Published name
1. Are there any specific approaches applied in the method that you agree with?
1.a Why or why not?
Very pleased to see the requirement for suitably qualified person to ensure the scientific validity of what the method is purporting to deliver. The process of appropriately stratifying the land and assigning a reference ecosystem is one that takes a specific ecological skill relying on interrogating and understanding existing vegetation, geology, soils and other ecological associations.
2. Are there any specific approaches applied in the method that you do not agree with?
2.a Why or why not?
- Ambiguous definition of shrub and tree - this is inconsistent with other vegetation condition assessment frameworks
- Section 6.3.1 (Process for assingment of reference ecosystems) - part 5a - In reference to the requirement for an alternative native vegetation type that is selected as a reference ecosystem for a site must occur within a 5 km radius of the activity area, if this is referring to the given native vegetation type needing to be extant and present within 5km (as opposed to being mapped as historically present within 5km) then this requirement is too restrictive. Many vegetation types aiming to be established/restored, having been preferentially cleared in the past, but historically present in the area, are often highly fragmented; with the potential that it may not occur for tens of kilometres or more. There is other information that, in addition to point b) can be used to justify the target restoration vegetation type without the need for a spatial restriction. Also, in dot point 6, if the justification for why the biophysical attributes in an activity area reflects a change in climate (or impending change based on climate modelling), then the 5km requirement is even more restrictive, as establishment of a vegetation type from much further afield (>5km) may be warranted.
- Section 6.5.2 - I have an issue with referring to the 50m x 20m area as a 'transet'. Terminology here should refer to a 'plot' with the transect referring instead to the 50m centreline running the length of the plot. What I consider a mis-use of the word transect is repeated throughout the documnet.
- Section 6.5.2 - For safety reasons, permanent markers can only safely be installed once operations in the first two to three years are no longer required to be undertaken (e.g. weed control, slashing, planting etc)
- Section 6.5.5 - What is considered 'ground cover'? Less than 1 m in height? Just grasses and forbs? What about low-lying woody shrubs?
- Section 6.5.5 - "Each point must be assigned to one of the categories listed in Table 5". How does this approach account for this method intercepting multiple categories at one point: e.g. plants native to the local area (A1) intercepted over underlying Litter (C).
- Section 6.5.6 - For the 1m x 1m quadrat, is the cover estimated from the vantage point of 1m above the ground? What is the height from which the assessment is made as shrubs at 80cm could obscure the underlying ground attributes. Also, measuring the cover of all species could result in >100% cover if the sum of all species collectively add to over 100%.
Section 6.5.8 - Point 3, referring to assigning the proposed activity area to ecological condition state, given that there are three plant categories (A1, A2 and A3), there is the potential for none of the three ground cover classes to sum over 50%. How is that assigned?
Table 6 - Note that the benchmarks for a number of states do either not record a benchmark for this attributes (NSW) or is instead reported as median (Qld). Many states have no benchmarks whatsoever.
Table 6 - Is the native vegetation crown cover intended to refer to tree, shrub, vine and grass/forb or just trees? If trees, is it referring to ecologically dominant layer (canopy) and/or sub-canopy? Section 6.13.1 outlines that it might include “canopy, understory, where relevant”. What is considered understory and when/how is that considered? What constitutes a forb and what about species that are not grasses (Poaceae) or a forb?
Table 7 - The method talks about strata as ‘canopy’ and ‘understory’ but the none of the reference benchmarks that are available in those staes where there are benchmarks refer to ‘understory’ and each of them includes instead a set of other strata (e.g. Qld BioCondition includes canopy, sub-canopy, shrub).
Section 8 - point 7) f) includes requirement to outline measures adopted by the project to respond to climate change, however Section 6.13.1 states "“The counterfactual scenario within this method assumes that in the absence of the project, the condition of each activity area would remain static over the period of the project.” As such, the method seems restrictive in not being able to respond/account for climate change as intended.
Section 10 - in reference to 'areas are not deliberately burnt more than once every seven years". This needs to be informed by ecological burning guidelines consistent with First Nations advice and/or advice from Herbaria rather than just nominating a 7 year limit.
Table 8 - introduces a height of predominant canopy indicator whereas Table 6 does not refer to predominant canopy (assuming ecological dominant layer, canopy or T1?). It also refers to cover of predominant canopy (crown cover) although Table 6 mentions “Native vegetation crown cover (by vegetation layers)” so assuming more than just predominant canopy. What does 'lifeform' mean in Table 8 as Table 6 refers to trees, shrubs, vines, and grass/forbs. Are we just referring to them?
2.b What do you think would be a better approach in the areas that you do not agree with?
Better define and make consistent the terms for the measurable attributes.
3.a Cleared Land (section 5.3)
I note that it is stated that the land must have forest potential, defined as the potential to support native trees and shrubs over 2m in height, yet the definition of shrub under this instrument effectively precludes woody plants that would get over 2m as it does not include woody plants with a growth form that does or would preclude the stem diameter being measured at breast height (DBH) where DBH is 130cm (i.e. inconsistent).
3.b Certificate Issuance (section 16)
3. c Monitoring (section 13)
4. This method has been designed so it can be ‘stacked’ with the Australian Carbon Credit Unit (ACCU) scheme’s Reforestation by Environmental or Mallee Plantings FullCAM method.
The Committee would be interested in feedback on how well the method would facilitate stacking.
No comment on this as yet. Preferred approach is the certified Environmental Account approach under the Accounting for Nature Framework.
5. Is the proposed method consistent with the biodiversity assessment instrument?
Generally yes, although prescribing comparison of benchmark without guidance on how to establish benchmarks is problematic
6. Do you have any other feedback on the method?
Seems to be reinventing the wheel when there are perfectly tried and tested native vegetation condition assessment methodologies under the Accounting for Nature Framework to draw from. e.g. NV-02
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