Published name
Upload a submission
Comment on the proposed requirements for native vegetation regeneration projects to notify potential impacts to regional agriculture
Comments by Peter Ritson (FarmWoods)
Date 14 January 2021
Introduction
The following are comments on the Consultation Paper Proposed amendments to the Carbon Credits (Carbon Farming Initiative) Rule 2015 relating to Emissions Reduction Fund native vegetation regeneration projects.
Consistency across methods
It is suggested there should be consistency across all ERF reforestation methods for notifying potential impacts to regional agriculture and actions to be implemented to manage risks, i.e. including the following methods.
Human-induced regeneration
Native forests from managed regrowth
Plantation Forestry
Farm Forestry
Reforestation and Afforestation
Reforestation by Environmental or Mallee plantings.
Currently, only the Plantation Forestry and Farm Forestry methods have notification requirements. However, these methods apply to reforestation managed for timber or other forest products as well as carbon revenue. Hence, there is a strong incentive to actively manage the reforestation for good growth (carbon sequestration) and to reduce risks of fire, pests, weeds and diseases. Hence, it seems logical that Plantation Forestry and Farm Forestry methods should have the least need for notification requirements.
Other reforestation methods do not require the same level of on-going management, e.g. environmental plantings are often ‘plant and leave’ operations and are most likely to have absentee landowners.
Methods that rely on FullCAM for accounting provide little incentive for responsible management as the model does not account for how well risks are managed.
Scale for potential exclusion
The Consultation Paper mentions that the proposed new exclusions would allow the Agriculture Minister to exclude HIR or NFMR projects that are bigger than 15 hectares and make up more than a third of a farm.
This seems like a good rule, particularly if only projects that exceed that scale are required to submit a notification.
It would be helpful if the same rule could be applied to Plantation Forestry and Farm Forestry projects. Currently these projects are required to submit notifications for any scale of project. For Plantation Forestry projects it is understood that notifications are only required for ‘New Plantation’ activity not ‘Conversion’ activity. Thus, as has been our experience, a proposed project that has hundreds of hectares of Conversion activity but minimal New Plantation activity (less than 10 hectares) still requires a Notification for Agriculture Minister consideration.
Fire Management
As well as managing pests and weeds, adequate fire management should be a requirement for reforestation projects. Wildfires have the potent to spread onto neighbouring farms threatening life and property. The problem may be most acute where whole farms are purchased for carbon projects and the there is no resident landowner or resident land manager. In that situation there will be a limited capacity to detect and respond to fires starting on the property. Also rural fire brigades that commonly rely on volunteers from people living in the district may struggle to find the support they need.
Forest Management Plans
Another recommendation is that all proposed reforestation projects of more than one third of a farm should submit a detailed Forest Management Plan or equivalent document as part of the Notification for Agriculture Minister consideration. The FMP should include a detailed Fire Management Plan and plans to manage other risks including pests, weeds, diseases and soil erosion.
