertaking an eligible offsets project. activity – fire management.

These requirements include: This is clearly verified through examination of satellite
— There must be an approved methodology for the type fire scar mapping which demonstrates that the adoption
ACCU issuance to date of project. of the savanna fire management method has been the
— The project must deliver abatement that is additional direct cause of recent positive changes in fire management
to what would occur in the absence of the project. across much of northern Australia.
— The project must be undertaken in accordance with
WALFA ACCU CALFA ACCU SEALFA ACCU SEALFA2 ACCU NEALFA ACCU
the methodology and comply with other scheme The savanna fire management method is built upon millennia
issuance to date issuance to date issuance to date issuance to date issuance to date eligibility requirements. of Indigenous Traditional knowledge and decades of
— The project proponent must report to the Regulator peer-reviewed scientific research. The combination of which
2,116,442 2,102,640 265,742 100,708 301,242 about the conduct of the project and the abatement provides an ecologically appropriate, robust, measurable
achieved. Certain reports must be accompanied by a and verifiable method that delivers a permanent greenhouse
report prepared by a registered greenhouse gas and gas reduction annually with no risk of reversal as well as other
energy auditor. environmental, cultural, social and economic outcomes.

24 25
Every year ALFA generates ACCUs from the ALFA ACCUs are highly sought after on the voluntary five registered savanna burning project areas. market, which comprises a significant proportion
A public record of these ACCUs is available online of ALFA’s ACCUs sales annually. Voluntary buyers in the Emissions Reduction Fund Project Register are aware of the cultural, social and environmental cleanenergyregulator.gov.au benefits that are achieved through the operation
of the fire projects, as well as the reinvestment of
A number of carbon markets operate in Australia carbon income to other projects that support local for producers of carbon to sell their ACCUs. These communities.
include selling ACCUs to the Australian Government through the Emissions Reduction Fund, selling ACCUs ALFA’s partner groups have been abating GHG to companies with carbon compliance obligations emissions through fire projects for up to 15 years, under the safeguard mechanism and the voluntary making them some of the most experienced savanna market, where companies and organisations choose burners in the world. Each group documents their work to voluntarily purchase ACCUs to offset their activities in detail, with a thorough and independent carbon footprint. audit conducted annually.

Mimal rangers Josephine Austral and Kaitlyn John. The number of women involved in fire
management across ALFA’s project areas has increased significantly over the previous five years,
with many ranger groups achieving gender equity within their respective workforces. This is one
of many factors defining the ACCUs produced by ALFA as high integrity. Photo © Renae Saxby.

Equally as important as environmental compliance is — Fire projects have inspired the transmission of
the flow-on positive impacts of fire projects for knowledge and skills including making and carrying
Traditional Owners in Arnhem Land, which are fire using bush tools, kangaroo fire drives and the
abundantly evident across a range of environmental, language of fire behaviour.
cultural and social co-benefits. — People are spending more quality time out bush,
where they are able to access and harvest bush
Environmental co-benefits tucker not available in bigger towns.

Producing
— Reinstating customary burning pattern across — Ranger groups now have the resources to run
landscapes has improved the overall ecological and bushwalks, cultural camps and other events focused
cultural health of country. on intergenerational knowledge transfer.
— Protection of fire sensitive ecological communities — Ranger groups are working closely with schools to
such as Anbinik (Allosyncarpia ternata) rainforest teach young people the intricacies of customary fire
isolates, jungle patches and the federally declared knowledge and practice.
Arnhem Plateau.
— Many endemic, culturally important and/or Social co-benefits
threatened flora and fauna species require cool — Millions of dollars are reinvested annually in remote
burning regimes to thrive. communities through ranger wages.

high integrity
— ALFA has inspired others to replicate our model — Ranger programs offer meaningful, highly sought-after
of business, leading to increased overall global roles in economically disadvantaged regions.
GHG avoidance. — More women rangers are involved in fire operations
— Biodiversity monitoring data suggests that where every year.
critically endangered small mammal populations — Regular income provides food security for families.
persist, there is a correlation with good fire management. — Ranger work is physically active.
— Ranger programs support staff to access to training
Cultural co-benefits and education.
— Traditional Owners are supported to live and work

ACCUs
on country, with ranger programs offering a genuine Additional to the benefits derived directly from the
future for people on country. delivery of the fire projects, income created from
— Participation in fire programs enhances cultural ALFA’s sale of ACCUs allows ranger groups deliver other
identity through connecting Traditional Owners with community-driven projects.
‘orphaned’ clan estates.
— Traditional Owners are supported to make decisions Organisations and companies can contact ALFA
about and participate in the active management of directly if they are interested in purchasing high
their country. integrity ACCUs that support these outcomes.

26 27
ALFA’s custom training program
After working closely with our partner groups over many years, ALFA identified the need to devote more effort to developing capacity and recognising the existing skills of Aboriginal rangers undertaking fire management within Arnhem Land.

In 2020, funding was secured for a three-year project and an operational flight under instruction which includes to develop a model of training delivery that adapts an in-flight emergency fire drill (students must also
Nationally Accredited Units of Competency to an complete a further two operational flights of at least
Arnhem Land context. The aim is to increase the capacity one hour to gain competency).
of rangers to deliver best practice fire management across Arnhem Land. Funding was obtained from Oversight of the project will be undertaken by a Training the Indigenous Land and Sea Corporation (ILSC) and the Reference Group. This small expert group is made up of
Karrkad Kanjdji Trust (KKT) and in 2021, ALFA entered Traditional Owners, Aboriginal rangers and supported into a third-party delivery agreement with a local by an expert in cross cultural adult education from
NT based Registered Training Organisation (RTO), Train Charles Darwin University.
Safe NT.
By the end of 2021, ALFA has four units of competency
ALFA’s training project commenced this year and will on scope with Train Safe NT.
run until 2023. It is being managed by Mark Desailly, who These are: brings to the role four years’ experience with ALFA as — Work safely around aircraft course PUAFIR017.
well as extensive experience delivering informal training — Operate aerial ignition equipment in an aircraft to ALFA’s partner ranger groups over many years. PUAFIR008.
— Prevent injury PUAFIR210.
Initial consultations with partner ranger groups — Respond to wildfire PUAFIR204.
highlighted that the clear priority for all groups was to undertake accredited training in helicopter-based fire These units of competency relate directly to skills and management operations. knowledge rangers require in their prescribed burning ALFA’s Training Manager Mark Desailly works one-on-one with young Warddeken
and firefighting activities. ALFA will provide training in ranger Recain Nabarlambarl to equip her with the skills and confidence to operate a
Raindance incendiary machine, as well as with more experienced rangers in a refresher
The delivery and method of assessment for the work the above units as early dry season burning commences on helicopter safety. Photos courtesy of Warddeken Land Management.
safely around helicopters and aerial incendiary course in 2022.
was trialled with six different ranger groups.
We are fortunate in that through the funding of this
Training involves hands-on instruction in the use, project, we have the flexibility to mesh accredited maintenance and safety features of the Raindance training with normal ranger work activities and the time incendiary machine; theory of the principles of operation to ensure a focus on quality.

28 29
North West Arnhem Land (NWALFA)
— A New Fire Project to commence in 2022

NWALFA

NEALFA

WALFA CALFA

SEALFA

During 2021, ALFA undertook pre-consultation work
with individual Traditional Owners, using a large pictorial
information booklet to support conversations about
SEALFA
Stage 2
the following:
— Explain the project in detail.
— Explain the setup of ALFA and its involvement in the
support of fire projects.
— Talk through fire history maps to look at current fire
management regimes.
N — Gather information related to Traditional Owners’
aspirations for fire management on their country.
— Determine whether there is interest in their clan
estates being included within a new fire project area,
For a number of years, Traditional Owners from and if so, take initial instructions from Traditional
north-western Arnhem Land have watched the Owners on how they would like to be involved with
emergence of fire projects in neighbouring regions, and the project.
expressed their interest in establishing and registering
a fire project across 25 clan estates in the region north Pre-consultation indicated that overwhelmingly,
of Gunbalanya all the way to the coast. Traditional Owners were in favour of registering and
operating the NWALFA (North West Arnhem Land Fire
During this time, a number of Traditional Owners from Abatement) project in time for the 2022 fire season.
the project area were supported by ALFA to attend Traditional Owners also worked through maps of
pre- and post-season fire meetings, allowing them country and gave initial instructions in regards to how
to listen to ranger groups present, observe planning they would like to be involved in the fire management
processes, and discuss the fire project with Aboriginal project in 2022.
family members from other groups.
Following the favourable pre-consultation results, the
In 2020, a request was formally made to ALFA from NLC completed the consultations required to enter into
the Northern Land Council (NLC) and Demed Aboriginal a Land Use Agreement with Traditional Owners.
Corporation to undertake information sharing,
pre-consultations about formally establishing a ALFA looks forward to the finalisation of the NWALFA
North West Arnhem Land (NWALFA) Fire Project. Land Use Agreement in 2022 and the subsequent
registration of the new project with the Clean Energy
The project area includes country managed alongside Regulator. Preparations are already underway for
and on behalf of Traditional Owners by the Adjumarllarl, fire management to commence in the early dry season
Photos courtesy of ALFA (NT) Limited. Garngi and Mardbalk ranger groups. in 2022.

30 31
Project Summaries

Summary of ALFA WALFA CALFA SEALFA SEALFA2 NEALFA project areas
(>1000mm) (600–1000mm)

Ranger groups involved Ranger groups involved Ranger groups involved Ranger groups involved Ranger groups involved
— overall key Bawinanga Rangers
Mimal Rangers
Bawinanga Rangers
Mimal Rangers
Yugul Mangi Rangers
Numbulwar Rangers
Yugul Mangi Rangers
Numbulwar Rangers
Yirralka Rangers statistics Jawoyn Rangers
Warddeken Rangers
ASRAC Rangers

Adjumarllarl Rangers

“From a Western ecological
perspective, fire management
in Arnhem Land resourced
through ALFA’s engagement Project area Project area Project area Project area Project area
with the carbon industry, has
successfully addressed the
prevalence of hot, widespread
and destructive wildfires in
28,000 km2 26,000 km2 5,000 km2 10,000 km2 11,000 km2
the landscape – a threat to
the environmental assets of
northern Australia recognised
in both Aboriginal and Western
science knowledge systems.” 1

Running for: Running for: Running for: Running for: Running for:

11 years 11 years 11 years 7 years 6 years

1 tonne carbon dioxide ACCU issuance ACCU issuance ACCU issuance ACCU issuance ACCU issuance equivalents (CO2-e) to date to date to date to date to date

2,116,442
= 1 Australian Carbon
Credit Unit (ACCU)
2,102,640 265,742 100,708 301,242

32 33
2021 Fire Management Outcomes

Summary of ALFA WALFA CALFA SEALFA SEALFA2 NEALFA project areas —
(>1000mm) (600–1000mm)

Flight line km Flight line km Flight line km Flight line km Flight line km
2021 management 29,900 27,000 3,200 6,500 6,140 statistics
*ALFA partner groups
combined totals.

Flight line kilometres represent the total distance flown by each EDS % burnt EDS % burnt EDS % burnt EDS % burnt EDS % burnt project during aerial prescribed burning operations.

EDS % is the per cent of the
30.1 31.2 18.6 22.3 13.4
LDS % burnt LDS % burnt LDS % burnt LDS % burnt LDS % burnt project area burnt in the early dry season (January to July).
LDS % is the per cent burnt in the late dry season (August
3.3 4 15 15.7 25.1 to December).

Unburnt % represents the total area of each project unburnt Total % Total % Total % Total % Total % by early or late fire. Research burnt Unburnt % burnt Unburnt % burnt Unburnt % burnt Unburnt % burnt Unburnt %

33.4 66.6 35.2 64.8 33.6 66.4 38.0 62.0 38.5 61.5 suggests maintaining long unburnt areas of country is a key requirement to protect threatened fauna, and so undertaking planned burning early in the EDS and active wildfire prevention in the LDS to maintain large tracts of unburnt country is critically important.

1 tonne carbon dioxide ACCU issuance ACCU issuance ACCU issuance ACCU issuance ACCU issuance equivalents (CO2-e)
= 1 Australian Carbon
Credit Unit (ACCU) 281,055 340,952 30,217 -130 45,122

34 35
Fire
Management
Activities
Summary
2021
Planning and Consultation
On ground burning
Aerial burning
Wildfire suppression

Mimal ranger Ross Tukumba.
Photo © Renae Saxby.

36 37
Before the fire season begins, rangers talk PLANNING
AND CONSULTATION with Traditional Owners of clan estates

372 within their respective project areas about where and how they want early burning to happen on their country and how they might TRADITIONAL like to be involved. These consultations set OWNERS CONSULTED the framework of each ranger group’s annual burning plan. Above: Bawinanga rangers discuss fire management plans
for the year. Photo © David Hancock.
Below: The first opportunity for project partners to come
together in person in 2021 at the ALFA pre-season meeting
in Maningrida. Photo courtesy of ALFA (NT) Limited.

ALFA (NT) held a pre fire season meeting at Maningrida Additionally, rangers workshopped their collective on 7th and 8th April 2021. There were over 70 participants needs and aspirations in relation to training, to in the meeting, consisting of representatives from all assist ALFA to further develop and customise the ranger groups involved in ALFA (NT) fire projects as training program.
well as other stakeholders. The rangers discussed their management plan with neighbouring ranger groups Each ranger group also undertakes internal Landowner and presented on their proposed burning activities for consultations, ensuring that the right people for each the year. clan estate within their respective operational areas
gives consent for burning work to occur, is able to
Rangers workshopped best practise engagement of nominate who they would like to undertake aerial
Traditional Landowners in fire management focusing on: prescribed burning (APB), and advises whether they
— Why is Traditional Owner involvement and oversight would like to be involved in any of the upcoming fire
important? season activities. COVID-19 restrictions also hindered
— What are ranger groups already doing to engage Landowner consultations for most groups, however in
Traditional Owners? all cases ranger groups used innovative and creative
— How can we improve Traditional Landowner approaches to ensure sufficient approval and permission
involvement and oversight? was obtained prior to prescribed burning commencing.

38 39
Historically, landscape scale burning was achieved
as people moved across country, burning as
EARLY DRY SEASON they went. On ground burning remains a core
BURNING – ON GROUND
component of the fire management activities

13,390
undertaken by ranger groups, who work throughout
the early dry season to establish fine scale and
targeted firebreaks. On ground burning is often
KILOMETRES ON GROUND BURNING
performed for the purpose of protecting cultural,
environmental and infrastructure assets.

228
RANGERS INVOLVED
Opposite top left: Homeland residents play an integral role in early
burning due to their constant presence on country.
Opposite below left: Warddeken rangers protect environmental and
cultural assets through installing and back burning from fire breaks.
Photos courtesy of Warddeken Land Management.
Below right: Adjumarllarl rangers perform asset protection burns
around solar arrays and other infrastructure at homelands across
their project area. Photo courtesy of ALFA (NT) Limited.

On ground burning is undertaken by rangers and
Traditional Owners across the project areas, particularly
along roadsides and hunting tracks, infrastructure and
around important cultural and environmental sites.
Rangers perform ground burning from a vehicle (4WD
or quad bike) or by foot, using a drip torch or matches
as the ignition source.

Before aerial burning operations begin, rangers first
secure infrastructure and assets across their respective
management areas. This involves installing firebreaks
and implementing protective burns at cultural sites
including rock art galleries and sacred sites, as well as
securing infrastructure including houses, buildings and
water and energy assets at homeland communities.

Many ranger groups run events such as cultural
camps and bushwalks, involving young people and
elders, which allows groups of Landowners to conduct
fine scale burning across large tracts of country that
may not otherwise be visited. For many ALFA partners,
these activities are of great importance, as they allow a
new generation of Traditional Owners to burn country
as the old people did.

Data for ground burning activities is recorded by ranger
groups using GPS, CyberTracker and work diaries.

40 41
Each year, rangers take to the skies to deliver incendiary burning across vast tracts of remote country — a synthesis of customary and contemporary ecological management practices.

Aerial prescribed burning (APB), delivered from
Robinson 44 helicopters and utilising incendiary
delivery machines, allows rangers to access remote
regions of their project areas and cover vast tracts of
otherwise inaccessible country. APB creates a mosaic
of burnt country throughout project areas, and also EARLY DRY
secures the boundaries between neighbouring groups.
SEASON BURNING
APB flight routes are determined by many factors,
including: topography, previous years’ fire scars,
– AERIAL
sacred sites, local knowledge and experience, real-time

72,740
observation of grass and conditions, and type of soil
and vegetation. Rangers utilise the existing features
of the landscape, such as rivers and roads, to create
Mimal female rangers prepare to deliver strategic aerial burning. Photo © Renae Saxby.
landscape scale firebreaks comprised of burned and
natural breaks.

APB by its very nature is a thoroughly modern fire
management tool, however, rangers and Traditional
Owners are readily able to translate knowledge of KILOMETRES FLOWN
country and fire behaviour to an aerial approach.
Importantly, through adjustments to the delivery rate
of incendiaries, APB can be tailored to deliver very

175
specific burning results taking into account weather
and fuel conditions for different environments in the
landscape. Rangers from all partner groups are now
highly experienced in APB operations. As a result of
this, APB operations across ALFA project areas are
increasingly being undertaken solely by senior rangers
and Traditional Owners. ALFA’s custom training will
further support this trend. TRADITIONAL
OWNERS INVOLVED
Ranger groups record aerial burning activities using Warddeken Rangers and Landowners
take off in an R44 helicopter to perform
either a combination of GPS and work diaries, or strategic APB across the Warddeken
CyberTracker to document flight lines. IPA. Photo © Matthew Abbott.

42 43
In the late dry season, rangers’ focus shifts to the prevention of wildfires, which burn hot and WILDFIRE uncontrolled as weather conditions become SUPPRESSION warmer and drier. This involves promoting awareness of dangerous fire conditions amongst community members, as well as intensive wildfire suppression campaigns to protect
120
RANGERS priority areas of country.
“We define success of the firefighting based on the plan and outcome
of the plan. For example, sometimes we can put out the entire wildfire
and that is a success. Sometimes, we stitch upgaps and backburn
and leave the fire and that is a success.”
— Jawoyn Rangers
6,550
PERSONNEL HOURS

A team of Warddeken rangers works a fire line with
backpack leaf blowers, pushing the flames and embers
back in on themselves in an attempt to control the blaze.
Photo courtesy of Warddeken Land Management.

Increasingly, wildfire suppression has become a major often fight fires that threaten important cultural or
component of annual fire management programs. environmental sites, and on many occasions have
Most firefighting is undertaken ‘dry’, meaning rangers preserved significant cultural and environmental assets
use techniques of controlling fires that do not involve through extinguishing wildfire.
water, such as installing mineral earth breaks that
act as a barrier to pull up fires through removing One of the most unique aspects of firefighting in
combustible fuel. Arnhem Land is rangers’ use of backpack leaf blowers
Rangers prepare to be dropped into a fire front in containing wildfires – by blowing out flames and
by a helicopter. Photo © Matthew Abbott. Helicopters are often required to ferry teams of blowing embers and combustible fuels such as grass
firefighters in to access remote fire lines. Rangers and leaf litter back into the active fire.

44 45
United Nations Sustainable
Development Goals

The United Nations (UN) Sustainable Development
Goals are a global call to action protect the
planet, end poverty and improve the lives and
prospects of everyone, everywhere. The 17 Goals were
adopted by all UN Member States in 2015, as part of
the 2030 Agenda for Sustainable Development, which
sets out a 15-year plan to achieve the Goals
sdgs.un.org/goals

ALFA’s partners are proactively addressing a number emissions and improved ecological health of country.
of the UN Sustainable Development Goals through However, equally importantly, ranger programs also the delivery of their land and cultural heritage generate a host of cultural, economic and social management programs. With income created from co-benefits to Traditional Owners and their families.
the sale of ACCUs, ranger groups are able to deliver Many bush foods still favoured today are their respective fire management programs, as well ALFA’s partners are addressing the following Sustainable reliant on cool, sustainable fire regimes.
as other community led projects leading to positive Development Goals through the annual delivery of their Photo © Renae Saxby. environmental outcomes through reduced carbon fire management programs.

46 47
Goal 1. No Poverty Goal 3. Good Health and Wellbeing Goal 8. Decent Work and Economic Growth Goal 13. Climate Action

Millions of dollars annually Ranger work is active and promotes Ranger programs offer meaningful, The work of ALFA partners leads
reinvested in communities physical activity. highly sought-after roles in to significant GHG emission
through wages. People are able to harvest and access economically disadvantaged regions. reduction every year.
Ranger programs provide bush tucker through ranger programs. Ranger programs support staff to ALFA has led others to replicate
employment opportunities in Supported to live and work access training and education. our model of business, leading to
remote communities. on their country. more GHG avoidance.
Connection to cultural identity.

Goal 2. Zero Hunger Goal 5. Gender Equality Goal 11. Sustainable Cities and Communities Goal 15. Life on Land

Ranger groups operate food security All of ALFA’s partners have Ranger groups provide essential Ranger work respects the
programs such as tucker runs. women’s ranger programs. services in remote communities. choice of Traditional Owners to
Regular income allows families More women rangers Ranger groups offer the only remain on country.
to buy food. are getting involved in fire employment at many homeland Ranger groups are providing a
Support people living on country operations every year. communities. future for people on country.
and accessing bush foods.

48 49
ALFA is partnered with nine community and homeland-based Aboriginal ranger groups, supporting them to collectively deliver five fire management projects across 80,000 km2 of Arnhem Land.

The fire project areas include ranger groups managing four declared Indigenous Protected
Areas (IPAs) — the Djelk, Warddeken, South East
Arnhem Land and Laynhapuy IPAs, as well as two
IPAs currently under consultation — the Mimal and ASRAC IPAs.

The following section of the report is an opportunity for each of our partner groups to share highlights from their 2021 burning season, and demonstrate the exceptionally high quality at which they deliver their work.

Rangers from each of ALFA’s partner groups maintains a
network of tracks and roads across their management areas,
allowing them to access country for both early and late
season fire management activities. Photo © Matthew Abbott.

50 51
Adjumarllarl Rangers
– Meaningful collaboration

The Adjumarllarl rangers were one of the Northern Owners to share knowledge of fire management to
Territory’s first Aboriginal ranger programs, and have preserve and protect these sacred areas.
been working out of Gunbalanya in western Arnhem
Land for over 30 years. Adjumarllarl rangers manage This year Adjumarllarl commenced a Community approximately 10,000 km2 including floodplains, Development Program (CDP) through sub-contractor savanna woodland and sandstone escarpment. agreement with the Arnhem Land Progress Aboriginal
Corporation (ALPA). This resulted in job seekers carrying
Operating at the gateway to Arnhem Land, Adjumarllarl out fire breaking activities safely. Rangers provided are on the frontline of managing invasive weed species Traditional Owners and job seekers with matches and and have worked determinedly over the years to training on how to burn safely in areas where rangers ensure that highly flammable gamba grass – which were unable to gain access. This collaboration enabled burns three times as hot as native grasses and can the ongoing protection of sacred sites, and empowered render savanna burning projects ineligible – does not Traditional Owners to continue caring for their land.
take hold in Arnhem Land.
In addition to installing fire breaks on homelands,
Throughout 2021, the Adjumarllarl ranger team rangers also completed back burning around the consisted of four full-time rangers and a pool of casual following assets within the project area: employees, representing Traditional Owners from — Access tracks and roads.
across the operational area. The team dedicated — Creeks and rivers.
more than 2,000 hours to executing an overall fire — Cultural/heritage sites (where access is management plan. allowed by Traditional Owners).
— Escarpment edges.
Adjumarllarl commenced the dry season by consulting Traditional Owners and representatives With extreme weather conditions and COVID-19 from the homelands within the prescribed fire restrictions in place during the year, the timeframe management area, allowing Landowners to contribute for safe fire management burning was significantly invaluable knowledge of their country and the reduced, however, rangers were still able to dig deep current climate, as well as providing their informed and complete the project for another successful year.
consent for all fire plans and activities on their land. Rangers conduct asset protection burning
at homeland communities, ensuring houses,
During the consultation process, Traditional The Adjumarllarl rangers look forward to another year power and water facilities and other
Owners also identified sacred sites with restricted of active fire management in 2022, and continuing the infrastructure is protected. Photo courtesy access. Adjumarllarl acknowledges and respects close collaboration with Traditional Owners, ALFA and of ALFA (NT) Limited. the directions received, and work with Traditional neighbouring ranger groups.

52 53
Arafura Swamp Rangers
Above: The poster created by ASRAC
rangers and Landowners to visually
represent elements of a culturally-driven
fire program.

– Culturally-driven burning
Below: ASRAC rangers completed more
than six thousand kilometres of on ground
burning, traversing long distances in
vehicles and on foot, emulating the way old
people burned.
Photos courtesy of ASRAC. The right people burning country at the
right time with a strong carbon business,
and there are plenty of healthy
sugarbag, emu and kangaroo

The Arafura Swamp Rangers Aboriginal Corporation of that, is engagement of Traditional Owners in APB
(ASRAC) comprises seven ranger groups that work activities either as a navigator or as a Raindance with Traditional Owners to keep Indigenous knowledge machine operator.
strong and to make sure it is being used to look after country. Together these ranger groups look after An important part of ASRAC’s annual right way fire the Gurruwiling (Arafura Swamp), its catchment management is to create opportunities for the transfer and adjacent sea country: Dhupuwamirri rangers, of customary knowledge of fire and fire practices. In
Donydji rangers, Mirrngandja rangers, Malnyanganark 2021, rangers delivered a number of such activities.
Bukgurl-na rangers, Balmawirrey Dhipirri rangers, Ramingining School students were involved in on ground
Gupulul Marayuwu rangers, Gurruwiling rangers and burning through the Learning on Country (LoC) program.
Wanga Djakamirr rangers. The Arafura Swamp rangers ASRAC rangers talked to students about the importance are currently consulting on a proposed new IPA of right way fire and the theory behind culturally-driven covering 14,000 km2 which includes the Gurruwiling burning. Students then had the opportunity to partake
(Arafura Swamp) – a vast wetland surrounded by a in burning in the Dhabla area and put what they learnt catchment extending from Castlereagh Bay to the into practice.
upper reaches of the Goyder and Glyde Rivers.
ASRAC supported a Balparra Camp at Malnyanganark
Prior to prescribed burning, ASRAC rangers carry outstation and at Djilpin, where family gathered to out asset protection burning at 21 outstations around share knowledge on fire. Another Balparra Camp was local power and water infrastructure, transport held at Dhipirri outstation over a week in October.
infrastructure and at sacred sites. During outstation Traditional Owners, elders and community got together firebreaks Landowners, Djungayi (mother’s country on country to discuss the effect of bushfires on their relationship) and family are engaged to help. land. Discussion focused on whether people felt fire
management was improving or not, and if controlled
Ranger groups carried out 6,210 kilometres of on burning was leading to the desired objectives of ground burning, mostly on foot. Ground burning was also plentiful bush tucker, habitat for animals, knowledge conducted with Landowners and family groups during sharing and cultural obligation.
camps in Malnyanganark, Djilpin and Donydji areas. The location of APB runs was decided in consultation with The outcome of these important conversations led to
Landowners and Djungayi by going through proposed the development of a ‘Right Way Fire’ poster, which lines on computer maps, and then jointly adjusting. visually represents the elements of culturally correct
ASRAC’s focus on right way fire, and one of the key aspects fire management practice.

54 55
Bawinanga Rangers
– Strong relationships

DJE LK Left: Rangers inspect a rock art gallery they have
protected through their firefighting efforts.
Right: As in previous years, Bawinanga and Warddeken
rangers stepped in to assist one another, working
collaboratively on a number of occasions to suppress
wildfires in both project areas.
Photos courtesy of ALFA (NT) Limited.

When firefighting in rugged terrain rangers must carry supplies with them, including chainsaws and fuel, which allows them to fell trees threatening to breach hard-won fire breaks. Photo courtesy of ALFA (NT) Limited.

Bawinanga rangers are pioneers of Australia’s requested collaborative plans be made in order to
Indigenous land management movement. Formed by ensure rangers involved the right people in burning
Traditional Owners in the early 1990s in response to operations. Many Traditional Owners and Djungkay,
growing environmental concerns such as feral animals, took advantage of the opportunity to use a helicopter to
invasive weeds and wildfire, for 30 years Bawinanga inspect and burn country in ways that are not possible
rangers have worked to keep their land and sea from the ground.
country in western Arnhem Land healthy. Rangers are
based in the community of Maningrida and service an In the late fire season, Bawinanga rangers responded to
area of over 10,000 km2, which includes more than 30 40 wildfires within the project area, as well as assisted
family-based outstation communities. Warddeken rangers in putting out fires in the shared
boundary of the Warddeken and Djelk IPAs. ALFA fire
Bawinanga rangers worked in small groups to engage officer Steph Rouse also provided valued support
and consult key Traditional Owners and Djungkay in wildfire responses. Working collaboratively with
– people who speak for each outstation in Bawinanga’s partners is an opportunity to strengthen both groups’
area of operations. Rangers utilised a Traditional Owner fire response capacity.
Delegation List to guide these consultations.
In continuing Bawinanga’s commitment to supporting
In preparation for the 2021 fire season, rangers the development of emerging generations as fire
commenced asset protection burning, including creating managers, rangers worked closely with Maningrida
fire breaks at over 36 outstations and other third-party Community College’s Learning on Country program and
infrastructure such as Telstra communication towers Bawinanga interns to build skills and knowledge and to
and the Arnhem Land Barra Lodge. When ground undertake practical fire management activities.
burning started in late April, rangers provided wind and
waterproof match packages to Traditional Owners to In 2022, Bawinanga rangers look forward to working with
burn and protect their sacred areas. Landowners and Djungkay from across the Djelk IPA to
build on the success of this year’s fire management,
Aerial prescribed burning was informed by the feedback as well as strengthening existing relationships with
and wishes of Traditional Owners and Djungkay, who partners and neighbours.

56 57
Jawoyn Rangers
– New opportunities

Jawoyn rangers have been caring for country by Creek, Mangarrayi and Wagiman rangers. Jawoyn
incorporating customary values and culture with completed all but two of the prescribed blocks in the
the latest in scientific practice since the late 1990s. contract, and this new program of work provided both
Operating out of Jawoyn Association headquarters an additional funding source as well as an opportunity
in Katherine, Jawoyn rangers manage 16,000 km2 of for Jawoyn rangers to hone their fire management skills
country including part of the west Arnhem Land plateau in different country and contexts.
– stone and gorge country that contains one the world’s
largest and most significant bodies of rock art. As part of the VCL burning project, certified training was
also incorporated into real-world applied work activities.
All the money generated through Jawoyn’s fire Further training was provided by Mark Desailly in
management program is reinvested in activities that operating Raindance machines, as well as fire response
support important social, cultural and environmental training at Nitmiluk National Park as part of ALFA’s
outcomes, for example managing country, offering new training program. Mark Desailly of ALFA and Jay
increased jobs and training for Landowners and Evans of the Darwin Centre for Bushfire Research also
custodians, and connecting people back to country. delivered training focused on using GIS and the North
The reduction in late dry season wildfire also helps Australian Fire Information (NAFI) website to enhance
protect significant fire sensitive ecosystems and the fire management.
many threatened plants and animal species in
the Jawoyn region. Rangers and Landowners report Jawoyn rangers worked with neighbours including
seeing important birds, mammals and reptiles Nitmiluk National Park rangers to perform on ground
returning to country since the inception of the fire burning around the Biddlecomb Tourist Camp along
management program. the Jatbula Trail, around Jodetluk (Gorge Camp) with
Bushfires NT, around Safari Camp (Waterhouse) and at
This year, Jawoyn rangers were able utilise their skill and Nipbarnjarn Waterfalls Camp.
experience as fire managers to take on a contract to
deliver prescribed burning on Vacant Crown Lands (VCL) Aerial burning with stakeholders and neighbours
from March through to August. The VCL contract saw included Nitmiluk National Park, Sleisbeck and
A smoky sunset on the west Arnhem rangers travel across the NT to Mataranka, Borroloola, Snowdrop in Kakadu National Park, the border along plateau. Photo © Matthew Abbott. Timber Creek, Pine Creek and Katherine township, Conways Station, top of Eva Valley (Manyallaluk), and
where they worked alongside Waanyi Garawa, Timber around Edith Falls (Leliyn).

58 59
Mimal Rangers
– A greater role for women

The Mimal Land Management operational area sits at in the soil and plants keeping early burns small and the geographic centre of Arnhem Land. Mimal country cool, and less windy conditions in the late dry season is made up of many different ecosystems – from keeping wildfires more manageable. The more favorable grassy plains, rock country, woodlands and forest to conditions were enhanced by concentrated strategic freshwater country. The main communities and planning efforts and responding quickly to wildfires with homelands in the area include Bulman, Weemol and a dedicated crew of rangers.
Barrapunta (Emu Springs). Mimal are currently being supported by the Federal Government to establish a Women rangers took on a greater role in planning and new IPA that will cover over 18,000 km2 in south-central consultations this year, and were able to talk with 32
Arnhem Land. senior Landowners from Bulman, Weemol, Beswick,
Barunga and Katherine. In addition, Mimal’s ongoing
Mimal was administered by the Northern Land Council IPA development meant that there were far more
(NLC) for many years, however Traditional Owners opportunities to engage with Landowners and share expressed a desire to create their own company, stories about ranger work.
operated under local Indigenous management.
Mimal’s journey to independence is inherently linked Mimal had a busy year with fire suppression, to their involvement in the WALFA project, as it allowed responding to 20 wildfires using a helicopter, and a
Traditional Owners to use income generated through further five wildfires using only vehicles. Fires from the fire project to fund a separate incorporation and mid-October through to December were mostly autonomy. In October 2017, Mimal Land Management caused by lightning strikes. A helicopter and pilot were celebrated a new chapter as a group with control over based at the Mimal office during the late dry season, its own land, working toward a clear vision for Mimal which allowed rangers to respond very quickly to fires.
Above: Mimal rangers don backpack leaf blowers, ready people, country and culture. Although Mimal responded to more fires than usual to tackle a wildfire. Photo © Renae Saxby.
this year, the combination of responding early and Below: Mimal rangers use drip torches to conduct roadside
The weather conditions in the 2021 fire season were not light winds allowed rangers get them under control burning. Photo courtesy of Mimal Land Management.
as intense as in previous years, with increased moisture relatively quickly.

60 61
Yugul Mangi Rangers and Numbulwar Numburindi
Rangers (SEALFA)
– Strategic early burning
Above: Rangers and coordinators discuss helicopter safety in preparation for aerial burning.
Opposite left: Yugul Mangi ranger Jana Daniels uses a backpack leaf blower during an asset
protection burn at an outstation.
Photos courtesy of Northern Land Council.

The South East Arnhem Land (SEAL) IPA is jointly protect infrastructure from fire damage. On ground
managed by the Yugul Mangi and Numbulwar burning was undertaken on foot as well as from vehicles
Numburindi rangers who are based at Ngukurr and along roads by the rangers.
Numbulwar respectively and administered by the
Northern Land Council (NLC). The rangers work The 2020/2021 wet season was above average, which
on behalf of Traditional Owners of the Ritharrngu, meant that APB began a little later than in previous
Rembarrnga, Ngandi, Ngalakgan, Warndarrang, Yugul years, and pushed the end of burning into August. APB
and Nunggubuyu peoples whose country is situated in was used to create a mosaic of burnt country throughout
south-east Arnhem Land. the project area and to secure the boundaries of the
SEALFA and SEALFA2 project areas. Aerial prescribed
The SEAL IPA covers an area of 18,199 km2 on the burning was undertaken by both ranger groups over
western edge of the Gulf of Carpentaria in the Northern 16 days from April through to August, using an R44
Territory. With a history of strong local leadership (Robinson) helicopter and R2 Raindance Machine.
within both groups, the rangers have thrived, remaining Burning commenced along the western SEAL IPA
focused on the vision of their elders and founders. Fire boundary over the Urapunga Aboriginal Land Trust and
management is a major focus of the Yugul Mangi and then progressed towards the east into Arnhem Land.
Numbulwar Numburindi rangers’ work.
The rangers used a handheld GPS to record their tracks
Rangers implemented an extensive early dry season for the flight lines. Approximately 73 hours of flying
burning program from April to August. This included on time was used to undertake aerial prescribed burning,
ground burning by foot and roadside, track burning by covering over 9,518 kilometres of flying tracks.
vehicle and aerial prescribed burning. Twenty-three staff
were employed to undertake fire-related work activities There were numerous wildfires in the SEAL IPA in the late
in 2021. This included full time, part time and casual staff. dry season, however, due to operational restrictions,
the rangers did not undertake any firefighting in 2021.
A huge effort was put towards securing assets prior to Fires were monitored using the North Australia and
the commencement of aerial burning. Rangers ensured Rangelands Fire Information website.
firebreaks were installed and protective burning was
undertaken around 22 outstation communities to Students from Ngukurr and Numbulwar Schools
protect infrastructure. Back burning around these participated in early dry season burning activities with
outstations was undertaken prior to aerial burning to the rangers as part of the Learning on Country program.

62 63
Warddeken Rangers
–Protecting ancient ecosystems

“Anbinik is the tree from the very beginning.”
— Mary Naborlhborlh, Warddeken Professor (1932 – 2012)

Warddeken Land Management was formed in 2007 now survive only in gorges and relictual forests across to assist Nawarddeken Traditional Owners in the the kuwarddewardde (Arnhem plateau). Warddeken protection and management of their country in western rangers utilise customary fire management techniques
Arnhem Land. The Warddeken IPA was declared in to protect these culturally and ecologically important
2009 and covers approximately 14,000 km2, including trees and ecosystems.
seven outstation communities and a range of important habitats supporting numerous species of flora and Work involves the maintenance of firebreaks around fauna, many of which are rare and endemic to the entire stands of rainforest, and conducting cool
Arnhem Land escarpment region. burns in the late afternoon or evening. Warddeken’s
Anbinik Program has been running for a decade
Rangers work from bases at Mamadawerre, Manmoyi now – the only such program in Australia dedicated and Kabulwarnamyo homelands, offering the only to protecting these ancient, fire sensitive trees ongoing employment in these extremely remote and ecosystems.
communities. Warddeken consistently delivers an ambitious annual fire management program, generating Old people maintained these patches through positive ecological, social and cultural outcomes for careful and deliberate burning – a practice now
Landowners and their communities. This includes reinstated by rangers at fifteen of the most at-risk widespread asset protection burning for important rock Anbinik isolate forests. After ten years delivering art complexes, as well as for ancient, endemic Anbinik the Anbinik Protection Program, Warddeken are
(Allosyncarpia ternata) rainforests. seeing positive ecological outcomes in terms of forest
regeneration and canopy cover. Just as importantly,
Anbinik are important to Warddeken Landowners for the program has generated strong cultural learning their contemporary ecological status as well as their outcomes, with senior rangers, cultural leaders
Above: Warddeken rangers use leaf blowers to reinforce a mineral earth fire cultural significance. Old people actively managed and elders reporting that younger generations are break surrounding the entire Anbinik rainforest. Photo © Matthew Abbott.
Anbinik using fire, and valued the shade, amenity and becoming knowledgeable about Anbinik and how to Below: An aerial image shows the lengths to which Warddeken rangers have shelter they offered. Anbinik are fire sensitive and manage it using customary techniques. gone to protect entire stands of Anbinik rainforest. Photo © Matthew Abbott.

64 65
Yirralka Rangers
–Reconnecting with the country

Left: A smoky sunset in open savanna woodland
in the Yirralka IPA.
Right: A major component of Yirralka’s on ground
burning is installing breaks along the roads and bush
tracks that criss-cross their management area.
Yirralka rangers during on Photos courtesy of Yirralka.
ground early burning operations.
Photo courtesy of Yirralka.

The Yirralka rangers represent the Yolngu Traditional and stories, including talks about the joint development
Owners of north-east Arnhem Land, and were of a seasonal fire calendar. During the week, miyalk
established in 2003. Yirralka rangers manage the rangers participated in training focused on using and
land and sea in the Laynhapuy Indigenous Protected operating drip torches and leaf blowers, and completed
Area, which extends from Gove Peninsula to Blue collaborative burns around camp the river to put new
Mud Bay and covers over 11,000 km2 of land skills into practice.
and 480 kilometres of coastline. For residents of the
14 homeland communities within the Laynhapuy IPA, A highlight of this year’s burning program was facilitating
Yirralka rangers provide sustained opportunities for a trip for four rangers to Woodah Island in Blue Mud Bay
meaningful employment, and ranger positions are to conduct APB, inspect for feral animals, and take time
highly sought after. The Yirralka rangers currently to visit and reconnect with the country. Some of the
employ 50 permanent Yolngu staff who are based rangers had not visited the Island for many years, and
across all 14 homelands. this work provided a rare and meaningful experience for
all involved.
Over the previous year, Yirralka have continued to
focus on developing the capacity of rangers to deliver In the 2021 late dry season, rangers and students
across all elements of the fire management program. joined together for a Learning on Country excursion
Funding from the sale of ACCUs has allowed Yirralka to to Nyinyikay Homeland, to perform a work cultural
better resource the ranger program to implement the burning activity. This involved burning the cured grass
annual suite of fire management activities. New vehicles on a section of dry floodplain, before walking across the
in the fleet allow more rangers to travel out on country newly burned country to check holes for bush foods.
and access more areas to burn, improving the scope The activity involved 30 students, along with rangers,
of fine scale ground burning efforts throughout the local elders and school staff. Intergeneration transfer
Laynhapuy IPA. of knowledge is a primary goal of the Learning on
Country Program, and Yirralka Rangers is committed to
The miyalk (women) rangers took part in a women’s fire supporting this transfer by leading camps and activities
camp at Nimirrli (Blythe River Crossing) in July. Hosted through a formalised Learning on Country Memoranda
by the Mimal rangers, it was a great opportunity to get of Understanding with Laynhapuy Homelands School,
together and share and exchange valuable knowledge Gapuwiyak School and Baniyala Garraŋali School.

66 67
Financial Statements
For the Year Ended 30 June 2021

Statement of Profit or Loss and Statement of
Other Comprehensive Income Financial Position
2021 2020 2021 2020
$ $ $ $

Revenue 10,091,532 5,001,834 Assets
Other income 32,868 35,687 Current assets
Grant Funding (6,627,367) (463,563) Cash and cash equivalents 5,295,147 1,395,019
Subcontracting costs (1,436,649) (4,883,611) Trade and other receivables 1,399,615 207,831
Other expenses (321,603) (257,190) Total current assets 6,694,762 1,602,850
Employee benefits expense (298,383) (279,927) Non-current assets
Hire fees (42,658) (29,811) Plant and equipment 66,466 83,082
Depreciation and amortisation expense (16,616) (20,770) Total non-current assets 66,466 83,082
(Loss) before income tax 1,381,124 (897,351) Total assets 6,761,228 1,685,932
Income tax expense - -
(Loss) / profit from continuing operations 1,381,124 (897,351) Liabilities

Other comprehensive income, net of income tax - - Current liabilities

Total comprehensive (loss) for the year 1,381,124 (897,351) Trade and other payables 916,978 132,063
Employee benefits 39,874 29,769
Other liabilities 5,106,073 2,206,921
Total current liabilities 6,062,925 2,368,753
Total liabilities 6,062,925 2,368,753
Net (liabilities) / assets 698,303 (682,821)

Equity
Retained earnings / (accumulated losses) 698,303 (682,821)
Total equity 698,303 (682,821)

68 69
Directors’ Declaration financial reporting provisions of the Australian Charities
and Not-for-profits Commission Act 2012. As a result, the
be expected to influence the economic decisions of users
taken on the basis of this financial report.
financial report may not be suitable for another purpose.
Our audit opinion is not modified in respect of this matter. As part of an audit in accordance with the Australian
The directors of the registered entity have determined This declaration is made in accordance with subs 60.15(2) Auditing Standards, we exercise professional judgement that the Company is not a reporting entity and that these of the Australian Charities and Not-for-profits Commission Other Information and maintain professional scepticism throughout the special purpose financial statements should be prepared Regulation 2013. The directors are responsible for the other information. audit. We also: in accordance with the accounting policies described in The other information obtained at the date of this auditor’s — Identify and assess the risks of material misstatement
Note 2 of the financial statements. report is included in the Directors’ Report, but does not of the financial report, whether due to fraud or error,
include the financial report and our auditor’s report design and perform audit procedures responsive to
The directors of the registered entity declare that: Director ........................................................................................ thereon. those risks, and obtain audit evidence that is sufficient
and appropriate to provide a basis of opinion. The risk
1. The financial statements and notes, as set out on pages Our opinion on the financial report does not cover the other of not detecting a material misstatement resulting from
5 to 16, are in accordance with the Australian Charities information and accordingly we do not express any form of fraud is higher than for one resulting from error, as fraud
and Not-for-profits Commission Act 2012 and: Director ........................................................................................ assurance conclusion thereon. may involve collusion, forgery, intentional omissions,
(a) comply with Australian Accounting Standards; and misrepresentations, or the override of internal control.
(b) give a true and fair view of the financial position In connection with our audit of the financial report, our — Obtain an understanding of internal control relevant
as at 30 June 2021 and of the performance for the Dated this 21st day of October 2021 responsibility is to read the other information and, in doing to the audit in order to design audit procedures that
year ended on that date of is in accordance with so, consider whether the other information is materially are appropriate in the circumstances, but not for the
the accounting policies described in Note 2 to the inconsistent with the financial report or our knowledge purpose of expressing an opinion of the effectiveness of
financial statements. obtained in the audit or otherwise appears to be materially the Company’s internal control.
2. In the directors’ opinion, there are reasonable grounds misstated. — Evaluate the appropriateness of accounting policies
to believe that the Company will be able to pay its debts used and the reasonableness of accounting estimates
as and when they become due and payable. If, based on the work we have performed on the other and related disclosures made by the directors.
information obtained prior to the date of this auditor’s — Conclude on the appropriateness of the director’s use of
report, we conclude that there is a material misstatement the going concern basis of accounting and, based on the
of this other information, we are required to report that audit evidence obtained, whether a material uncertainty
fact. We have nothing to report in this regard. exists related to events or conditions that may cast
significant doubt on the Company’s ability to continue
Independent Audit Report to the Responsibilities of the Directors for the Financial Report as a going concern. If we conclude that a material members of ALFA (NT) Limited The directors of the registered entity are responsible
for the preparation and fair presentation of the financial
uncertainty exists, we are required to draw attention
in our auditor’s report to the related disclosures in the
report that gives a true and fair view and have determined financial report or, if such disclosures are inadequate, to
that the basis of preparation described in Note 1 to the modify our opinion. Our conclusions are based on the
Report on the Financial Report financial report is appropriate to meet the requirements of audit evidence obtained up to the date of our auditor’s
the Australian Charities and Not-for-profits Commission report. However, future events or conditions may cause
Opinion Act 2012 and is appropriate to meet the needs of the the Company to cease or continue as a going concern.
We have audited the accompanying financial report, being standards are further described in the Auditor’s members. The directors’ responsibility also includes such — Evaluate the overall presentation, structure and content a special purpose financial report of ALFA (NT) Limited (the Responsibilities for the Audit of the Financial Report section internal control as the directors determine is necessary to of the financial report, including the disclosures, and
“Company”), which comprises the statement of financial of our report. We are independent of the Company in enable the preparation of a financial report that gives a whether the financial report represents the underlying position as at 30 June 2021, the statement of profit or accordance with the auditor independence requirements of true and fair view and is free from material misstatement, transactions and events in a manner that achieves loss and other comprehensive income, statement of the Corporations Act 2001 and the ethical requirements of whether due to fraud or error. fair presentation.
changes in equity and statement of cash flows for the year the Accounting Professional and Ethical Standards Board’s then ended, notes comprising a summary of significant APES 110: Code of Ethics for Professional Accountants In preparing the financial report, the directors are We communicate with the directors regarding, among accounting policies and other explanatory information, (the Code) that are relevant to our audit of the financial responsible for assessing the Company’s entity’s ability other matters, the planned scope and timing of the audit and the directors’ declaration. report in Australia. We have also fulfilled our other ethical to continue as a going concern, disclosing, as applicable, and significant audit findings, including any significant
responsibilities in accordance with the Code. matters related to going concern and using the going deficiencies in internal control that we may identify during
In our opinion the financial report of ALFA (NT) Limited concern basis of accounting unless the directors either our audit.
has been prepared in accordance with Div 60 of the We confirm that the independence declaration required intend to liquidate the registered entity or to cease
Australian Charities and Not-for-profits Commission Act by the Australian Charities and Not-for-profits Commission operations, or have no realistic alternative but to do so.
2012, including: Act 2012, which has been given to the directors of the
(a) giving a true and fair view of the Company’s financial Company, would be in the same terms if given to the Auditor’s Responsibility for the Audit of the Financial Report
position as at 30 June 2021 and of its performance for directors at the same time of the auditor’s report. Our objectives are to obtain reasonable assurance about
the year ended on that date; and whether the financial report as a whole is free from
(b) complying with Australian Accounting Standards to We believe that the audit evidence we have obtained material misstatement, whether due to fraud or error,
the extent described in Note 1, and Div 60 of the is sufficient and appropriate to provide a basis for our and to issue an auditor’s report that includes our opinion. PERKS AUDIT PTY LTD PETER J HILL
Australian Charities and Not-for-profits Commission opinion. Reasonable assurance is a high level of assurance, but is 84 Smith Street Director
Regulations 2013. not a guarantee that an audit conducted in accordance Darwin, NT 0800 Registered Company
Emphasis of Matter – Basis of Accounting with Australian Accounting Standards will always detect Auditor
Basis for Opinion We draw attention to Note 1 to the financial report, which a material misstatement when it exists. Misstatements
We conducted our audit in accordance with Australian describes the basis of accounting. The financial report is can arise from fraud or error and are considered material
Auditing Standards. Our responsibilities under those prepared to assist ALFA (NT) Limited to comply with the if, individually or in the aggregate, they could reasonably Dated this 21st day of October 2021

70 71
Vernon Garnarradj and his young
daughter Veneesha on a Warddeken
bushwalk. This walk allowed Veneesha
to visit her country for the first time, and
was an opportunity for rangers and their
families to connect with country and
conduct fine scale burning across clan
estates in the north of the Warddeken
IPA. Photo © Matthew Abbott.

72 73
“We use fire for many reasons: not only for conservation and management, but also as a healing
process for land, for people, for native plants and
animals. Fire is a tool that we have used from the
beginning, from the deep past until today.”
– Dean Yibarbuk, Traditional Owner

74

CSIRO PUBLISHING

International Journal of Wildland Fire 2020, 29, 371–385 https://doi.org/10.1071/WF18152

Contemporary Aboriginal savanna burning projects in
Arnhem Land: a regional description and analysis of the
fire management aspirations of Traditional Owners

Jennifer Ansell A,K, Jay Evans B, Adjumarllarl RangersC, Arafura Swamp RangersD,
Djelk RangersE, Jawoyn RangersF, Mimal RangersG, Numbulwar Numburindi
RangersH, Warddeken RangersI, Yirralka RangersJ and Yugul Mangi RangersH
A
ALFA (NT) Limited, North Australia Research Unit, 23 Ellengowan Drive, Brinkin, NT 0810,
Australia.
B
Darwin Centre for Bushfire Research, Research Institute for Environment and Livelihoods,
Charles Darwin University, Darwin, NT 0810, Australia.
C
Demed Aboriginal Corporation, PMB 89, Oenpelli, NT 0822, Australia.
D
Arafura Swamp Rangers Aboriginal Corporation, 8 Warrk Road, Ramingining, NT 0822,
Australia.
E
Bawinanga Aboriginal Corporation, PMB 102, Winnellie, NT 0822, Australia.
F
Jawoyn Association Aboriginal Corporation, 89 Victoria Highway, Katherine, NT 0850,
Australia.
G
Mimal Land Management Aboriginal Corporation, Lot 31, Weemol Community, NT 0852,
Australia.
H
Northern Land Council, 45 Mitchell Street, Darwin, NT 0801, Australia.
I
Warddeken Land Management Limited, PO Box 785, Nightcliff, NT 0814, Australia.
J
Laynhapuy Homelands Aboriginal Corporation, 86 Galpu Road, Yirrkala, NT 0881, Australia.
K
Corresponding author. Email: ceo@alfant.com.au

Abstract. The growth of the carbon industry in Australia over the last decade has seen an increase in the number of
eligible offsets projects utilising the savanna burning methods in northern Australia. Many of these projects are operated
by Aboriginal people on Aboriginal lands utilising local Aboriginal knowledge and customary burning practice. The
present paper reviews existing land management planning documents to describe the aspirations of Traditional Owners in
relation to fire management at a regional scale in Arnhem Land. Available data collected in the course of savanna burning
operations are then utilised to examine the extent to which the savanna burning projects are meeting these goals. There
were six clear goals in relation to fire management within the planning documents across Arnhem Land. Traditional
Owners want to: (1) continue the healthy fire management of their country; (2) see fewer wildfires; (3) protect biodiversity;
(4) protect culturally important sites; (5) maintain and transfer knowledge; and (6) create a carbon abatement. The results
from this paper suggest that although the savanna burning projects are annually variable, these goals are being met.
Importantly, the present paper clearly communicates a description of contemporary fire management from the perspective
of Traditional Owners at a broad regional scale.

Additional keywords: Aboriginal fire management, carbon abatement, eligible offsets project.

Received 11 September 2018, accepted 25 September 2019, published online 26 November 2019

Introduction Kerins 2012). Aboriginal people living on remote Aboriginal
Arnhem Land, in the remote tropical north of Australia, has a Land, while maintaining strong cultural identity and the con- history of Aboriginal use and management stretching back more tinuation of customary practices, face significant economic than 50 000 years (Clarkson et al. 2017). Over the last few development problems as well as a complex range of natural and decades this stewardship has evolved to include community- cultural resource management issues (Altman et al. 2007).
based Aboriginal land and sea ranger programs (Altman and Incomes are very low, and the majority of the population in

Journal compilation Ó IAWF 2020 Open Access CC BY-NC-ND www.publish.csiro.au/journals/ijwf
372 Int. J. Wildland Fire J. Ansell et al.

Arnhem Land remains overly dependent on welfare and early in the dry season and at times of heavy dew and little wind, detached from the labour market (Markham and Biddle 2018). so that fires go out overnight; to burn strategically, adding to
As in many other parts of northern Australia, formalised natural breaks such as moist ground along creeks, cliff lines and
Aboriginal ranger groups operate in Arnhem Land to provide a tracks to create a mosaic of burnt and unburnt areas; to protect coordinated and regional approach to tackle natural and cultural jungles, heaths and sacred places using early-burned breaks; resource management challenges while empowering and and, importantly from a cultural perspective, to engage ‘the right employing local people (Altman and Kerins 2012; Austin et al. people for country’ in planning and delivery (Yibarbuk et al.
2018). These ranger programs integrate the interests of Tradi- 2001; Whitehead et al. 2009).
tional Owners, and incorporate Aboriginal knowledge and cul- With the advent of the Commonwealth Government’s Car- tural practices as well as western science and technology bon Credits (Carbon Farming Initiative) Act 2011 (CFI Act) and
(Warddeken Land Management Limited 2016). Key natural and subsequent Emissions Reduction Fund (ERF) legislation, the cultural resource management challenges for these ranger pro- WALFA project became the landscape-scale model upon which grams include the loss of people from country, the loss of the approved savanna burning method was based. An approved knowledge about country, the invasion and spread of feral ani- method under the CFI Act explains how to carry out a registered mals and weed species and the loss of fire management (e.g. offsets project and measure the resulting reductions in emissions
Warddeken Land Management Limited 2016; Mimal Land through the management of fire (Commonwealth of Australia
Management Aboriginal Corporation 2017). 2017). Throughout the present paper when we refer to the
Fire is, and has always been, the most important tool that savanna burning method we refer to the Carbon Credits
Aboriginal people in Arnhem Land have utilised for managing (Carbon Farming Initiative – Emissions Abatement through their country (Yibarbuk et al. 2001). Prior to European settle- Savanna Fire Management) Methodology Determination 2015, ment, the people of Arnhem Land would burn as they traversed which enables registered fire projects to earn Australian Carbon their country; they would also use fire for ritual purposes Credit Units (ACCUs; Commonwealth of Australia 2017).
(Altman 2009; Garde et al. 2009). Garde et al. (2009) vividly Today, there are now over 70 registered savanna burning described in Bininj Kunwok, a language from that region, the projects in northern Australia (Commonwealth of Australia traditional burning practices from the Arnhem Plateau, includ- 2018a). These registered savanna burning projects cover a broad ing the landscape, weather and seasonal interaction that people range of land tenures, and all utilise the methods developed in had with plants, animals and fire. Following European coloni- western Arnhem Land to produce carbon credits (Maraseni et al.
sation and the displacement of Aboriginal people from their clan 2016; Commonwealth of Australia 2017). Currently accounting estates in Arnhem Land (Cooke 2009), Aboriginal fire manage- for 10% of Australian carbon credit issuance, the savanna ment began to break down; subsequently, fire regimes became burning projects constitute a sizeable reduction in Australia’s dominated by extensive wildfires occurring mostly during the carbon emissions (Commonwealth of Australia 2018a).
severe fire weather conditions of the late dry season (August to The savanna burning projects also deliver a suite of eco-
December), covering many thousands of square kilometres nomic, social, cultural and environmental benefits (Social
(Cooke 2009). Ventures Australia Consulting 2016). These co-benefits are
In the late 1990s, Aboriginal Traditional Owners from arguably the reason why Aboriginal people are engaging with western and central Arnhem Land and non-Aboriginal scientists the carbon industry and also why the carbon credits they produce began talking about fire in the landscape. These discussions led are highly valued by the carbon market (Jackson and Palmer to the development of a vision of people living on healthy 2015; Barber and Jackson 2017). Still evolving are discussions country, and ultimately to the innovative program of fire and methods focused on how to measure, value and account for management now known as the Western Arnhem Land Fire the co-benefits associated with the production of carbon credits
Abatement (WALFA) project (Russell-Smith et al. 2009). The (Jackson and Palmer 2015; Sangha et al. 2017; Austin et al.
WALFA project commenced formal operation in 2006 and 2018; McMurray et al. 2018). Often overlooked in these was a partnership between the five Aboriginal ranger groups discussions is an examination of the savanna burning projects with responsibility for that part of Western Arnhem Land, the from the viewpoint of Traditional Owners. The aim of the
Northern Territory Government, the Northern Land Council, present study is to address whether the savanna burning projects
Northern Territory-based research scientists and ConocoPhillips in Arnhem Land are meeting the fire management goals of
(a global oil and natural gas company). The goal was to reinstate Traditional Owners, the landowners and managers of the fire
Aboriginal-led fire management regimes over the remote project areas.1 To this end, we present the results in two parts.
Arnhem Plateau, in part to offset greenhouse gas emissions First, describing the fire management goals of Traditional from ConocoPhillips Liquefied Natural Gas plant in Darwin Owners and second, examining the savanna burning project
Harbour (Whitehead et al. 2009). outcomes against the described fire management goals.
The five Aboriginal ranger groups involved in the WALFA In the present study, we review and summarise existing project developed ways of emulating customary Aboriginal fire planning documents from Aboriginal ranger groups across management using modern tools. The key elements of custom- Arnhem Land to describe the goals of Traditional Owners in ary fire management incorporated into the project were: to burn relation to fire management. These plans are the written

1
Throughout this paper, we use the term Traditional Owner, to refer to both Traditional Aboriginal Owners, Aboriginal people who have inherited country from their father’s side (as defined in the Aboriginal Land Rights Act (Northern Territory) 1976), as well as Aboriginal people who have inherited management responsibilities for country on their mother’s side, called Djungkay in much of Arnhem Land.
Aboriginal savanna burning in Arnhem Land Int. J. Wildland Fire 373

ALFA NT
FIRE PROJECTS
CALFA
WALFA
NEALFA
SEALFA
N SEALFA Stage 2

Fig. 1. Location of the Arnhem Land Fire Abatement Northern Territory (ALFA (NT)) fire projects in Arnhem Land. CALFA, Central Arnhem Land Fire
Abatement; WALFA, Western Arnhem Land Fire Abatement; NEALFA, North East Arnhem Land Fire Abatement; SEALFA, South East Arnhem Land Fire
Abatement. documentation of extensive consultation and planning with (Arnhem Land Fire Abatement Northern Territory) Limited as senior Traditional Owners, and represent their collective goals eligible offsets projects under the CFI Act 2011. ALFA (NT) for looking after country. We then compile the strategies and Limited is an Aboriginal-owned, not-for-profit company ini- indicators that have been chosen by Traditional Owners as tially created by the Aboriginal ranger groups operating the appropriate actions and measures to monitor whether they are WALFA project. Since then, the company has expanded to meeting their fire management goals. Using each strategy, we support other fire projects throughout Arnhem Land (Fig. 1).
describe and assess the outcomes from the operation of savanna These five projects are all located on inalienable freehold burning projects in Arnhem Land using the indicators described Aboriginal Land vested by the Aboriginal Land Rights Act above (i.e. the indicators that have been chosen by Traditional (Northern Territory) 1976, primarily the Arnhem Land
Owners to monitor the effectiveness of current strategies in Aboriginal Land Trust, in the Northern Territory, Australia. The achieving their fire management goals). The available data used five fire projects encompass a range of operational experience, as indicators in this paper include: information on fire manage- span a mix of fire project start dates and have different baseline ment activities (e.g. prescribed burning, employment, training); periods (Table 1).
the pre- and post-fire management history of the project areas The five ALFA fire projects are located within the savannas based on available satellite fire mapping; and information from of northern Australia that receive more than 600 mm long-term the ERF project register of eligible offsets projects earning average annual rainfall. The general climate of the region is
ACCUs. In the Discussion, we consider the extent to which characterised by marked rainfall seasonality, with over 90% of the fire projects in Arnhem Land are meeting the fire manage- rainfall occurring between the months of November and April ment goals of Traditional Owners. and daily maximum temperatures of over 308C for much of the
year (Bureau of Meteorology 2018). Culturally, this is a diverse
Methods
region of Australia, with over 30 distinct Aboriginal languages
Regional context spoken (Capell 1942). The last census estimated the population
In the present study, we focus on five savanna burning project in this broader region (encompassing the East Arnhem, West areas in Arnhem Land that are registered by ALFA (NT) Arnhem and Roper Gulf Local Government areas) to be around
374 Int. J. Wildland Fire J. Ansell et al.

Table 1. The five fire projects in Arnhem Land registered as eligible offsets projects under the Carbon Farming Initiative Act 2011
WALFA, Western Arnhem Land Fire Abatement; CALFA, Central Arnhem Land Fire Abatement; SEALFA, South East Arnhem Land Fire Abatement;
SEALFA 2, South East Arnhem Land Fire Abatement Stage 2; NEALFA, North East Arnhem Land Fire Abatement

Project Area (km2) Ranger groups Baseline Start year
(retrospective/registered)

WALFA 28 000 Djelk, Mimal, Jawoyn, Warddeken, Adjumarllarl 1995–2004 2011/2015
CALFA 26 000 Djelk, Mimal, ASRAC 1996–2005 2011/2015
SEALFA 5000 Yugul Mangi, Numbulwar Numburindi 2000–09 2011/2016
SEALFA 2 10 000 Yugul Mangi, Numbulwar Numburindi 2000–14 2015/2015
NEALFA 11 000 Yirralka 2006–15 2016/2016

18 000 Aboriginal people (Commonwealth of Australia 2016). The fire management goals were collated from all the
The majority of people resides in the main townships such as planning documents and summarised into broad categories.
Maningrida, Gunbalanya, Ramningining, Bulman, Yirrkala, We then summarised all of the strategies and indicators docu-
Katherine, Ngukurr and Numbulwar, with a smaller number of mented within the planning documents in relation to meeting the people resident on outstations (smaller family-based communi- fire management goals. We use descriptive statistics in Micro- ties with between 10 and 50 residents). soft Excel to examine the frequency of goals and strategies
Nine Aboriginal ranger groups, consisting of Traditional Own- within the different planning documents. Where a strategy ers and their families, operate the five fire projects (see Table 1). and/or indicator was described that was not regional (i.e. related
Collectively, these groups manage an area of over 80 000 km2, specifically to the circumstances of a single ranger group), this encompassing rugged sandstone escarpments, monsoon rainforest, was omitted from the regional analysis.
pristine riparian ecosystems, floodplains, remote coastal regions and vast expanses of savanna. The fire project areas include Savanna burning project outcomes four declared Indigenous Protected Areas (IPAs) – the Djelk, Aboriginal ranger groups in Arnhem Land annually undertake
Warddeken, South East Arnhem Land and Laynhapuy IPAs. a coordinated program of strategic fire management. This
includes early dry-season burning and late dry-season fire-
Summary of fire management goals, strategies and indicators fighting to reduce the extent and severity of destructive, late dry-
Of the nine Aboriginal ranger groups operating the fire projects season wildfires, and reduce the fire-generated emissions of in Arnhem Land, eight groups are covered by seven detailed greenhouse gas. These ranger groups manage and implement all operational plans of management: Arafura Swamp Rangers operational aspects, including fire planning, consultations, early
Aboriginal Corporation 2017; Bawinanga Aboriginal Corpora- dry-season burning, late dry-season firefighting, data recording tion 2015; Gambold 2015; Jawoyn Association Aboriginal and fire monitoring.
Corporation 2018; Laynhapuy Homelands Aboriginal Corpo- Annually, each ranger group records data on its fire manage- ration 2017; Mimal Land Management Aboriginal Corporation ment activities. The recorded data include a written record of
2017; and Warddeken Land Management Limited 2016. The planning and consultations with Traditional Owners, as well as
Yugul Mangi and Numbulwar Numburindi Rangers both oper- information on aerial- and ground-prescribed burning opera- ate under the South East Arnhem Land (SEAL) IPA Plan of tions and firefighting. From these datasets we have compiled the
Management (Gambold 2015). Within the last decade, many location, date, kilometres travelled, a description of who was
Aboriginal ranger groups in Australia have utilised the Healthy undertaking the burning (Aboriginal ranger and/or Traditional
Country Planning (HCP) framework for developing their oper- Owner) and the total number of people employed in the fire ational plans. Indeed, five of the seven management plans in management activity. At the end of the year, each ranger group
Arnhem Land have been undertaken using the HCP framework. also presents a descriptive summary report outlining fire-
HCP is an adaptation of the Conservation Action Planning management-related works that occurred within their area of
(CAP) method based upon the Open Standards for the Practice operations, including cultural, training and education events.
of Conservation (Conservation Measures Partnership 2018). A We use descriptive statistics in Microsoft Excel to summarise particular focus of HCP is the engagement of Traditional the planning and fire management data and assess the effective-
Owners to focus the work of the ranger programs throughout the ness of current activities in achieving the desired outcome.
planning, project implementation and monitoring process Where remotely sensed fire regime metrics were identified as
(Moorcroft et al. 2012). The planning documents define the relevant indicators, these were assessed utilising a pre-existing vision for land management – the guide for the plan and the work annual burned area archive (Jacklyn 2018) derived from Moder- to be achieved; the assets – the things on country that need ate Resolution Imaging Spectroradiometer imagery (250 250-m looking after in order to achieve the vision; the threats – the pixels) and encompassing the baseline and operational periods things that are making the assets unhealthy; the goals and (see Table 1) for each of the five projects. Layers for each metric strategies for looking after the assets and minimising the threats; were derived in raster format using the ArcMap software package and the indicators – the parameters to measure to tell whether the (Environmental Systems Research Institute 2016). Comparison work is meeting the goals. of the different project period means (those with n $ 3) was done
Aboriginal savanna burning in Arnhem Land Int. J. Wildland Fire 375 using the R software package (R Core Team 2019), and Table 2. Compilation and summary of fire management goals across figures were produced using Microsoft Excel. We analysed the the ranger group planning documents in Arnhem Land project period means with respect to two operational periods that differentiate between the period in which groups were undertak- Fire management goal Number of planning ing fire management in the period prior to the introduction of the documents (n ¼ 7)
CFI Act (retrospective) versus operating an eligible offsets Continue healthy fire management 6 project and funding fire management from the sale of carbon Fewer wildfires in the project area 2 credits (registered), i.e. (1) the baseline and the retrospective Protect biodiversity 4 operational period, and (2) the baseline and the registered Protect important sites 1 operational period. In this case, each pair of variables was tested Maintain and transfer knowledge 2 for differences using the Wilcoxon Rank Sum test. Produce a carbon abatement 3
For each savanna burning project the annual emissions in tonnes of CO2-e was also calculated using the online Savanna
Burning Abatement Tool (Commonwealth of Australia 2019).
projects in Arnhem Land using the indicators chosen by Tra-
Trends in annual emissions were assessed over the same periods
ditional Owners as measures (Table 3). Where these indicators as described in the previous paragraph.
include remotely sensed fire metrics, we compare results
The Clean Energy Regulator publishes and maintains the
between the baseline (pre-fire management) and during the fire details of projects registered under the Emissions Reduction
operational project periods (see Table 1).
Fund. To describe ACCU production from the savanna burning projects in Arnhem Land we downloaded the Emissions Reduc-
(a) Burning is directed by Traditional Owners tion Fund project register, which records the number of ACCUs issued (Commonwealth of Australia 2018a). One ACCU is The first step in the annual fire management program is earned for each tonne of carbon dioxide equivalent stored or planning and consultation. Annually, each ranger program avoided by a project (Commonwealth of Australia 2017). meets with Traditional Owners from the different clan groups
within their operational area. This is an opportunity for Land-
owners and Djungkay to communicate how they would like to be
Results
involved in fire management and/or how they would like the
Summary of fire management goals, strategies and indicators rangers to care for their clan estates. Traditional Owners for each
In Arnhem Land, fire is seen both as an asset to protect and utilise project area number in the thousands and, as a result, the ranger within the landscape, and as a threat to manage. All seven plan- groups consult and plan with people who have the appropriate ning documents list fire as a key asset that Traditional Owners authority to approve, direct and be involved in the burning of consider necessary for the health of their country. Conversely, country on their clan estates. In 2017, the average number of uncontrolled wildfires are listed as a threat in all seven of the Traditional Owners consulted ranged between 72 and 88 per planning documents. In the five Healthy Country Plans, the threat ranger program (ALFA (NT) Limited 2017, unpubl. data).
of wildfire pertains to an average of over 75% of the other assets Consultation and planning includes an evaluation of past fire in the plan (range 45–100%). These include assets such as sacred histories using fire scar maps and the establishment of an sites, rock art, food and medicinal plants, animals and Anbinik operational plan for the upcoming burning season. This infor-
(Allosyncarpia) forests, as well as the maintenance of healthy fire mation is mapped and then forms the basis for prescribed regimes (Warddeken Land Management Limited 2016; Arafura burning routes (Fig. 2).
Swamp Rangers Aboriginal Corporation 2017; Mimal Land
Management Aboriginal Corporation 2017). (b) Traditional Owners involved in delivery of fire
Although Traditional Owners are undertaking fire manage- management ment to satisfy several motivations, the compilation of fire Across Arnhem Land, Traditional Owners are involved in the management goals from the seven planning documents clearly delivery of fire management, both on-ground and aerial burning.
demonstrates consistent themes. Indeed, six of the seven plans During the planning process described previously, Traditional had the goal to continue healthy fire management and four of the Owners can nominate who will burn their clan estates. This might plans to include protection of biodiversity (Table 2). include themselves, a family member or an Aboriginal ranger
As with the fire management goals described previously, (who are Traditional Owners themselves). In 2017, the WALFA there were synergies across Arnhem Land in relation to fire and Central Arnhem Land Fire Abatement (CALFA) projects management strategies and indicators, and their relationship to recorded the formal engagement of 178 Traditional Owners (not the broader fire management goals. The planning documents including those formally employed as rangers through the ranger clearly illustrate that each fire management strategy relates to program) in the delivery of fire management. The average several fire management goals (Table 3). The single strategy number of Traditional Owners engaged to undertake burning that was consistent across all seven plans was that ‘Burning is by each ranger group in the WALFA and CALFA project areas directed by Traditional Owners’. was 29.7 6.8 (range 9–54). Typically, in regards to aerial-
prescribed burning, a Traditional Owner will navigate at the front
Savanna burning project outcomes of the helicopter, while an Aboriginal ranger, trained as an
Using each strategy in Table 3 as a sub-heading, we describe and incendiary machine operator, will manage the delivery of incen- assess the outcomes from the operation of savanna burning diaries (see Ansell and Koenig 2011 for further description).
376 Int. J. Wildland Fire J. Ansell et al.

Table 3. A summary of the strategies and indicators described within the planning documents to meet fire management goals and assess the
effectiveness of current activities in achieving the desired outcome
The frequency value presented is the number of planning documents listing that strategy in regards to undertaking fire management. ALFA, Arnhem Land Fire
Abatement; CHFM, continue healthy fire management; MTK, maintain and transfer knowledge; FW, fewer wildfires; PB, protect biodiversity; PIS, protect
important sites; CA, carbon abatement; EDS, early dry season; LDS, late dry season; ACCU, Australian Carbon Credit Unit

Strategy Fire Management Goal Frequency Indicator
(n ¼ 7)

1. Burning is directed by Traditional Owners CHFM, MTK 7 Fire plans overseen and managed by the right people
2. Burning is delivered by Traditional Owners CHFM, MTK 4 Number of Traditional Owners involved in burning
3. Continue strategic early dry season burning CHFM, FW, PB 4 Reduce extent of fires through fire management
Change the seasonality of fires through fire management
(EDS v. LDS firescars)
Good patchiness of fire
4. Increase ground burning CHFM, PB, PIS 2 Kilometres of on-ground burning increases throughout
project period
5. Continue late dry season fire suppression CHFM, FW, PB, PIS, CA 3 Area of LDS wildfire decreases with project operation
Late fire frequency declines with continued project
operation
Number of successful wildfire suppression responses
6. On-country site protection, fire education and CHFM, PIS, MTK 3 Number of recorded on-country events
training events
7. Employment and Training CHFM, MTK 3 Number of Aboriginal people employed and trained
8. Strengthen participation in ALFA CHFM, CA 2 Completion of ALFA project milestones
9. Operate successful carbon abatement project CHFM, FW, PB, MTK, CA 2 Generation of ACCUs
ACCU sales covers fire management costs

vegetation or cultural sites. Given the remote nature and vast
fire project areas, many thousands of kilometres of aerial and
ground burning are undertaken annually (Fig. 3, Table 4). The
effort, in terms of kilometres travelled, is seasonally dependant
and varies from year to year, enabling fire managers to respond
to seasonal fire conditions (Table 4). For example, helicopters
can fly at low speed and low height, allowing the Raindance
machine operator to choose the delivery of capsules to suit
weather conditions, vegetation types and fuel loads in order to
vary the intensity of the resultant on-ground fire (Fig. 4).
Through fire management activities, the total area burnt has
generally declined across the five projects, albeit non-
significantly. However, these trends are defined by mostly
significant (1) increases in area burnt during the early dry season
(EDS), and (2) decreases in area burnt during the late dry season
Fig. 2. Arafura Swamp Rangers map flight lines at the pre-season fire (LDS) (Fig. 5b, c). In all projects, the average EDS area in the meeting. baseline period was under 10% of the total project area and rises
to an average of 11–32% during active fire management
(Fig. 5b). Similarly, there is a marked change in burnt area size
(c) Continue strategic early dry season burning class distributions on commencement of active fire management
The fire projects in Arnhem Land predominantly use in the project areas. For all project areas, relative to baseline aerial-prescribed burning (incendiary pellets dropped from years smaller fires have become more numerous (Fig. 5d) and helicopters) during the early dry season to reduce fuel loads longer unburnt areas appear to be increasing (Fig. 5e).
and establish a network of strategic burnt fire breaks across the landscape. This prevents the intrusion of fires from neighbour- (d) Increase ground burning ing lands and contains other fires within the project area. Given The kilometres of ground burning using vehicles undertaken the large operational areas, these strategic breaks may be within each project area varies from year to year and between the hundreds of kilometres long. Aerial burns are complemented project areas (Table 4). The total ground burning kilometres by finer-scale ground burning from motor vehicles (4WD or accounts for ,31% of all prescribed burning kilometres quad bike), or by walkers using matches and drip torches to (Table 4). Over the period 2015–17, WALFA and CALFA create more effective barriers, particularly around sensitive projects demonstrate a range of ground burning effort between
Aboriginal savanna burning in Arnhem Land Int. J. Wildland Fire 377

250 000 300 000 350 000 400 000 450 000 500 000 550 000 600 000 650 000 700 000
8 700 000

ALFA (NT) Ltd
2017 Project Activities
8 650 000
8 600 000
8 550 000
8 500 000

LEGEND
2017 flightlines
Project areas
2017 Burnt areas
Season
8 450 000

Early
Late
8 400 000

Fig. 3. Aerial-prescribed burning records for the fire projects in Arnhem Land in 2017. ALFA (NT), Arnhem Land Fire Abatement Northern Territory.

Table 4. The lineal kilometres of aerial- and ground-prescribed burning coordinated by Aboriginal rangers in Arnhem Land

Year Number of registered projects Ground burning (km) Aerial burning (km) Total distance travelled (km)

2015 4 16 148 34 530 50 678
2016 5 26 693 52 158 78 851
2017 5 21 074 55 833 76 907

1947% of total burning kilometres. Since it began in 2016, over extinguish fires. Where access is possible, rangers can use
60% of all recorded burning kilometres in the North East ground-based vehicles to create fire breaks or fight fires. Where
Arnhem Land Fire Abatement (NEALFA) project are from ground access is not possible, small teams of rangers are flown ground burning. Conversely, the two South East Arnhem Land by helicopter and work their way around the active edge of the
Fire Abatement (SEALFA) projects have very low recorded wildfire with the leaf blowers. These firefighting tactics rely on percentage of ground burning kilometres (,2%). using existing landscape features and fire scars to support
wildfire suppression.
(e) Undertake late dry season fire suppression Within 2017 alone, the WALFA and CALFA projects
Primarily undertaken within the WALFA and CALFA pro- recorded wildfire suppression responses to 34 individual wild- jects, wildfire suppression is becoming an increasingly applied fires in the four-month period from 1st August – 31st November fire management strategy. Over the last decade, rangers in 2017. These comprised suppression of early dry season pre-
Arnhem Land have adopted and refined a variety of firefighting scribed burns (8%); human induced roadside or hunting fires tactics to suit the rugged and remote landscape. Back pack leaf (67%) and lightening induced fire (23%). As a result of the blowers are deployed to create fire breaks and directly combination of strategic early dry season burning and the late
378 Int. J. Wildland Fire J. Ansell et al.

Limited 2016; Mimal Land Management Aboriginal Corpora-
tion 2017).

(h) Strengthen participation in ALFA
Since the development of ALFA by the five Aboriginal
ranger groups operating the WALFA project, the company has
grown to register an additional four fire projects and support an
additional four Aboriginal ranger groups in their engagement
with the carbon market.
Annually, ALFA contracts and funds the ranger groups to
undertake and report on operational activities associated with
the fire projects. All of the engaged ranger groups also attend the
pre, and post fire season meetings, attend producer group
meetings and support logistics for the ALFA Board meetings.

Fig. 4. A Yugul Mangi ranger operates the aerial incendiary ‘Raindance’ (i) Operate successful carbon abatement project machine. Every ALFA fire project has significantly reduced its emis-
sions after ERF registration (Fig. 5f). However, the annual
issuance of ACCUs demonstrates annual variation (Fig. 7). Prior
to 2015, the fire projects demonstrated a biennial cycle of higher dry season wildfire suppression, the frequency of late dry season and lower abatement years. However, since 2015 the fire fires has reduced considerably across Arnhem Land (Fig. 6). The projects have achieved more consistency as well as an increase ten-year late fire frequency map from 2017 demonstrates an in the abatement of greenhouse gases. Of all the savanna burning observed reduction in the area of red and yellow (areas with a projects listed on the ERF register, the five ALFA projects high frequency of late fire) and an increase in the white and currently account for over 50% of the ACCU issuance under the green areas (areas with no or little late fire in the ten-year period) method. The WALFA project currently accounts for the highest compared with the previous ten-year period (Fig. 6). number of ACCUs issued to a single project across all eligible
offsets projects across all methodologies (Commonwealth of
(f) On country site protection, fire education and training Australia 2018a). Whilst actual carbon credit sales prices are events confidential, using the current average ERF Auction price as a
conservative value ($11.97 as at June 2018, (Commonwealth of
Annually, the ranger groups in Arnhem Land facilitate Australia 2018a), sales of ALFA’s 2 668 848 ACCUs to date several other formalised fire management activities including equates to well over AUD $31 million.
bushwalks, culture camps and the protection of culturally important sites (e.g. rock art, sacred sites and Anbinik forests).
In 2017, seven ranger groups within the fire project areas Discussion recorded 70 individual other activities related to fire, including Across 80 000 km2 in Arnhem Land, Aboriginal people are integration with Learning on Country, the junior ranger program currently undertaking sophisticated fire management utilising partnering with local schools (Table 5). customary fire knowledge. Fire management operations at this
landscape scale is resource intensive and beyond the scope of
(g) Employment and training ‘business as usual’ for Aboriginal ranger groups and Traditional
The five registered ALFA fire projects in Arnhem Land are Owners. It is important to acknowledge that many of the solely implemented by Aboriginal ranger groups. In 2017, the Aboriginal ranger programs in Arnhem Land are supported five registered fire projects recorded the employment of 316 financially by the Australian Government through funding
Aboriginal people to undertake the actual burning and fire- programs like Indigenous Protected Area (IPA) and Indigenous fighting work. Advancement Strategy (IAS) as well as other sources of income,
The employment outcomes are considerably higher, when including philanthropy. However, in Arnhem Land it is the engagement in other fire activities are also taken into account revenue derived from the sale of ACCUs that funds the savanna such as fire planning and consultation. The WALFA project burning projects and enables its delivery in a way that is cul- records employment and hours of engagement for the five main turally responsive over such a vast scale. Clearly demonstrated fire management works (see Table 6). Within the WALFA project, in Fig. 5, the adoption of the savanna burning method has been preseason consultation and planning as well as roadside burning the direct cause of the recent positive changes in fire manage- and asset protection burning account for the highest number of ment regimes in Arnhem Land. Although the WALFA project staff employed as well as hours of employment (Table 6). (with funded fire operations since 2006) demonstrates clear
Even further employment is achieved with many groups improvements during its retrospective fire operation period, fire investing carbon credit revenue into non-fire related land man- regime metrics demonstrate further improvements with the agement employment (for examples see Jawoyn Association additional funding provided through the generation and sale of
Aboriginal Corporation 2018; Warddeken Land Management ACCUs since 2015 (Fig. 5).
Aboriginal savanna burning in Arnhem Land Int. J. Wildland Fire 379

(a) 100 (b) 100
Baseline
90 90

Percent project area burnt early
Retrospective operation
80 80
Percent project area burnt
Registered operation
70 70

60 60

50 50

40 40

30 30

20 20

10 10

0 0
WALFA CALFA NEALFA SEALFA SEALFA2 WALFA CALFA NEALFA SEALFA SEALFA2

(c) 100 (d) 7
90

Percent of burnt area <100 ha fires
6
Percent project area burnt late

80

70 5

60
4
50
3
40

30 2
20
1
10

0 0
WALFA CALFA NEALFA SEALFA SEALFA2 WALFA CALFA NEALFA SEALFA SEALFA2

(e) 100 (f ) 600
90
Resultant emissions (K tCO2-e)
Percent project unburnt >3 yrs

500
80

70
400
60

50 300

40
200
30

20
100
10

0 0
WALFA CALFA NEALFA SEALFA SEALFA2 WALFA CALFA NEALFA SEALFA SEALFA2

Fig. 5. Summary averages for the Arnhem Land Fire Abatement (ALFA) fire projects baseline and project operation years.
Baseline ¼ period before project operation, retrospective operation ¼ period of fire management before project registration,
registered operation ¼ years of operation as registered eligible offsets project. (a) Percentage project area burnt, (b) percentage
project area burnt by early dry season fires, (c) percentage project area burnt by late dry season fires, (d) percentage of total area
burnt that is made up of patches ,100 ha in size, (e) percentage project area remaining unburnt for three or more years, and
( f ) resultant emissions. Error bars are standard error of the mean; *indicates significant (t-test: P , 0.05) change from baseline
period. WALFA, Western Arnhem Land Fire Abatement; CALFA, Central Arnhem Land Fire Abatement; NEALFA, North East
Arnhem Land Fire Abatement; SEALFA, South East Arnhem Land Fire Abatement; SEALFA2, South East Arnhem Land Fire
Abatement Stage 2.
380 Int. J. Wildland Fire J. Ansell et al.

The results in this paper demonstrate that fire management frequent goal described in the planning documents was to across these landscapes is being undertaken to meet several ‘continue healthy fire management’. In itself, this goal is environmental, cultural, social and economic goals. Of note is significant and reflects the success and progress of the fire the recurring theme in the planning documents of fire manage- management programs in Arnhem Land to date through the ment as an asset to be maintained in its own right on country. eyes of Traditional Owners. A previously intractable problem,
Broadly summarised into six key goals, their consistency how to reinstate Aboriginal fire management practices across a further demonstrates how integral fire management is for vast remote landscape, has in fact been solved. For the last
Aboriginal people and their vision for country. The most decade, fire management programs, particularly in west and

(a)

Times burnt
1
2
3
4
5
6
7
8
9
10

(b)

Times burnt
1
2
3
4
5
6
7
8
9
10

Fig. 6. Ten-year late fire frequency maps for eastern Top End of the Northern Territory: (a) 1995–2004;
(b) 2008–17.
Aboriginal savanna burning in Arnhem Land Int. J. Wildland Fire 381 central Arnhem Land, have been delivering outstanding fire in the extent and seasonality of fire between the baseline and the management results. fire project periods. In particular, project areas exhibit a signifi-
The goal to ‘continue healthy fire management’ also pro- cant decrease in the area of late dry season fire and a significant vides an opportunity to examine and describe what good fire increase in the area of early dry season fires, which have also management looks like for Aboriginal people in Arnhem Land. become smaller and more numerous (indicators of patchy fire)
All of the eight planning documents detail the importance of as a result of operating the fire projects.
Traditional Owners directing and undertaking fire management Traditional Owners see on-ground burning as an important activities on their country. At the regional scale, the fire projects fine-scale fire tool, particularly for the management of specific in Arnhem Land are owned and operated by Traditional Owners food resources as well as cultural and environmental sites.
through the formation and operation of the ALFA Co. At the Ground burning activities also maximise employment opportu- local scale, each Aboriginal ranger group is tasked to coordinate nities and, importantly, enable rangers to engage in the custom- the planning and delivery of fire management with Traditional ary economic component of their individual and communal
Owners. How this translates to fire management on the ground livelihoods (Buchanan and May 2012; Altman 2012). Altman varies greatly from year to year and also from clan to clan across (2012) described the high value placed by Aboriginal people on the landscape. As such, it is important for the savanna burning mobility and on accessing traditional lands given the significant method to remain a mechanism to calculate and account for lack of transport infrastructure in remote areas. It is also for this carbon given a range of management actions rather than pre- reason that ground burning is likely to be significantly under- scribe a particular fire management regime. This is particularly represented in the data, because it is often largely ad hoc.
relevant for Aboriginal Land under the Aboriginal Lands Rights Traditional Owners in Arnhem Land want fire management
Act because regardless of the project proponent, Traditional to result in fewer wildfires on their country. Indeed, this goal
Owners have the right to burn their clan estates at any time. provided the impetus for the commencement of the WALFA
The ALFA fire projects are clearly delivering strongly on their use of strategic fire management in the early dry season as 400 000 well as their employment outcomes. The delivery of the suite of WALFA
Australian Carbon Credit Units fire management activities provides a mix of employment 350 000 CALFA opportunities for hundreds of Aboriginal people across Arnhem 300 000 SEALFA
Land. As a result, in all project areas there is a significant change 250 000 SEALFA2
200 000 NEALFA
150 000
Table 5. On country site protection, fire education and training events
facilitated by the ranger groups within the fire project areas in 2017 100 000

50 000
Activity Number of ranger Number of individual
0
groups events 2011 2012 2013 2014 2015 2016 2017

Bushwalks 4 4 Year
Culture camps 2 2
Bush trips 1 6 Fig. 7. The Australian Carbon Credit Unit (ACCU) issuance from each of
Protect sacred sites 1 15 the registered fire projects in Arnhem Land. One ACCU is equal to an
Protect rock art 1 30 abatement of one tonne of carbon dioxide equivalent. WALFA, Western
Ceremony 2 2 Arnhem Land Fire Abatement; CALFA, Central Arnhem Land Fire Abate-
Learning on Country 3 3 ment; SEALFA, South East Arnhem Land Fire Abatement; SEALFA2,
South East Arnhem Land Fire Abatement Stage 2; NEALFA, North East
Arnhem Land Fire Abatement.

Table 6. Employment breakdown for the WALFA project in 2017
Figures in parentheses are the average percentage change from 2011 to 2016. Note: although any activity could be considered ‘asset protection’, here it is used to designate work to directly secure cultural and environmental sites of significance as well as infrastructure. EDS, early dry season; LDS, late dry season

Pre-season consultation Roadside burning Aerial burning Asset protection Total EDS ops LDS Fire Suppression
Group People Hours People Hours People Hours People Hours Hours People Hours

Adjumarllarl 33 264 6 152 6 20 6 152 588 0 0
Djelk 70 560 33 476 18 60 33 476 1572 7 784
Jawoyn 30 240 45 1392 13 70 45 1392 3094 8 384
Mimal 46 500 50 756 15 24 28 1000 2280 14 850
Warddeken 70 560 45 456 26 238 45 456 1710 29 1190
Total 249 2124 179 3232 78 412 157 3476 9244 58 3208
(þ89%) (þ351%) (þ73%) (28%) (þ27%) (þ12%) (þ95%) (þ26%) (þ15%) (þ14%) (11%)
382 Int. J. Wildland Fire J. Ansell et al. project before the establishment of the savanna burning meth- and frequency of severe wildfires and include the retention of ods and Federal carbon legislation (Whitehead et al. 2009). In areas of 3þ years of unburnt vegetation (Woinarski et al. 2011; the fire-prone landscapes of northern Australia, large wildfires Radford et al. 2015). Other important factors include the proliferate in the absence of fire management (Yibarbuk et al. distribution of different-aged stands of vegetation, riparian
2001). The results in this paper related to wildfire ignition areas, rainforest pockets, tree hollows and fruiting trees sources are similar to other such reports, where fires are lit (Radford et al. 2015). In addition, fire also effects the interac- mostly by people but are also ignited by lightning strikes during tion of native fauna with predators and this can have a marked periods of extreme fire weather conditions before the start of effect on vertebrate biodiversity. Research in northern Western the wet season (Yibarbuk et al. 2001). The joint strategies of Australia demonstrates that feral cats are attracted to late fire reinstating customary fire regimes and active fire suppression scars within the landscape because their hunting is more across Arnhem Land through the operation of the fire projects effective in open country (Leahy et al. 2016). Although not a has significantly reduced the average area burnt in the late dry substitute for biodiversity monitoring, the results from season with a marked decline in both the extent and frequency research outside of Arnhem Land suggest that the contempo- of late dry season fire between the baseline and fire project rary fire regimes in Arnhem Land (which demonstrate a high periods (Figs 5, 6). level of patchiness, areas of unburnt vegetation and a reduction
The protection and preservation of biodiversity, particu- in the extent and frequency of late dry season fires) are likely to larly plants and animals that are economically and culturally be favourable for a broad suite of existing biodiversity (e.g.
important to Aboriginal people (Altman 1987), is another key Woinarski et al. 2011; Griffiths et al. 2015; Radford et al.
fire management goal in Arnhem Land. Within the planning 2015; Werner and Peacock 2019).
documents, Traditional Owners identify species that are Within the planning documents, Traditional Owners state important indicators for healthy fire regimes including species that they want the fire management projects to protect cultural such as emus, wallabies, native bees and fire sensitive plant sites as well as to maintain and transfer knowledge in relation to communities like Anbinik (Allosyncarpia ternata) and the fire in the landscape. Although these goals are site specific to
Callitris pine (Callitris intratropica) (Bawinanga Aboriginal individual operational areas and outside the broad scope of this
Corporation 2015; Warddeken Land Management Limited paper, it is likely that they are beginning to be met across
2016; Arafura Swamp Rangers Aboriginal Corporation Arnhem Land as a result of the reintroduction of people
2017; Mimal Land Management Aboriginal Corporation managing fire. Annual fire reports from each of the Aboriginal
2017; Jawoyn Association Aboriginal Corporation 2018). ranger groups in Arnhem Land describe the facilitation of
Few publications have examined the response of these indica- specific larger fire-related events on country targeted at particu- tors to the changed fire regimes in Arnhem Land (Evans and lar audiences (e.g. school kids and elders). These events
Russell-Smith 2019; Woinarski et al. 2009), and some Aborig- included overnight bush walks and canoe trips on country, inal ranger groups in Arnhem Land have begun ambitious cultural camps in the school holidays, wildlife fire drives and research and monitoring projects in order to be able to examine ceremonies. For example, in 2016, Mimal Land Management the biodiversity outcomes from their management regimes Aboriginal Corporation and Arafura Swamp Rangers Aborigi-
(e.g. Mayh Species Recovery Program; Warddeken Land nal Corporation supported the performance of a fire ceremony
Management Limited 2017). that had not been performed for more than 40 years. All of these
The sandstone plateau of Arnhem Land and its surrounds education and training events celebrate and share the knowledge supports an unusually high number of endemic plant and of various uses of fire as directed by Traditional Owners.
animal species, distinctive vegetation types and many threat- The final of the six fire management goals is the production ened species (Woinarski et al. 2009). Ecological research in of a carbon abatement. Only three of the planning documents other parts of northern Australia provides some indication of included this as a specific goal of their fire management.
the effectiveness of Arnhem Land fire regimes for the protec- Although it is the production of a carbon abatement that tion and preservation of this biodiversity hotspot. Werner and provides the funding to operate the fire projects and associated
Peacock (2019) studied the population dynamics of open-forest cultural activities, this paper demonstrates that it does not drive savanna canopy trees (i.e. those trees that form the basic decisions about how fire management is undertaken within the structure of the savannas and provide resources for associated project areas. The ALFA projects are performing extremely well fauna species) under various fire regimes. This research in regard to producing a carbon abatement under the savanna demonstrates that long-term persistence of savanna canopies burning method (Fig. 7). This is likely to increase with the with a non-sorghum understory are severely compromised by potential for the Arnhem Land projects to engage with new occasional late dry season fires. Werner and Peacock (2019) methodologies, particularly the recently released 2018 savanna recommended that late dry season fires in these landscapes burning sequestration and emissions avoidance methods should be avoided where possible and otherwise not occur less (Commonwealth of Australia 2018b). Not surprisingly, it is than every five years. the income generating potential of the fire projects that receives
Current research specifically focused on native fauna sug- the most attention within the broader Australian community. A gests that fire heterogeneity on a landscape scale is one of the common misconception is that the savanna burning method pays most important factors, because not all animals respond the people to burn and that, as a result, more country is burnt more same way to fire regimes (Radford 2010; Lawes et al. 2015; often (Ray 2018). However, an abatement is only created when
Radford et al. 2015; Russell-Smith et al. 2017). Fire regimes projects reduce the extent and severity of fire in the landscape that benefit savanna mammals are those that reduce the extent compared with a historical baseline. As described above, the
Aboriginal savanna burning in Arnhem Land Int. J. Wildland Fire 383 results from this paper clearly show a general decreasing trend in Conclusion the total area burnt, a significant decrease in the area of late dry The development of savanna burning into an industry able to season fire and early dry season fires have become smaller and earn and sell carbon credits has not been met with a shift in more numerous (indicators of patchy fire) as a result of operat- public understanding of fire management, as summarised in a ing the fire projects (Fig. 5). recent newspaper article (Ray 2018). Common critiques ques-
Petty et al. (2015) asked how the fire management aspira- tion not only the environmental outcomes of fire management tions of Traditional Owners will continue to articulate with (of which there is a growing body of both Aboriginal and organisations such as ALFA (NT) Limited, which must remain western scientific evidence) but also the use and value of responsive to the requirements and constraints of national Aboriginal customary knowledge. This paper clearly commu- greenhouse gas emissions frameworks and carbon abatement nicates a description of contemporary fire management from the contracts. In Arnhem Land, successful operation focuses on perspective of Traditional Owners across a broad region of fire local ownership of the fire management projects while utilising project operation. In particular, this paper describes the aspira- existing local Aboriginal ranger groups to coordinate delivery tions of Traditional Owners and the importance of cultural and engagement of Traditional Owners across large regional responsibilities in relation to fire management. In Arnhem Land, scales. Indeed, it is this structure that forms the framework for Traditional Owners are making their own decisions about the governance of ALFA (NT) Limited. As noted by Altman country and the use of fire as they have done for many thousands
(2012), Aboriginal rangers use local Indigenous ecological of years. In doing so, Traditional Owners are utilising the best knowledge that they possess and mobilise from their relations tools available for undertaking the job and accessing cutting with family living on outstations, who are their eyes on their edge information and expertise through key partnerships country. The ranger groups have been developing their experi- (including with their local Aboriginal ranger programs), they are ence and expertise over many decades, supported by a diverse managing fire according to their intimate cultural and bio- array of external partnerships as well as functional host organi- physical knowledge of country and continuing to share this sations offering coordination, administration and financial man- knowledge with younger generations.
agement support. It is these complex and highly functional internal and external relationships that have enabled Traditional
Owners in Arnhem Land to utilise their customary fire knowl- Conflicts of interest edge, navigate the administrative and methodological complex- The lead author is the CEO of ALFA (NT) Limited. ALFA is ities of registering fire projects and subsequently reap the responsible for managing the savanna burning project reporting economic, cultural, social and environmental benefits of engag- and the generation and sale of carbon credits from the Arnhem ing with the developing carbon industry. Land fire projects. ALFA was not involved in the consultation,
The compilation of ranger planning documents has proved an compilation or publication of any of the ranger planning effective means of utilising existing and extensive information documents.
from Traditional Owners across a broad regional scale. How- ever, we note that the views of all Traditional Owners will not be Acknowledgements encapsulated within these plans and that this regional summary
We thank the Traditional Owners throughout Arnhem Land, whose approach was not the original intention of the planning docu-
knowledge of, and vision for, country has been documented through the ments. Previous research highlights the importance of the need ranger planning documents, and for their ongoing oversight and support of to monitor the effectiveness of large-scale fire management the ranger programs. The Adjumarrlarl, Arafura Swamp, Djelk, Jawoyn, programs, particularly when there is a monetary incentive Mimal, Numbulwar Numburindi, Yugul Mangi, Warddeken and Yirralka behind particular management actions (Fitzsimons et al. ranger groups acknowledge the assistance of their many project partners who
2012). Fache and Moizo (2015) analysed the burning practice support, fund and contribute to the management of land and sea country in of Aboriginal rangers in south-east Arnhem Land before opera- Arnhem Land. We thank Jon Altman, Jeremy Russell-Smith, Shaun Ansell, tion of a registered fire project. They described a transfer of the Ben Lewis and David Curmi, the Associate Editor and two anonymous social and ritual responsibility of burning from Traditional reviewers for helpful comments on drafts of the manuscript. We also thank
Owners to Aboriginal rangers and other non-Aboriginal stake- Alex Ernst and Jett Street for the use of their photographs. This research did
not receive any specific funding.
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Postcolonial Studies

ISSN: (Print) (Online) Journal homepage: https://www.tandfonline.com/loi/cpcs20

No ordinary company: Arnhem Land Fire
Abatement (Northern Territory) Limited

Jon Altman , Jennifer Ansell & Dean Yibarbuk

To cite this article: Jon Altman , Jennifer Ansell & Dean Yibarbuk (2020): No ordinary company: Arnhem Land Fire Abatement (Northern Territory) Limited, Postcolonial Studies, DOI:
10.1080/13688790.2020.1832428

To link to this article: https://doi.org/10.1080/13688790.2020.1832428

Published online: 23 Oct 2020.

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POSTCOLONIAL STUDIES https://doi.org/10.1080/13688790.2020.1832428

No ordinary company: Arnhem Land Fire Abatement
(Northern Territory) Limited
Jon Altmana, Jennifer Ansellb and Dean Yibarbukc a
School of Regulation and Global Governance, The Australian National University, Canberra, Australia; b
Arnhem Land Fire Abatement (Northern Territory) Limited, Darwin, Australia; cKabulwarnamyo, Arnhem
Land, Australia

ABSTRACT KEYWORDS
Arnhem Land Fire Abatement (Northern Territory) Limited (ALFA) is Carbon emissions reduction;
a non-profit company established to make a financial return from Aboriginal land rights;
savanna fire management. It operates as a charitable entity to savanna burning; corporate
governance; postcolonial
ensure that its earnings benefit the Aboriginal landowners of
possibilities
Arnhem Land, many living in deep poverty. ALFA is unusual
because it must operate at the intersection of Western and
customary domains. It catalyses and supports the carbon
emission avoidance activities of Aboriginal ranger groups and
traditional landowners, who deploy customary and Western fire-
management approaches at a large regional scale.
Simultaneously, ALFA manages the Australian Carbon Credit Units
that it earns, either selling them under contract to the Australian
government or to corporate purchasers, or saving them for later
sale. In this article we examine the first five years of ALFA since
its establishment in 2015 – its origins and more recent history, its
achievements and its governance. We then examine several
climatic, financial, environmental and politico-cultural challenges
that it faces operating in the Australian carbon and conservation
economies. We show from diverse perspectives how, during a
late-capitalist period of extreme climatic uncertainty, ALFA has
evolved into an established model of sustainable postcolonial
possibility, as ‘no ordinary’ company.

Preamble
In early March 2020 the directors of Arnhem Land Fire Abatement (Northern Territory)
Limited (ALFA) met in person in Darwin. Coordinating the logistics for a meeting of
ALFA’s 16 directors, each living in a different remote Aboriginal community in
Arnhem Land, is a herculean task at the best of times. The March 2020 meeting
finalised the company’s budgets and contracts for the upcoming fire season, covering the 80,000 sq. km of sparsely settled Aboriginal-owned land in Arnhem Land subject to savanna fire management for carbon emissions avoidance. Then COVID-19 pandemic restrictions were imposed, and Arnhem Land was designated a restricted biosecurity zone. ALFA’s annual pre-season fire planning meeting was cancelled and replaced by fortnightly Zoom meetings between directors and staff and Aboriginal ranger groups.

CONTACT Jon Altman jon.altman@anu.edu.au
© 2020 The Institute of Postcolonial Studies
2 J. ALTMAN ET AL.

Planning and consultation with traditional landowners were completed as usual and early prescribed burning commenced in April 2020.
The COVID-19 pandemic has not been the only influence on our perspectives as we have collaborated on writing this article. Earlier, on 21 October 2019, as we sat in Darwin in air-conditioned comfort, the city sweltered at over 38 degrees Celsius, the 2nd hottest
October day on documented record, highlighting the emerging reality of global warming.1 We looked intently and nervously at the North Australia Fire Information
(NAFI) website as Aboriginal rangers in Arnhem Land struggled in real time to manage late dry-season wildfires that would cost ALFA valuable carbon credits.2
The 2019 fire season was one of the most challenging in recent memory for northern, and then subsequently for southern, Australia.3 In January 2020, 186,000 sq. km of south- eastern Australia was scorched by the Black Summer bushfire disaster and Australia’s
Top End experienced its second below average wet season in a row, with some of the lowest rainfalls in 80 years of official record keeping.4 Rapid global warming is an increas- ing risk for ALFA and its core goal of producing and selling commodified carbon emis- sion reductions. The 2020 fire season will also be challenging as ALFA looks to generate enough carbon credits to meet its multiyear contractual obligations that provide the income stream needed to fund its ongoing fire-management operations.
In March 2020, just before the domestic closure of air travel, we met in person in Mel- bourne, as one co-author, Dean Yibarbuk, a director of ALFA, made a presentation at the
Fire Forum convened by the Institute of Postcolonial Studies,5 and as ALFA’s CEO, Jen- nifer Ansell, conducted meetings with Melbourne-based carbon brokers. There is growing interest nationally in how and why Aboriginal people burn their country and whether this generates co-benefits for the environment (or ‘Country’), for species, the climate and people. This interest has grown with climate change and global warming, and with scientific evidence that seasonal burning practices that accord with Aboriginal tradition reduce greenhouse gas emissions.6 Following the catastrophic bushfires in south-east Australia, a Royal Commission into National Natural Disaster Arrangements has sought expert evidence, with one of its terms of reference highlighting ‘traditional’ burning by Aboriginal and Torres Strait Islander peoples.

Introduction
This article relates the story of ALFA, an Aboriginal-owned non-profit carbon business.
ALFA was initially established by the traditional landowners of Arnhem Land, in north- ern Australia, in 2013. ALFA’s main aims are to support planned savanna fire manage- ment across Arnhem Land and simultaneously to commercially manage and market the remunerated carbon emission reductions this activity generates. ALFA’s primary objec- tive, as formally documented in its constitution, is to protect, preserve and care for the environment through abatement of greenhouse gas emissions by means of bushfire-man- agement activities. It has other objects focused on biodiversity conservation, alongside charitable objectives to improve the wellbeing of people with traditional Aboriginal con- nection to its project areas, alleviating poverty and assisting in education.
The company was established by community-based Aboriginal ranger groups in west
Arnhem Land. As in many other areas of northern Australia, Aboriginal ranger groups operate across Arnhem Land to deliver natural and cultural resource management
POSTCOLONIAL STUDIES 3 services; some operate in declared Indigenous Protected Areas, and all use fire manage- ment as a landscape-management technique.7 After extensive consultation with all land- owning groups in the proposed fire project areas, ALFA was granted the legal right to undertake fire management for the purpose of generating and selling carbon credits.
Such consultation and agreement are required by the Aboriginal Land Rights (Northern
Territory) Act 1976. Membership of ALFA is open to any traditional owner of land where
ALFA operates. As such, it is at once an alliance and a collaboration between traditional owners and their affiliated Aboriginal ranger group contracted by ALFA to coordinate
fire management in accordance with landowner directions.
Nine Aboriginal ranger groups, consisting of traditional owners and their families, undertake all operational aspects of the landscape-scale fire management that occurs in five ALFA project areas. The spatial extent of these projects is illustrated in Figure 1 and the names of Aboriginal ranger groups are provided in Table 1.
ALFA operates as a complex intercultural broker.8 It initially mediates between the
Aboriginal ranger groups, which are contracted to manage fire over their area of oper- ations, in accordance with landowner directions to generate carbon credits. This requires considerable governance and coordination effort across a massive region with limited infrastructure. ALFA then engages with the Australian government’s Clean Energy Reg- ulator in a legislated validation process to convert measured and independently verified emission reductions into saleable Australian Carbon Credit Units (ACCUs). Finally, it enters the carbon market, either selling these units to the Emissions Reduction Fund
(ERF) or in other markets.9 Alternatively, ALFA can retain ACCUs in a bank-like

Figure 1. Map of ALFA fire project areas (CALFA: Central Arnhem Land Fire Abatement; WALFA: West
Arnhem Land Fire Abatement; NEALFA: North East Arnhem Land Fire Abatement; SEALFA: South East
Arnhem Land Fire Abatement).
4 J. ALTMAN ET AL.

Table 1. The five ALFA fire projects registered as eligible offset projects.
Date of carbon trading
Project Area (sq. km) Aboriginal ranger groups registration
WALFA 28,000 Warddeken, Bawinanga/Djelk, Mimal, Jawoyn, December 2014
Adjumarllal
CALFA 26,000 Bawinanga/Djelk, Mimal, Arafura Swamp Rangers December 2014
SEALFA 5,000 Yugul Mangi, Numbulwar Numbarindi August 2015
SEALFA 2 10,000 Yugul Mangi, Numbulwar Numbarindi January 2016
NEALFA 11,000 Yirralka November 2016
Note: the distinction between SEALFA and SEALFA2 refers to the latter being below the 1000 mm per annum rainfall
region and subject to a different emission reduction methodology. But the two areas are contiguous, and both are
managed by the same two ranger groups. institution called the Australian National Registry of Emissions Units (ANREU). This tri- partite set of highly techno-bureaucratic activities undertaken by ALFA is mandated by
Australia’s Carbon Farming Initiative legislation of 2011, which created ACCUs as a form of property and crypto commodity.10
We begin by very briefly reflecting on three phases in regional fire history. The first is the precolonial period, which saw the use of fire by Aboriginal people to manage the highly flammable Arnhem Land tropical environment. This was followed by a settler colonial period of domination when Arnhem Land was gazetted a reserve, missions and government settlements were established, and such burning practices were actively discouraged by state authorities and so declined. The third period can be conceptualised as postcolonial. This period began when Aboriginal people were granted exclusive own- ership of their lands and natural resources (except sub-surface minerals) under land rights law. These new property rights have been reiterated and reinforced by the
Native Title Act 1993, passed as the statutory response to the High Court Mabo judgment of 1992. The immediate antecedent to ALFA was a globally pioneering endeavour called the West Arnhem Land Fire Abatement (WALFA) project, initiated in the late 1990s, which both piloted carbon emission reductions from savanna burning and advocated for these to be legally recognised. WALFA entered a voluntary agreement with the multi- national corporation Conoco Phillips to abate 100,000 tonnes of carbon emissions a year from 2006. Subsequently, after passage of the Carbon Credits (Carbon Farming Initiative)
Act, 2011, WALFA incorporated as WALFA Ltd, in 2013, and then, as it expanded its operations eastwards across Arnhem Land, its name changed to ALFA, in 2015.11
Next, we explore the operations of ALFA and its performance as it expanded its ambit from western to central Arnhem Land and then to southeast and northeast Arnhem
Land. We illustrate how ALFA’s corporate form and participatory governance allow it to navigate a complex institutional and political environment, and how much of this ability was framed from the earlier experiences of its founders with Aboriginal organis- ations and environmental enterprises in Arnhem Land. We also reflect on its ongoing attentiveness to build the capacity of its directors to face the many challenges that have emerged.
The authors of this article come from diverse backgrounds: the social sciences, biologi- cal sciences and Indigenous fire ecology. As the notes on contributors indicate, we have long associations with each other and with the issues raised. And as our disclosure state- ment indicates, we openly acknowledge that we are champions of ALFA and the savanna- burning activities that it sponsors and underwrites. Our narrative gives ALFA legal
POSTCOLONIAL STUDIES 5 personality in places, but we are keen to avoid providing some uncritical hagiography of the company. Hence under the broad rubric ‘challenges’, we discuss some of the risks, threats, concerns and critiques of the company’s activities that are emerging. We also outline the steps that ALFA has taken to address those challenges.
Finally, we combine our diverse perspectives to provide an analysis of ALFA as ‘no ordinary’ company, borrowing the title of Nonie Sharp’s book No Ordinary Judgement about the long struggle for the recognition of native title that resulted in the successful
Mabo High Court judgment.12 We deploy this idiom to reflect the long struggle, like
Mabo, of nearly a decade for the carbon reduction outcomes from controlled savanna burning to be legally recognised; and our view that traditional owners should be empow- ered to exercise their native title rights and interests to determine how their land is managed postcolonially. We end by reflecting on the symbiotic relationship between savanna burning to reduce carbon emissions and generate income and the growing
Caring for Country environmental movement across Arnhem Land. Despite the precar- ity of the present period and the many challenges ALFA faces, it has proven to be ‘no ordinary’ company, successfully engaging with one very distinct postcolonial possibility.

The genesis and ancestry of ALFA: one history, three phases
Terrestrial Arnhem Land is a highly flammable region of nearly 100,000 sq. km. In the nineteenth century much of the region was explored by European colonists and parts of it temporarily occupied by commercial cattle enterprises that failed and were then abandoned.13 It was only in the twentieth century that state and missionary colonisation occurred, along the coastal and terrestrial borders of Arnhem Land, with the interior largely left for continued Aboriginal occupation and use. Even as government policy sought to centralise people in missions and government settlements for assimilation, small groups continued to manage the environment and its natural resources by deploy- ing customary seasonal fire regimes, ‘the Wurrk (bushfire) tradition’. Dean Yibarbuk out- lines this tradition in a short 1998 essay and in a jointly authored article in 2001.14 A decade later, linguist Murray Garde collaborated with eight senior Aboriginal interlocu- tors in dialects of the west Arnhem Land regional pan-dialectical language Bininj
Kunwok to provide a comprehensive account of the language of landscape burning on the Arnhem Land Plateau and adjoining savanna woodlands and grasslands.15 At the core of pre-colonial deployment of fire to manage the environment was the annual sea- sonal cycle.
To simplify considerably and focus on west Arnhem, the region whose lingua franca and practices we know best and where the emissions reduction initiative began, the annual cycle is divided into six seasons, which have some correspondence to the
Anglo-Australian dry and wet seasons: yekke (early dry), wurrkeng (cool mid dry/fire season) and kurrung (late dry) followed by kunumeleng (early wet/first rains), kudjewk
(mid wet monsoon) and bangkerreng (late wet/last rains).16 Customary burning was and continues to be undertaken by people primarily in the early- and mid-dry season as they traverse the landscape igniting fires that generally go out overnight. Such fires create a patchily burnt landscape and natural firebreaks that limit the extent of destruc- tive wildfires in the hot late-dry season when lightning strikes can ignite non-anthropo- genic burning. Any such wildfire is only extinguished as it travels into an area with
6 J. ALTMAN ET AL. reduced fuel loads (through earlier burning) or by the onset of monsoonal wet seasons, a
fire-free period. The story of the seasonal cycle, fire and the regeneration of vegetation and biodiversity is one that has been related in the scientific and ecological literature many times in recent years.17
The colonial period was followed by a change of government policy from the early
1970s. This policy shift to a form of self-determination saw the passage of land rights law and the provision of some limited support for groups seeking to reoccupy their ancestral lands – what became known as the homelands movement. These shifts in approach are open to various interpretations that we will not debate here18: We see them as a form of partial decolonisation in a remote region that opened up some new possibilities – forms of intercultural living informed by extant Aboriginal norms and values that emerged even while Aboriginal people remained deeply encapsulated within the juridical and political dominance of the settler colonial state. Repopulation of outstations in some regions demonstrated how the landscape could be managed by people using fire. Conversely, continual depopulation of other regions, especially the massive and relatively inaccessible Arnhem Land Plateau, showed that environmentally destructive wildfires had become a recurring annual seasonal event. This contrast was clearly apparent to Aboriginal landowners when visiting their depopulated estates, and to Western fire ecologists viewing the landscape both on the ground and using remote satellite imagery. Simultaneously, there was growing Aboriginal concern about environ- mental threats to their repossessed lands from invasive feral animals and exotic weeds.
An Aboriginal-led environmental movement, Caring for Country, spread across
Arnhem Land (and elsewhere where land was reoccupied) and community-based Abori- ginal ranger groups were established from the 1990s.19 In their management plans each group identifies prescribed burning as a means to manage the environment, and uncon- trolled wildfires as a serious threat to biodiversity.
From the late 1990s the West Arnhem Fire Abatement (WALFA) project was estab- lished to reduce destructive wildfires in the depopulated Arnhem Land Plateau and sur- rounding areas. This project was a collaboration between Western scientists, five emerging Aboriginal ranger groups (the WALFA partners in Table 1) and traditional owners. It was initially sponsored by the Natural Heritage Trust, the Tropical Savannas
Management Cooperative Research Centre (TSM-CRC) (1995–2009) based at Charles
Darwin University, and the new Caring for Country Unit within the Northern Land
Council, an Aboriginal statutory authority with responsibilities for managing Aboriginal land in the Top End of the Northern Territory. Research by fire ecologists demonstrated the potential commercial value of carbon abatement that would emerge if Australia was to ratify the Kyoto Protocol. A detailed history of this decade-long development of the globally pioneering WALFA project has been documented elsewhere in a comprehensive volume.20 This collaboration was predicated primarily on the marrying of remote sensing techniques for measuring emissions reduction with the on-the-ground practice of Abori- ginal ranger groups (complemented by the activities of outstation residents) in contem- porary burning of the landscape based on seasonality. The customary basis of this fire regime had its foundations in ‘the Wurrk (bushfire) tradition’ of west Arnhem Land, as outlined above.21
Peter Cooke uses the theoretical construct of ‘social capital’ to explain how over a decade a network of like-minded people laboured to alter the widely held view of
POSTCOLONIAL STUDIES 7

Aboriginal fire management as ‘anarchic pyromania’. Instead that network sought to create a public understanding that early dry season managed burning reduces intensive and uncontrolled wildfires during the late dry season, thus contributing to both biodiver- sity conservation and carbon emissions reduction.22 This perspective was promoted by
Darwin-based scientific researchers working in collaboration with experienced Aborigi- nal fire ecologists such as co-author Dean Yibarbuk. It was vigorously marketed to con- servation-minded sections of the political and bureaucratic apparatus in Darwin and
Canberra and the wider scientific community in an effort to alter perceptions. The crucial role of the decade-long WALFA experiment was, as Cooke notes, ‘the bonding collaborations between blacks and whites working together in the “big laboratory” of
Arnhem Land to create the science of fire, fuel loads, and vegetation communities that led to the acceptance of the savanna burning methodologies’.23 Not to be overlooked, an essential element of this bonding occurred in the Aboriginal domain as traditional owners of numerous discrete land estates voluntarily conjoined their lands into a joined-up savanna-burning environmental commons, initially in West Arnhem.
The energy company ConocoPhillips was developed a plant in Darwin to liquefy natural gas for export and, in exchange for a licence to operate, was required by the
Northern Territory government to fund an environmental project to offset its industrial carbon emissions. The company took the risk to select the yet unproven WALFA project as that offset project. From 2006, Darwin Liquefied Natural Gas (DLNG) committed to providing long-term funding of $1 million per annum (indexed for inflation) under the
West Arnhem Fire Management Agreement (WAFMA) to five ranger groups (see Table
1) to underwrite the cost of maintaining annual controlled burning across 28,000 sq. km of western Arnhem Land. In exchange, the ranger groups were required to generate a minimum annual greenhouse gas reduction of 100,000 tons CO2 equivalent, against an earlier 10-year calculated baseline, for a 17-year contract period.
WALFA demonstrated what is achievable from a Western scientific carbon account- ing perspective. But more significantly, it allowed Aboriginal ranger groups to trial such a project, an opportunity they embraced, thus proving to themselves and others that they could reinstate fire regimes on a landscape scale if financially resourced to do so. Five years later, the Australian government introduced the Carbon Credits (Carbon
Farming Initiative) Act, 2011, an emissions trading scheme for the creation and trade of a virtual or crypto commodity called an Australian Carbon Credit Unit (ACCU), which is deemed the equivalent of one tonne of carbon dioxide. Now there was a market instrument created for the generation and sale of carbon. At that time,
WALFA had already been operating for over five years. The operations of WALFA were the precursor to the official acceptance in 201224 by the Australian government of the savanna burning methodology that has since led to the proliferation of over 70 registered savanna-burning projects across tropical north Australia.

ALFA’s operations, governance and management: the first five years
It is straightforward to say that the current ALFA evolved from WALFA; it is far more difficult to track that transformation in the evolving institutional arrangements of the highly politicised climate change debates and ever-changing carbon-trading environ- ment in Australia between 2007 and 2014.
8 J. ALTMAN ET AL.

Accompanying the introduction of carbon legislation in 2011, the Australian govern- ment established the Indigenous Carbon Farming Fund to assist Indigenous groups to develop and register projects under the Carbon Farming Initiative Act. Warddeken Land
Management Limited lodged a successful application in 2013 on behalf of the five
WALFA partners to fund business and project development activities to assist the formal commercialisation and expansion of WALFA’s activity. The WALFA partners wished to maintain the integrity of the WALFA project as well as the relationship between WALFA and DLNG. One requirement of the legislation was that a Recognised Offsets Entity be the legal holder of ACCUs created by the WALFA project. Early meeting notes record the shared vision to create a single and separate legal entity to undertake the future admin- istration and business elements of carbon-trading activity on behalf of all the WALFA partner organisations. Also articulated was the need for such an entity to focus on ‘bininj to bininj’ (Aboriginal to Aboriginal) communication. Legal compliance required formalisa- tion and completion of land use agreements between the new legal entity and Aboriginal traditional owners under s. 19 of the Aboriginal Land Rights Act. This in turn required extensive consultation with landowners, undertaken by a WALFA-appointed team, and staff of the Northern Land Council, to ensure that the new entity was vested with the legal right to undertake fire management for the purpose of generating and selling carbon.
In late 2013 WALFA Ltd was registered as a company limited by guarantee under the
Australian Securities and Investment Commission; and in 2015 its name was changed to
ALFA to reflect its geographic expansion. This non-profit company was also registered as a charity with the Australian Charities and Not for Profits Commission with tightly defined objectives that required it to allocate its income to meet annual operational costs of fire management in the first instance. Surplus income earned by Aboriginal ranger groups could be allocated to meet other land-management goals, but no cash pay- ments could be made to individuals.
The membership of ALFA is open to any Aboriginal adult who has customary respon- sibility for the land in its project areas under traditional law. Members are divided into eight membership classes or wards, determined by their Aboriginal ranger group’s geo- graphic areas of operations, as illustrated in Figure 1 and outlined in Table 1.25 Each ward elects two directors to the ALFA Board and so the strategic direction and management of the company are effectively the responsibility of these 16 directors. Directors who can self-nominate or be nominated by members of their ward are elected for three years.
A number of these wards correspond to the jurisdictions of Indigenous Protected
Areas (IPAs) that have been incorporated into the Australian National Reserve System for their outstanding environmental values. Almost all the ALFA project areas are either within the Warddeken, Djelk, Yirralka and South East Arnhem Land IPAs or in two proposed IPAs (Mimal and Arafura Swamp) that are in the consultation phase and will likely be declared in 2021. In a recent analysis of the management plans of all the Aboriginal ranger groups that are members of ALFA, it was shown that managing the natural environment and biodiversity with seasonal savanna burning is a priority for all Aboriginal ranger groups.26 But funding from government and non-government sources does not properly cover the high cost of such savanna burning, which requires thousands of kilometres of ground and aerial prescribed burning to be undertaken annually. The annual savanna fire management that occurs in Arnhem Land is resourced through engagement with the carbon market and the savanna burning methodology.
POSTCOLONIAL STUDIES 9

ALFA contracts nine Aboriginal ranger groups to undertake the fire management intended to deliver carbon emissions reductions. This activity in turn generates the carbon credits that, when sold, finance the next round of annual contracted fire manage- ment that creates Aboriginal employment. Each ranger group produces a Fire Manage- ment Plan for its area and signs a contract with ALFA with an agreed budget for operations. The process is transparent to and agreed by the Board of Directors. Each group then gets a percentage of operational funds up front with additional payments on meeting agreed reporting milestones. The process for generating the carbon credits units requires highly technical calculations. These are undertaken by ALFA using an innovative online programme, the Savanna Burning Abatement Tool (SavBAT).
SavBat automates complex Geographical Information Systems (GIS) calculations inte- grating data from remotely sensed seasonal fire-scar maps, a validated vegetation map of each project area, and information provided by Aboriginal ranger groups on their early dry season prescribed burning. This information is included in an annual Projects
Offsets Report and must be audited independently on completion by an auditor listed on the Clean Energy’s Regulators Register of Greenhouse and Energy Auditors, before the
Clean Energy Regulator allocates ACCUs.
ALFA’s operational performance in its first five years can be assessed using many metrics. We focus here on financial performance as summarised in Table 2; and on its
ACCU (carbon credit) balance sheet as summarised in Table 3. The two are closely cor- related. Other more qualitative metrics that reflects local perceptions of environmental outcomes could also be used.27
In Table 2 it is evident that while ALFA’s income has fluctuated it has retained sufficient cash reserves to cover its expenditures, which include operational and grant funding to Aboriginal ranger groups, as well maintenance of a buffer (held in ACCUs and cash) equivalent to one year’s future contractual commitment. On top of this, each project makes a contribution to the company’s operational costs, which mainly con- sists of a small staff establishment; the direct costs of governance, such as regular board meetings; governance training, which has been contracted in since the company’s estab- lishment; and commissioning of independent verification of the company’s calculations of carbon reduction, as required under the Carbon Farming Initiative. The total annual costs of running the company are less than 10 per cent of its income.
Of fundamental importance to the company’s early ability to operate was the securing of ACCUs for retrospective abatements back to 2011, credited to ALFA in 2015 as a
Recognised Offset Entity under one of the earlier iterations of the Savanna Burning
Methodology. These retrospective credits recognised the carbon abatement created by

Table 2. ALFA total income, expenditure and profit/loss 2015–2019.
Year FY Income ($m) Expenditure ($m) Net result ($m)
2015* $7.4 5.6 +$1.763
2016 $0.4 0.7 −$0.3
2017** $6.9 7.5 −$0.6
2018** $10.7 10.5 +$0.2
2019** $5.5 6.3 −$0.8
Total $30.9 30.6 +0.2
*FY 2015 earnings include retrospective abatements to 2011.
** Inclusive of annual payments made under the 2006 WAFMA agreement.
10 J. ALTMAN ET AL.

Table 3. ALFA’s ACCUs verified and ERF commitments 2015–2019.
Year FY Total ALFA ACCUs ALFA ACCUs delivered to the ERF % of total delivered to ERF
2015 635,939* 0 0
2016 402,625 0 0
2017 819,528 204,000 25
2018 810,755 320,000 39
2019 348,347 230,000 66
Total 3,017,194 754,000 25
* includes retrospective abatements to 2011. the ALFA projects in the time since the passing of the CFI legislation and prior to project registrations. In enabling projects to backdate their baselines and project start dates, the
Australian government both recognised and adequately allowed for the time needed to undertake governance and business development, as well as the extensive consultations needed to gain the free, prior and informed consent of all traditional owner groups in
Arnhem Land. In the case of WALFA, it took almost four years to transition to a CFI- compliant entity. The retrospective carbon credits were sold at a premium price under the Labor government of Julia Gillard and it Emissions Trading Scheme. This income provided the critically important upfront capital base for the company in the 2014/15
financial year, which covered the initial operating funding of savanna burning by Abori- ginal ranger groups.
Table 3 summarises information about ALFA’s total accreditation of carbon credits, distinguishing commitments under 10-year contracts to the Emissions Reduction
Fund and carbon credits that can be sold to other markets. Annual accredited carbon credits fluctuate markedly (between 348,347 and 819,528 ACCUs) depending on climatic conditions and the performance of Aboriginal ranger groups. However, in no year to date has ALFA been in danger of facing a shortfall in meeting its long-term contractual obli- gations to Conoco Phillips and the ERF, as evident when comparing columns 2 and 3 from 2017 in Table 3.
The extent of ALFA’s operations year by year can be readily observed remotely on the easily accessible Northern Australia Fire Information website. But more concretely,
ALFA’s recent narrative annual report for the calendar year 2019 provides grounded information on the activities of each Aboriginal ranger group, as well as the totality of their efforts.28 It is reported quantitatively, that during the 2019 fire season, 14,326 km of early dry season ground burning using vehicles was undertaken, as well as 52,417 km of early dry season aerial burning deploying incendiaries. In respect of aerial burning, 177 traditional owners of the country being burnt accompanied helicopter pilots and Aboriginal rangers to direct the effort in accord with their local knowledge and customary authority. Ranger work in the late dry season focused on wildfire suppres- sion, with 97 wildfires being fought in 2019, requiring nearly 10,000 personnel hours and using a variety of fire-fighting tactics. Owing to unusual highly localised climatic con- ditions, a record 53 of these wildfires were located just within the Warddeken region
(Arnhem Land Plateau), and were being ignited by lightning till year’s end. All this activity is recorded by rangers using Cybertracker software, Global Positioning System
(GPS) way points, flight records, data sheets and work diaries. Further research revealing the points of view of traditional owners on these practices and their socio-environmental impacts is currently underway.
POSTCOLONIAL STUDIES 11

ALFA has been successful in meeting its contractual obligations in the last five years owing to its sound and participatory governance model and astute management. At the heart of its success is a constitution that is skilfully and collaboratively designed for purpose. Its drafters were individuals well-versed in managing Aboriginal corporations and cognisant of the need to adhere to principles of self-determination and project own- ership to ensure that key Aboriginal traditional owners were deeply engaged in the design of their company. As with the earlier WALFA, a combination of committed Indigenous and non-Indigenous conservation and business entrepreneurs crafted a constitution carefully designed to avoid any pitfalls around financial management and corporate gov- ernance. Indeed, the multiple regulatory regimes under which ALFA operates, including the Australian Securities and Investment Commission, the Australian Charities and Not for Profit Commission and the Clean Energy Regulator impose multiple levels of external accountability that require a high level of company discipline and compliance vigilance.
Of critical importance is the inclusiveness of the company offering membership to any traditional owner within its 80,000 sq. km area of operation. As noted earlier, member- ship nomination requires affiliation with one of eight membership classes or wards demarcated by the jurisdictions of each Aboriginal ranger groups. And each membership ward must elect two directors to the board. ALFA has an Aboriginal board representative of all its areas of operations – a devolved ‘bridging’ form of social capital29 across a con- siderable geographic jurisdiction. The ALFA area of operations can be conceptualised as a carbon commons that has resulted from the traditional owners of Arnhem Land com- bining their clan estates, each held under a restricted common property regime, and binding them to a common purpose.30 Such collaboration at once recognises the need for joined-up Western forms of company governance alongside the enduring customary pressures for localism and regional representation – especially as traditional owners of each membership ward use different Aboriginal languages or dialects and have diverse forms of social organisation. One of the co-authors, Dean Yibarbuk, is a member of one region (although he has traditional ownership rights in another) and would be reluc- tant to speak for traditional owners of others, in accord with extant Aboriginal custom.
But such representation across the region is of crucial importance given that the five project areas (and nine Aboriginal ranger groups) are contiguous, and effective savanna burning for emission avoidance requires collaboration and cooperation in plan- ning and execution.
ALFA’s commitment to sound participatory governance31 has seen it engage a long- term associate, Paul Josif, the principal of Savvy Community Development Consulting, to facilitate all its board meetings; and to engage in an ongoing programme of capacity building. A detailed Policies and Procedures Manual provides comprehensive guidance to directors, not just in relation to their roles and responsibilities but also about the div- ision of responsibilities between directors and management, and between directors and each Aboriginal ranger group. The directors focus on strategic direction, leadership and the culture and values of the organisation while the CEO is delegated authority to run the company. Anything that sits outside of business as usual – such as new projects, new partners and long-term financial agreements – is subject to resolution by the board.
Considerable attention is focused on financial management and income distribution.
The former sees operational and grant funding closely linked to commitments made in annual fire-management plans and the requirement to provide reporting information to
12 J. ALTMAN ET AL.

ALFA in a timely manner. The latter varies between projects and is dependent on whether the project is a collaborative project (that is, where there is more than one ranger group operating a single project). For WALFA and CALFA (with five and three partners respectively) the income is distributed in accordance with a formula that accounts for each group’s contribution to baseline emissions. To date all these distri- butions from ALFA have occurred amicably, without any recourse to dispute resolution.
All involved in the ALFA project are cognisant of the reality of ‘two laws’ or ‘two ways’ that permeates and complicates all aspects of politics in contemporary Arnhem Land32 – there are numerous overlapping institutional and jurisdictional spheres across a plethora of functional areas, with conservation and carbon emissions avoidance being just two.
Even ALFA’s five project areas and nine Aboriginal ranger groups take a variety of cor- porate forms, with the one critically important commonality being that all of Arnhem
Land is Aboriginal-owned and subject to management rights and responsibilities that accord with extant Aboriginal tradition and recognised in land rights and native title laws. And so, in all its activities, ALFA, as ‘no ordinary’ company, must continually tra- verse two domains.
ALFA manages this difficult task in part by delegating authority for much of its
Western ‘business’ and carbon accounting work to its CEO, a co-author of this article.
With science qualifications in ecology and natural resource management and a long history of engagement with many of the ranger groups in Arnhem Land, she supports the company in three crucial tasks: the management and reporting of information systems for the verification of emission reductions; the marketing of ACCUs; and, most importantly, the maintenance of governance relationships within the ALFA mem- bership. The stability that ALFA has enjoyed in its small staff establishment over the last
five years has been important. Jointly, the board and management have pursued a prudent, low-risk strategy that has seen it bed down as a company in an emerging indus- try in which the ‘rules of the game’ remain volatile. ALFA is no ordinary company because it has taken entrepreneurial initiative beyond business as usual: without ALFA and the level of fire management it underwrites there would be limited improvement in today’s historically high emissions from unmanaged wildfires, and traditional land- owners would have missed out on the opportunity to manage savanna burning on their lands to earn carbon credits. In the process, ALFA’s activities have arguably made Arnhem Land a net exporter of carbon credits, well beyond the carbon emissions generated by its estimated 18,000 Aboriginal and 4,000 non-Aboriginal residents.33

Emerging challenges
When ALFA was being established it was required to develop a business plan for consul- tations with traditional owners when seeking their free, prior and informed consent. The plan was prepared by interim CEO Ian Munro, who identified four threats and six risks.34
Five years on some of these threats and risks remain, and new concerns and critiques of prescribed fire management in the tropical savanna have emerged. We group these under four headings: climatic, financial, environmental and politico-cultural challenges.
On climatic challenges, in the past 13 years, Australian governments have overseen the development of two very different emissions reduction schemes. The first, which oper- ated from 2011 to 2014, was an emissions trading scheme, funded by polluters. The
POSTCOLONIAL STUDIES 13 second is an emissions reduction or avoidance scheme, operating since 2014, and funded by taxpayers. The aim of both is to avoid emissions and help Australia meet its Kyoto and now Paris targets and so assist in addressing the looming crisis of global warming. It is paradoxical that during ALFA’s first five years of operation, as it has reduced emissions by over 3 million tonnes of carbon dioxide equivalents, northern Australia has experi- enced rising temperatures that are predicted to escalate.35 We recognise climate change will generate additional challenges for Aboriginal ranger groups, especially in the costly and labour-intensive task of wildfire suppression during the late dry season.
The last two years demonstrate that under increasingly challenging climatic conditions
fire management becomes even more critical as a landscape-management tool. With escalating global warming and seasonal unpredictability, fire management will inevitably prove more resource intensive, and more costly to manage.
We note in passing that the climatic challenge could be exacerbated by the risk that exotic weeds, like the tall, dense and highly inflammable gamba grass (Andropogon gayanus), pose for fire management.36 Exotic weed infestations threaten the burning practice informed by customary ecological knowledge that predates such invasive species. Ensuring that project areas remain exotic weed free is an ongoing and critical challenge requiring continual vigilance by Aboriginal ranger groups.
These threats could combine to create a financial challenge for the company. This is especially the case as returns from the sale of carbon credits already fail to match the total economic cost of their production. ALFA contracts existing Aboriginal ranger groups to undertake the on-ground activities of prescribed burning and wildfire suppres- sion with the cost of the operation of functional remote ranger bases largely underwritten by the Australian government’s Indigenous rangers programme37 and a range of other sources, including environmental philanthropy. The emission reductions additionality that ALFA can deliver, funded by its operational allocations, is thus cross-subsidised by the Aboriginal ranger groups. Savanna burning delivers real and permanent avoided carbon emissions. But this is an expensive eligible activity that requires resource-intensive annual work (mainly owing to the necessary use of vehicles and helicopters) compared to other approved methods. Unfortunately, the market price for ACCUs, including issuance from the reverse auction (lowest-bid) Emissions Reduction Fund, does not reflect the rela- tively high cost of working in remote and rugged environments. There is an ongoing risk for ALFA that the escalating marginal cost of producing ACCUs owing to changes in sea- sonality, global warming and vegetation will exceed the income generated from their sale, especially under current lowest-cost abatement policies.
ALFA’s operations reduce carbon emissions and deliver an environmental good in terms of climate change mitigation. The environmental challenge for savanna burning is somewhat differently based on an expectation that biodiversity benefits are also gener- ated. Marcus Barber and Sue Jackson have recently undertaken a comprehensive review of the literature, identifying and categorising co-benefits generated by Indigenous environmental-management programs in Australia.38 Their analysis proposes a frame- work that includes environmental; health and well-being; social; cultural; political; and economic co-benefit categories. We do not propose to undertake a comprehensive analy- sis here of co-benefits from savanna burning. But we note that there is a clear expectation embedded in ALFA’s constitution that its carbon reduction activities will generate environmental, biodiversity, cultural, socioeconomic and educational co-benefits.39
14 J. ALTMAN ET AL.

A recent article by ALFA and Aboriginal ranger groups analyses the fire-management aspirations of traditional owners as interpreted by these groups (who all include land- owners).40 These aspirations are drawn from management plans and are summarised as a desire to continue the healthy fire management of country; see fewer wildfires; protect biodiversity; protect culturally important sites; maintain and transfer knowledge; and create carbon abatements. This indicates that for Aboriginal ranger groups, carbon avoidance is a lower order priority than other goals; and that the reduction of carbon emissions is seen as a means to an end rather than an end in itself. This matches
ALFA’s goals.
Another article by biological scientists asks whether savanna burning for emissions reduction is compatible with biodiversity conservation.41 The authors argue that biodi- versity co-benefits from environmental management with fire in the tropical savanna biome are assumed rather than demonstrated. They suggest that far better accounting is required of how biodiversity is responding to changed fire management undertaken on a regular annual basis to ensure that there are no unintended consequences, which they term ‘bioperversity’. It is noteworthy that while making these observations, these authors accept that late dry season wildfires are destructive, with poor outcomes for country and biodiversity. But with wildfires now largely reduced through the implemen- tation of fire-management regimes across much of northern Australia, these scientists are now advocating for more nuanced analyses of the effects of annual fires. Several solutions are proposed, including better monitoring of species likely to be impacted by fire timing, and the protection of fire-sensitive vegetation from annual burning.
We do not seek to comprehensively address such concerns here but make three obser- vations. First, we concur that greater biodiversity monitoring would allow for better accounting of the environmental impact of savanna burning. But such monitoring is expensive and rarely funded by government. We are all too aware of this as two of us are currently involved in fund-raising efforts for the mayh (animal species) monitoring project being undertaken on the Arnhem Land Escarpment by Warddeken Land Man- agement Limited. This project addresses the broader question of whether Warddeken’s resource management strategies (including prescribed burning) are impacting positively on biodiversity.42 Early results are promising. Warrdeken’s leadership in this area might see more widespread monitoring practice for all undertaking savanna burning.
Second, we note that the fire history data on the North Australia Fire Information site clearly shows what happens in the tropical savanna without planned burning. Indeed, it was on the back of evidence of late dry season wildfires, especially in uninhabited areas, that the case for the rigorous savanna burning methodology was based. In relation to
ALFA’s fire projects, there is no empirical evidence that savanna burning for carbon credits is having unintended negative consequences. The relevant counterfactual ques- tion is, what would be the impact of annual wildfires without prescribed burning? The historic baselines provide the answer – unacceptably high destruction of biodiversity.
Third, we caution that diplomacy is needed in raising such difficult questions to avoid reigniting debates between Aboriginal landowners and environmentalists that have his- torically marred relations between them.43 There is something a little colonial in empha- sising these legitimate concerns from a Western scientific context without adequate regard to the views of Aboriginal ranger groups. We say this at the same time as being acutely aware that in the Arnhem Land context it has been collaborations between
POSTCOLONIAL STUDIES 15

Western scientists and Indigenous landowners and practical ecologists over many years that has resulted in the pioneering savanna burning methodology. It is inequitable, in our view, to sheet home the onerous and expensive burden of proving biodiversity ‘co- benefits’ from savanna burning to under-resourced Aboriginal ranger groups.
Finally, we turn to what we term politico-cultural challenges, the possibility that tra- ditional landowners will become disaffected with savanna-burning projects. We note at the outset that extensive and expensive consultations were conducted with key members of about 300 land-owning groups to garner their free, prior and informed consent to savanna burning on their land. This process was overseen by legal and anthro- pological staff of the Northern Land Council and consent was provided for a period of seven plus seven years, with some projects now into the second period. We also note that the membership of ALFA is open to all traditional owners of project areas. And while ALFA has the exclusive rights to claim carbon credits for project areas, it has no authority to challenge the right of traditional owners to burn their country for customary or other purposes. As a rule, the seasonal burning by the traditional owners of occupied landscapes is complementary to the fire programs of ranger groups. But this is not always the case, as demonstrated with some of the fires lit in October 2019 by traditional owners on their country (referred to in the preamble).
It is important to recognise the rare instances of dissent. Some landowners believe that the outcomes from aerial incendiary burning are inferior to outcomes from fine-scale seasonal ground burning that replicates pre-colonial practice. We concur that the social, cultural and environmental benefits of being on country are enhanced with labour-intensive ground burning undertaken by walking, but this requires year-round occupation of the land and walking considerable distances to create fire lines. The unfor- tunate reality is that such an approach on its own is currently impractical over the 80,000 sq. km of Arnhem Land.
Some dissent might reflect intergenerational tensions over authority between senior landowners and a younger generation of Aboriginal rangers; or customary tensions between the valorisation of landowner autonomy, the highly valued right to do as one wishes on one’s land, and the contemporary need for planned burning to be undertaken seasonally. Elodie Fache and Bernard Moizo, for example, report tensions between the
Yugul Mangi Rangers and traditional landowners in southeast Arnhem Land over per- ceived inappropriate prescribed burning.44 But their reporting predated the establish- ment, with traditional owner approval, of the South East Arnhem Land registered project.
Coming from an anthropological perspective and focusing on ‘power relations and ambivalences’, Fache and Moizo raise a similar question as the Western biological scien- tists and some traditional owners, asking if contemporary burning regimes contribute to positive ecological outcomes, ‘caring for country’. In their research they also trouble the idea that while contemporary savanna burning is informed by traditional knowledge and practice, it is operationalised in a very different postcolonial context of global warming, climate change and a carbon economy. This is an issue that also concerns some tra- ditional owners: to what extent is tradition embedded in contemporary fire regimes that are highly dependent on modern technology? A response to such concerns is pro- posed in considering similar issues raised by Aaron Petty, Vanessa deKoninck and
Ben Orlove, whose research in Kakadu National Park indicates that traditional owners feel marginalised by fire-management regimes dominated by Western scientific and
16 J. ALTMAN ET AL. technocratic discourse. With specific reference to WALFA, they ask if Aboriginal ranger groups will be able to retain control and some degree of autonomy over fire-management programs committed to meet emissions reductions underwritten by a funding model measured by complex emission accounting methods.45
The answers are twofold. First, ALFA’s highly participatory governance model recog- nises that individual traditional owner groups retain primary and autonomous rights on their clan estates. Ultimately, any traditional owner group can exercise their statutorily guaranteed customary right to burn. Traditional owner groups also direct their affiliated Aboriginal ranger programs in terms of appropriate fire management on indi- vidual estates. If traditional owners are disaffected, they can activate dispute resolution mechanisms in ALFA’s constitution and/or exercise their legal right not to renew s.19 land use agreements at the completion of the current agreement period. To date there is no indication that this will happen. Second, in planning processes, ALFA and Abori- ginal ranger groups clearly manage the commodification of savanna burning; such con- trolled commodification is evident in the conservative limits that have been set on current long-term sales contracts.

ALFA as postcolonial possibility: three perspectives
Arnhem Land is an unusual jurisdiction in the Australian settler colonial context. Its nearly 100,000 sq. km is all Aboriginal owned, and over 80 per cent of the population is Aboriginal. Despite this exclusive land ownership, Indigenous people in this region are still living in deep poverty by the standards of the encapsulating society and economy, with over 50 per cent of the population recently estimated to live below the poverty line.46 But this land has high environmental values; and extractive forms of capit- alism only operate at the western and eastern extremities of Arnhem Land, a uranium mine to the west due for closure in 2021, and bauxite mines to the east at Gove due for closure in the next decade. The coverage of almost all of Arnhem Land by Indigenous
Protected Areas attests to the region’s high conservation values according to global cri- teria, which in turn raises questions about how these values might be converted into live- lihood benefits that accord with the aspirations of landowners. While in the Australian context Aboriginal landowners residing in Arnhem Land lack political sovereignty, they do exercise a degree of economic jurisdiction, represented by their property rights in the land and natural resources; and statutory regimes are in place requiring tra- ditional owners’ consent to any development. In our view, such economic jurisdiction opens a degree of postcolonial possibility, with one such possibility represented by the carbon farming activities of ALFA. In the past five years ALFA has earned $31 million through the sale of a ‘crypto’ commodity, ACCUs, to the Australian government and in other carbon markets. Almost all of ALFA’s income has been provided to Aboriginal ranger groups to create new jobs and facilitate enhanced savanna-burning regimes. We make these comments for two reasons. First, ALFA is an exemplar of how Aboriginal property rights in emission avoidance can be financialised by a wholly owned Aboriginal company. Second, we note that while ALFA’s operations represent a form of postcolonial possibility, they alone will not provide the solution to the livelihood needs of all – carbon reduction will be just one activity in a suite if there is to be a significant impact on con- temporary poverty.
POSTCOLONIAL STUDIES 17

ALFA’s performance to date, and prospects, can be assessed according to several per- spectives beyond that of financial viability, the dominant metric applied to for-profit companies. We seek to briefly provide three alternative perspectives on postcolonial possibility from Indigenous, ecological and developmental standpoints that reflect our diverse expertise (see Notes on Contributors).
The Indigenous perspective indicates that the membership and board of ALFA and the Aboriginal ranger group partners with whom the company contracts and collaborates are highly supportive of its activities. ALFA revenue facilitates the management of country with fire, especially empty country that has experienced landscape-scale destruc- tive wildfires. For example, the early resourcing of WALFA from the corporate sector provided funds that facilitated the repopulation of what had been termed ‘orphaned’ country. The emotion that the term ‘orphaned’ evokes reflects Aboriginal sadness for country that is abandoned and unloved in the highly relational worldview of the
Bininj people. Orphaned country is uncared for and unkempt country, while involve- ment in savanna burning affords an opportunity to ‘care for country’ with judicious sea- sonal burning. As people who now live on and visit country, many Aboriginal landowners, especially those working as rangers, have deep ecological and local experi- ential knowledge of the many co-benefits generated by prescribed burning. Earnings from the sale of ACCUs facilitate employment and residence on country, and provide future pathways that will see the transfer of ecological knowledge from the current gen- eration to the next. This is an imperative for many who saw Indigenous forms of ecologi- cal knowledge jeopardised during the disempowering colonial era. ALFA today is empowering contemporary Aboriginal values and aspirations to retain the cultural and environmental values of the land using an age-old tool, managed fire, as well as new tools for landscape burning and fire suppression. ALFA’s ‘fire money’ also funds essential programs and equipment that assist broader environmental work, such as weed control, which also helps manage wildfires.
From a Western ecological perspective, fire management in Arnhem Land resourced through ALFA’s engagement with the carbon industry, has successfully addressed the prevalence of hot, widespread and destructive wildfires in the landscape – a threat to the environmental assets of northern Australia recognised in both Aboriginal and
Western science knowledge systems.47 A significant challenge for the future will be main- tenance and continued improvement in fire management, particularly in the face of climate change. Climate change projections in northern Australia include an increase in the number of extreme heat days alongside an increase in the intensity and frequency of droughts, changes to freshwater availability and a loss of freshwater ecosystems.48 All these impacts will have considerable effects on fire behaviour in the landscapes in which the savanna-burning projects operate, and will likely make landscape-scale fire manage- ment more challenging and resource intensive. However, it will be more critical than ever for fire management to persist and adapt to these changing conditions to support the resilience of natural systems in response to climate change. In the longer term, govern- ments may need to more realistically underwrite the escalating costs of such activities or price ACCUs differentially to more accurately reflect the cost of their production.
The successful operation of the savanna-burning projects in Arnhem Land, and the development of the Aboriginal carbon industry more broadly, clearly illustrate an environmental-management opportunity. In under ten years, engagement with this
18 J. ALTMAN ET AL. opportunity has grown not only within Arnhem Land but across Aboriginal and non-
Aboriginal land in northern Australia.49 Are there other possibilities for ALFA to engage in continued modifications of carbon accounting methods, as well as the devel- opment of other environmental market-based instruments to effect and maintain posi- tive environmental change? Regarding emissions reduction, recent policy discussions and analysis of future opportunities focus around making existing industries more energy efficient, and this is indeed important. However, there are also opportunities for emissions avoidance that are not covered by approved methodologies. For example, the reduction of feral ungulate animal herds (like buffalo) in northern Australia would create significant opportunities for emissions reduction as well as improvements in environmental condition.50 However, the emissions from feral animal herds are not currently included in Australia’s National Greenhouse Gas Inventory. Specifically, in relation to savanna burning, there are also existing and additional sequestration method- ologies recognising and accounting for the carbon storage in dead organic matter and living biomass associated with changed fire regimes away from wildfires. It is estimated that these methods could considerably increase the supply of carbon credits to registered
fire projects.51
From the perspective of Indigenous-led development, and given the ongoing failure of mainstream forms of development to meet the livelihood needs of people in Arnhem
Land, ALFA’s activities represent an important alternative. Here we see people deploying their land ownership and native title rights and interests for the wellbeing of individuals, families and communities. This exercise of rights is predicated on carbon credits being legally recognised as a form of property, and an Indigenous-owned and -controlled company being entrusted with the monopoly right to engage in savanna burning in the interests of its members. Twenty years ago, an ALFA-like project was already being promoted as an important element of hybrid forms of productive economy that deploy customary knowledge and rights alongside engagement with the state and the market.52 Initially WALFA engaged with multinational corporation ConocoPhillips on an offsets basis. Later, the Australian government came to the party. This slow process has allowed Aboriginal stakeholders in ALFA to incrementally engage with the controlled commodification of carbon credits, now sold into several markets. ALFA’s developmen- tal success has been based on an active collaboration between landowners, Aboriginal ranger groups and non-Indigenous science experts and entrepreneurs. While ALFA will not be the sole source of livelihoods for all landowners in Arnhem Land, it is making a positive difference. Fundamental to its operations to date is a corporate struc- ture carefully crafted to ensure the commitment of income to environmental goals. The specific Indigenous form of participatory governance that guides ALFA’s operations, always cognisant of landowner authority, is fundamental to its ability to support forms of Aboriginal-led development focused on conservation.

Conclusion
We began this article with a preamble that reflected on recent evidence of rapid climate change and the 2020 Black Summer bushfires in southeast Australia; it is estimated that
650 million to 1.2 billion tonnes of carbon dioxide were added into the atmosphere by these bushfires to Australia’s annual emissions of 531 million tonnes.53 ALFA at best
POSTCOLONIAL STUDIES 19 is reducing measured emissions by 800,000 tonnes per annum and its future sequestra- tion activities might add several times that amount in recognised carbon storage. This is a fraction of what is needed to avert climate disaster, but it is a contribution by an Abori- ginal-owned company commodifying savanna burning in a controlled way, and deploy- ing a mix of customary Aboriginal expertise in conjunction with late-capitalist technology to manage fire and monitor outcomes. Postcolonial possibility emerges from the ability of this ‘no ordinary’ company to build upon the ‘no ordinary judgment’54 of the High Court in Mabo and earlier land rights law to generate environmental, social, cultural and economic benefit for its members. ALFA does this by organising the care- fully planned production and sale of a recently recognised legal form of property:
‘carbon credits’. Despite the unprecedented uncertainties of the present and the many challenges it faces, ALFA is an actually existing and quite extraordinary company. It benefits from an emerging postcolonial possibility in the form of payment for savanna burning that it has been instrumental in developing, establishing and now successfully operating in twenty-first-century Australia.

Notes
1. Available at: https://www.9news.com.au/national/darwin-has-second-hottest-day-at-38-2c/
02715498-52fa-44c5-8352-dd625d06c20f (accessed 20 May 2020).
2. The North Australia Fire Information site was developed by Peter Jacklyn of Charles Darwin
University as a ‘real time’ fire tracking tool, providing satellite maps of active fires and com-
prehensive information on fire history over the past 20 years across the north. See https://
www.firenorth.org.au/nafi3/ (accessed 20 May 2020).
3. Jennifer Ansell ‘Challenging 2019 Fire Season: ALFA NT’, Land Rights News Northern
Edition, December 2019/January 2020. Available at: https://www.nlc.org.au/uploads/pdfs/
LRN-WEB-DEC-2019.pdf (accessed 10 June 2020).
4. Available at: https://www.abc.net.au/news/2020-04-24/dry-in-the-top-end-of-australia-
and-rain-expected-in-the-south/12172258 (accessed 20 May 2020).
5. See recording at https://www.youtube.com/watch?v=6L_KAZqNWKQ&feature=emb_title
(accessed 20 May 2020).
6. Jeremy Russell-Smith, Peter Whitehead and Peter Cooke (eds), Culture, Ecology and
Economy of Fire Management in Northern Australian Savannas: Rekindling the Wurrk Tra-
dition, Melbourne: CSIRO Publishing, 2009.
7. Jon Altman and Sean Kerins (eds), People on Country, Vital Landscapes, Indigenous Futures,
Sydney: The Federation Press, 2012.
8. The term ‘intercultural’ is used to reflect that contemporary Aboriginal social norms, even in
remote Arnhem Land, comprise a mix of customary and Western social norms and values.
See Melinda Hinkson and Ben Smith, ‘Introduction: Conceptual Moves Towards an Inter-
cultural Analysis’, Oceania 75(3), 2005, pp 157–166.
9. There are currently five markets: the ERF; the secondary market (selling to someone else to
fill their ERF contract); the safeguard mechanism, any polluters that go over their safeguard
baseline; the voluntary market; and to companies stockpiling.
10. Section 150 of the Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act 2011). This
section resolves long-standing questions about who holds property rights in carbon abated.
11. Originally WALFA was conceived by scientists at the Darwin-based Tropical Savanna Man-
agement Cooperative Research Centre as an Arnhem Land-wide project to abate a
minimum 300,000 tonnes of carbon annually. But after failing to garner support from the
Australian Greenhouse Office, the project was spatially scaled back and instead sought to
attract corporate support.
20 J. ALTMAN ET AL.

12. Nonie Sharp, No Ordinary Judgment: Mabo, the Murray Islanders Land Case, Canberra:
Aboriginal Studies Press, 1996.
13. There was diverse contact experience across this massive region. In southern Arnhem Land
and in the gulf country that borders the pastoral zone there was considerable frontier vio-
lence, as outlined in Tony Roberts in Frontier Justice: A History of the Gulf Country to 1900,
Brisbane: University of Queensland Press, 2005.
14. Dean Yibarbuk, ‘Notes on Traditional Use of Fire in Upper Cadell River’, in Marcia Langton
(ed.), Burning Issues: Emerging Environmental Issues for Aboriginal People in Northern Aus-
tralia, Darwin: Centre for Indigenous Natural and Cultural Resource Management, North-
ern Territory University, 1998, pp 1–6. 1998 and Dean Yibarbuk, Peter Whitehead, Jeremy
Russell-Smith, Donna Jackson, Charles Godjuwa, Alaric Fisher, Peter Cooke, David Cho-
quenot and David Bowman, ‘Fire Ecology and Aboriginal Land Management in Central
Arnhem Land, Northern Australia: A Tradition of Ecosystem Management’, Journal of Bio-
geography 28, 2001, pp 325–344.
15. Murray Garde in collaboration with Bardayal Lofty Nadjamerrek, Mary Kolkkiwarra, Jimmy
Kalarriya, Jack Djandjomerr, Bill Birriyabirriya, Ruby Bilindja, Mick Kubarkku and Peter
Biless ‘The Language of Fire: Seasonality, Resources and Landscape Burning on the
Arnhem Land Plateau’ in Jeremy Russell-Smith, Peter Whitehead and Peter Cooke (eds),
Culture, Ecology and Economy of Fire Management in Northern Australian Savannas:
Rekindling the Wurrk Tradition, Melbourne: CSIRO Publishing, 2009, pp. 85–164.
16. Garde et al. ‘The Language of Fire’, p 95; Chris Haynes, The Pattern and Ecology of Manwag:
Traditional Aboriginal Fire regimes in North-central Arnhem Land’, Proceedings of the Eco-
logical Society of Australia, 13, 1985, pp 203–214; Jon Altman, Hunter-Gatherers Today: An
Aboriginal Economy in North Australia, Canberra: Australian Institute of Aboriginal
Studies, 1987, p 25.
17. Jeremy Russell-Smith, Peter Whitehead and Peter Cooke, Culture, Ecology and Economy of
Fire Management in Northern Australian Savannas.
18. See Nicolas Peterson and Fred Myers (eds), Experiments in Self-Determination: Histories of
the Outstation Movement in Australia, Canberra: ANU Press, 2016.
19. For Indigenous and non-Indigenous perspectives on this movement, see Jon Altman and
Sean Kerins People on Country.
20. Russell-Smith, Whitehead and Cooke Culture, Ecology and Economy of Fire Management in
Northern Australian Savannas. The three co-editors were key proponents of WALFA, with
fire ecologist Jeremy Russell-Smith; biological scientist Peter Whitehead; and Peter Cooke,
who initiated the Caring for Country Unit at the Northern Land Council.
21. For another historical accounts, see Aboriginal and Torres Strait Islander Social Justice
Commissioner, ‘Study: Western Arnhem Land Fire Management’, in Native Title Report
2007, Report No. 2, Sydney: Human Rights commission, 2008, pp 257–275.
22. Peter Cooke, ‘Social Capital and the Creation of an Innovative Environmental and Cultural
Enterprise in Arnhem Land’, in Jeremy Russell-Smith, Glenn James, Howard Pedersen and
Kamaljit Sangha (eds), Sustainable Land Sector Development in Northern Australia: Indigen-
ous Rights, Aspirations and Cultural Responsibilities, Boca Raton, FL: CRC Press, 2019, pp
120–123.
23. Cooke, ‘Social Capital’, p 121.
24. Carbon Credits (CFI) (Reduction of Greenhouse Gas Emissions through Early Dry Season
Savanna Burning – 1.1) Methodology Determination in 2013 by the Gillard government and
then the Carbon Credits (CFI – Savanna Fire Management – Emissions Avoidance) Meth-
odology Determination in 2015 by the Abbott government.
25. A minor difference is the SEALFA IPA that has two Aboriginal ranger groups and so the
membership class is the IPA jurisdiction not the area delineated by the operational jurisdic-
tion as is the case with the other seven Aboriginal ranger groups.
26. Jennifer Ansell, Jay Evans, Adjumarllal Rangers, Arafura Swamp Rangers, Djelk Rangers,
Jawoyn Rangers, Mimal Rangers, Numbulwar Numburindji Rangers, Warddeken
Rangers, Yirralka Rangers and Yugul Mangi Rangers ‘Contemporary Aboriginal Savanna
POSTCOLONIAL STUDIES 21

Burning Projects in Arnhem Land: A Regional Description and Analysis of the Fire Manage-
ment Aspirations of Traditional Owners’, International Journal of Wildland Fire 29, 2020 pp
371–385.
27. See Ansell et al., ‘Contemporary Aboriginal Savanna Burning Projects’.
28. Arnhem Land Fire Abatement (NT) Limited, Annual Report 2019, Darwin: ALFA, 2020.
29. Robert Putnam, Bowling Alone. New York: Simon and Schuster Paperbacks, 2000.
30. The Arnhem Land Aboriginal Land Trust is an unusual form of inalienable freehold title
whereby traditional owners of patrilineal clan estates have primary collective authority
over what happens on their land. We use the term ‘limited common property’ in the
sense that insiders can exclude outsiders but insider rights are held in common. See
Carol Rose, ‘Economic Claims and the Challenges of New Property’, in Katherine
Verdery and Caroline Humphrey (eds), Property in Question: Value Transformation in
the Global Economy, Oxford: Berg, 2004, pp 275–295.
31. For an extended discussion of participatory governance models, see Joel Krupa, Lindsay
Galbraith and Sarah Burch, ‘Participatory and Multi-level Governance: Applications to
Aboriginal Renewable Energy Projects’, Local Environment 20(1), 2015, pp 81–101.
32. See, for example, Nancy Williams, Two Laws: Managing Disputes in a Contemporary Abori-
ginal Community, Canberra: Australian Institute of Aboriginal Studies, 1987.
33. A third, which receives little attention, is that the carbon abatement activity of the producer
groups in the ALFA consortium more than offsets all of Arnhem Land’s non-industrial anthro-
pogenic carbon emissions by an estimated 20,000 people, even when calculated using the
average Australian per capita carbon footprint of about 26 tonnes per capita per annum.
34. Ian Munro, ‘ALFA (NT) Limited Business Plan 2015–2019’, unpublished consultancy
report, Darwin: ALFA, 2014.
35. Elizabeth Hanna and Mark Ogge, Cooked with Gas, Extreme Heat in Darwin, Canberra: The
Australia Institute, 2018. Available at: https://www.tai.org.au/sites/default/files/P510%
20Cooked%20with%20gas%20-%20Darwin%20days%20over%2035C%20FINAL.pdf
(accessed 10 June 2020).
36. Tim Neale and Jennifer Macdonald, ‘Permits to Weed: Weeds, Slow Violence and the
Extractive Future of Northern Australia’, Australian Geographer 50(4), 2019, pp 417–433.
37. The Working on Country program was launched by the Australian government in 2007 and
provides funds for the wages of Indigenous rangers especially in Indigenous Protected
Areas. For some reason, since 2019 the name of the program has changed to the bland Indi-
genous Ranger Projects. See https://www.niaa.gov.au/indigenous-affairs/environment/
indigenous-rangers-working-country (accessed 28 May 2020).
38. Marcus Barber and Sue Jackson, ‘Identifying and Categorising Cobenefits in State-sup-
ported Australian Indigenous Environmental Management Programs: International
Research Implications’, Ecology and Society 22(2), 2017, DOI: 10.5751/ES-09114-220211.
39. Paragraphs 5.1 to 5.5 of the Constitution of ALFA (NT) Limited, a company limited by guar-
antee under the Corporations Act 2001.
40. Ansell et al. ‘Contemporary Aboriginal Savanna Burning Projects’.
41. Ben Corey, Alan Andersen, Sarah Legge, John Woinarski, Ian Radford and Justin Perry,
‘Better Biodiversity Accounting is Needed to Prevent Bioperversity and Maximize Co-
benefits from Savanna Burning’, Conservation Letters, 2019, DOI: 10.1111/conl.12685.
42. Warddeken Land Management Limited, Annual Report 2018–19, Darwin: Warddeken Land
Management Limited, 2020.
43. See Eve Vincent and Tim Neale (eds), Unstable Relations: Indigenous People and Environ-
mentalism in Contemporary Australia, Perth: UWA Press, 2016.
44. Elodie Fache and Bernard Moizo, ‘Do Burning Practices Contribute to Caring for Country?
Contemporary Uses of Fire for Conservation Purposes in Indigenous Australia’, Journal of
Ethnobiology 35(1), 2015, pp 163–182.
45. Aaron Petty, Vanessa deKoninck and Ben Orlove ‘Cleaning, Protecting or Abating? Making
Indigenous Fire Management “Work” in Northern Australia’, Journal of Ethnobiology 35(1),
2015, pp 140–162.
22 J. ALTMAN ET AL.

46. Francis Markham and Nicholas Biddle, ‘Income, Poverty and Inequality’, CAEPR 2016
Census Paper No. 2, 2018. Available at: https://caepr.cass.anu.edu.au/sites/default/files/
docs/CAEPR_Census_Paper_2.pdf (accessed 10 June 2020).
47. See, for example, Garde et al., ‘The Language of Fire’, and Jay Evans and Jeremy Russell-
Smith ‘Delivering Effective Savanna Fire Management for Defined Biodiversity Conserva-
tion Outcomes: An Arnhem Land Case Study’, International Journal of Wildland Fire 29
(5), 2020, pp. 386–400.
48. CSIRO and Bureau of Meteorology 2015, Climate Change in Australia Information for Aus-
tralia’s Natural Resource Management Regions: Technical Report, CSIRO and Bureau of
Meteorology, Australia.
49. Commonwealth of Australia ‘Emissions Reduction Fund Project Register’. Available at:
http://www.cleanenergyregulator.gov.au/ERF/project-and-contracts-registers/project-
register (accessed 16 June 2020).
50. North Australian Land and Sea Management Alliance ‘Abatement of Methane Emissions
from Enteric Fermentation in Feral Buffalo, Bubalus Bubalis, by Sustained Reduction of
Populations in North Australian Savannas’, submitted as a draft methodology under the
Carbon Farming Initiative, Darwin, January 2014.
51. Peter Whitehead, Brett Murphy, Jay Evans, Cameron Yates, Andrew Edwards, Harry
McDermott, Dominique Lynch, and Jeremy Russell-Smith, ‘Recruitment, Growth and Mor-
tality of Savanna Trees in Northern Australia: The Effects of Fire Regimes on Living
Biomass’, Ecological Monographs (in revision), 2020.
52. Jon Altman ‘Sustainable Development Options on Aboriginal Land: The Hybrid Economy
in the Twenty-first Century’, Discussion Paper 226/2001, Canberra: Centre for Aboriginal
Economic Policy Research, the Australian National University, 2001.
53. Lesley Hughes, Will Steffen, Greg Mullins, Annika Dean, Ella Weisbrot and Martin Rice,
‘Summer of Crisis Climate Council of Australia Limited, 2020. Available at: https://www.
climatecouncil.org.au/wp-content/uploads/2020/03/Crisis-Summer-Report-200311.pdf
(accessed 10 June 2020).
54. Sharp, No Ordinary Judgment.

Acknowledgements
We thank Peter Cooke, Dan Gillespie and Ian Munro for comments on an earlier draft, important input from Joe Morrison and Jeremy Russell-Smith in recent conversations, and the constructive comments of two reviewers. All views expressed and any errors are ours.

Disclosure statement
The authors have known each other and collaborated on a diversity of projects for several decades.
Jon Altman is a foundation director of the Karrkad-Kanjdji Trust that benefits from the operations of ALFA. Jennifer Ansell is the CEO of ALFA; the company pays her a salary. Dean Yibarbuk is the
Chair of Warddeken Land Management Limited and deputy chair of the Karrkad-Kanjdji Trust, both of which benefit from the operations of ALFA, and is a member and director of ALFA. Con- versely, the Karrkad-Kanjdji Trust financially supports three of the participating Aboriginal ranger groups in two of ALFA’s five project areas. In March 2020 the ALFA board endorsed our collab- oration in this research, but some information we have accessed remains subject to ALFA’s confi- dential information policy.

Notes on contributors
Jon Altman is an economic anthropologist who is currently an emeritus professor at the School of
Regulation and Global Governance at the Australian National University. Jon has worked with
POSTCOLONIAL STUDIES 23

Aboriginal landowners in western Arnhem Land for over 40 years, focusing his research on liveli- hood possibilities in regional ‘hybrid’ economies that people might exercise as they struggle for forms of postcolonial autonomy while encapsulated within the Australian settler colonial state.
His research engages with landowner aspirations to create alternative forms of conservation economy and with the regulatory, governance and resourcing challenges that they must overcome.
Jennifer Ansell was appointed CEO of ALFA in 2015. Jennifer has a background in ecology, natural resource management, and community and business development. For the last 20 years, Jennifer has been living in the Top End of the Northern Territory and working with Aboriginal ranger groups and traditional owners on a diverse array of projects, including participatory ecological research, healthy country planning and wildlife enterprise development, as well as social and enter- prise opportunities for Aboriginal women. She completed a PhD through Charles Darwin Univer- sity in 2007 that examined the sustainability of harvesting timber for the Aboriginal art industry in central Arnhem Land.
Dean Yibarbuk is a respected Aboriginal fire ecologist of long-standing repute. He was born on
Gurrgoni country (Andirridjalaba patri-clan) prior to permanent colonial incursion into central
Arnhem Land. Dean is a champion of Indigenous-controlled management of fire and biodiversity.
In the early 1990s Dean was the driving force behind the formation of the Djelk community rangers in Maningrida; in the early 2000s, he shifted his focus to the largely depopulated
Arnhem Land Escarpment and assisted in the formation of Warddeken Land Management
Limited and the West Arnhem Land Fire Abatement project, as well as the establishment of the remote community of Kabulwarnamyo.