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31 January 2022
Department of Industry, Science, Energy & Resources (DISER)
To whom it may concern,
Re: Submission to consultation paper detailing proposed amendments to the Carbon
Credits (Carbon Farming Initiative) Rule 2015 relating to Emissions Reduction Fund
native vegetation regeneration projects
Greenfleet makes this submission as a member of the Carbon Marketing Institute, in response
to the proposed changes to the Carbon Credits (Carbon Farming) Rule 2015. The proposed
changes to the Rule introduce a requirement for new project proponents to gain the
Agriculture Minister’s approval for new carbon offset projects under the Human-Induced
Regeneration (HIR) and Native Forest from Managed Regrowth (NFMR) methods that occupy
more than 15 hectares and greater than 33% of the area of total landholding.
Greenfleet respects that the intent of the proposed change is to minimise the risk that
significant areas of prime agricultural land are transitioned to native regrowth projects, to the
perceived detriment of local economies. Similarly, Greenfleet acknowledges the role of the
Australian Bureau of Agricultural and Resource Economics and Sciences in providing
reasoning for the Minister’s individual approval decisions.
However, Greenfleet puts forward the following two positions on the matter:
1. Ministerial involvement that overrides individual landholders’ opportunities to
participate in the carbon market, like any other market, is not consistent with the
Government’s 2021-2022 de-regulation principles.
2. The proposed requirement for Ministerial approval for projects with a positive
environmental impact is not balanced against landholders’ current freedoms to clear
and degrade existing and impact in other negative ways on the environment, free from
Ministerial overview.
3. The proposed scale of new projects subject to Minister’s approval (15ha) is too small
and will deter or prevent landholder engagement with the carbon market where
agricultural production alone currently does not provide farm viability. A suggested
minimum size limit of 200 ha in would allow smaller landholders to access diversified
income options presented by the carbon market, with minimal impact on agricultural
output, to the benefit of the local and global environment, as well as to landholders
themselves. This is in keeping with Australia’s Net Zero commitment and our ethical
obligation to achieve emissions reductions in the shortest time possible.
Thank you for the opportunity to submit a response to the consultation process.
Regards,
Wayne Wescott | Chief Executive Officer
Level 4, 517 Flinders Lane, Melbourne
T +613 9642 0570 | D +613 8563 5553 | M +61 419 521 272
E alex.paddock@greenfleet.com.au
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