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Monday 31 January 2022
Soils and Vegetation Team
Department of Industry, Science, Energy and Resources
Via email: ERFForests@industry.gov.au
Dear Soils and Vegetation Team,
CONSULTATION: ERF NATIVE VEGETATION REGENERATION PROJECTS RULE CHANGE
Thank you for the opportunity to provide feedback on the potential changes to the Carbon Credits (Carbon Farming
Initiative) Rule 2015 (the Rule) to introduce a new category of excluded offsets projects under the Emissions
Reduction Fund (ERF) and to improve monitoring of compliance with rules to manage pests and weeds.
Corporate Carbon is actively engaged across all major sectors of the ERF. We value the efforts made by the
Department of Industry, Science, Energy and Resources to consult on a proposed Rule change which aim to
approve operation of the scheme and avoid unintended outcomes ERF projects.
Our specific comments in relation to the proposed Rule are provided in the attachment below. Please let me know if I
can provide any additional information in relation to this submission, or if you would like to discuss this submission in
further detail.
Sincerely,
Gary Wyatt
Managing Director
Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543 Suite 4, Level 16/25 Bligh St, Sydney NSW 2000 AFS Licence No:
430199 1300 227 206 info@corporatecarbon.com.au www.corporatecarbon.com.au
COMMENTS:
1. THE NEED FOR THE RULE CHANGE
In proposing the amendments to the Rule, the Department of Industry, Science, Energy and Resources (the
Department) states that:
“… it is important to ensure that such projects do not have unintended adverse effects on local communities
through inadequate management of weeds, pests and fire risks, or through negative impacts on agricultural
production or regional communities.”
While we support this statement, no evidence is offered (or to our knowledge has been gathered) that supports
the notion that the project types in question cause these undesirable outcomes. The Department simply states
that “Concerns have been raised in particular in regions …”.
In our view this is not adequate justification to substantial Rule changes to the scheme. Data properly defining
the potential shortcomings (if any) with the projects in question should be collected and analysed before
proceeding with any proposed Rule changes. Furthermore, this data should be used to design the corrective
actions in order to ensure the relevant problems are being addressed.
Proceeding with the proposed Rule change without proper analysis of the problems to be addressed (if indeed
there are any causative and material problems) is poor policy formation and is unlikely to achieve the desired
policy outcomes.
2. CARBON INDUSTRY ENGAGEMENT
Australia has an emerging carbon project development industry that has been revitalised by a high local carbon
spot price for ACCUs and international developments at Glasgow COP26. The peak body for this industry is
the Carbon Market Institute (CMI). The CMI and project developers have introduced a world leading Australian
Carbon Industry Code of Conduct. This attests to industry’s desire to undertake and implement carbon projects
in a manner that avoids unintended detrimental outcomes.
For reasons that are not immediately obvious, the proposed Rule has not been developed in consultation with
the CMI or carbon industry. We believe that if industry had been properly consulted in a timely manner, an
alternative more effective approach to dealing with the perceived shortcomings of the projects in question could
have been identified.
In fact, the carbon industry did have a process under way to identify and quantify any potential shortcomings of
the projects in question, but this has been short-circuited by the overly hasty introduction of this proposed Rule
change. Unfortunately, this increases the likelihood of perverse outcomes arising from a lack of due process.
A more productive approach would be to use the framework of the Australian Carbon Industry Code of Conduct
and engage with members on pro-active measures to amplify positive co-benefits arising from ERF project
implementation.
Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543 Suite 4, Level 16/25 Bligh St, Sydney NSW 2000 AFS Licence No:
430199 1300 227 206 info@corporatecarbon.com.au www.corporatecarbon.com.au
3. ENVIROMENTAL OUTCOMES ON RURAL LANDHOLDINGS
One of the stated goals of the proposed Rule change is to avoid material adverse impacts on agricultural
production. Firstly, this implies that delivery of environmental outcomes on rural landholdings (in this case
carbon sequestration) is somehow not an acceptable economic activity and is inferior to agricultural production.
This is an outdated notion which we reject and encourage the Department to move beyond.
Secondly, the Rule as drafted will slow the development of innovative technology in agriculture to deliver both
production and environmental outcomes. In the future, a strong and resilient rural economy will be built on
achieving both commercial and environmental goals together. Some forward-thinking Australia agricultural
producers are set to become global leaders in delivering this model, such as Packhorse Pastoral
(https://packhorse.net.au/).
Through the proposed Rule change, the Department risks hindering the efforts of many to sustainably innovate
in agriculture and as such should reconsider its approach.
4. IMPACT ON INVESTMENT
As we have pointed out above, the proposed Rule change is not evidence based, has not been developed in
consultation with industry and makes a false choice between agricultural production and environmental
outcomes.
These shortcomings in the proposed Rule are negatively perceived by potential investors in emissions reduction
projects (including international investors) owing to the undermining in scheme confidence caused by ‘knee-jerk’
responses in program administration. This undermining of confidence risks dampening investor interest in the
ERF beyond just these project types. This in turn will make abatement outcomes more expensive and
decarbonising the Australian economy harder to achieve.
Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543 Suite 4, Level 16/25 Bligh St, Sydney NSW 2000 AFS Licence No:
430199 1300 227 206 info@corporatecarbon.com.au www.corporatecarbon.com.au
