Nature Repair Committee consultation: Replanting Native Forest and Woodland Ecosystems Method

Anthesis Australia have provided a detailed written response: NRM Native Forest and Woodland Method Consultation_Anthesis Response vA.0.pdf. In this survey herein, we have provided a summary of this response and recommend that the Nature Repair Committee read the more detailed version in addition to the survey answers below.
We are aligned with the following aspects of the Method:
• In general, we think the Method is well-written and laid out in relation to the required steps for Initial site assessment and report, Record-keeping, Project Plan.

• The inclusion of a definition of permanent plantings that includes (some) flexibility on seed collection for propagation, in line with Environmental Plantings (version 2 in draft). We see this as a positive step, as complete prohibition would otherwise be a limitation to the conservation industry due to seed stock scarcity and providence.
This is also detailed in our review of Method Section 3 and Appendix A.

• The inclusion of considerations regarding climate adaptation:
o We commend the inclusion of an adjusted reference ecosystem in the definition of reference ecosystems that accounts for irreversible environmental changes, such as climate change. This will increase the success of projects.
o In designing plantings (section 6.3), the Method enables proponents to consider potential future climate conditions through prioritising provenances or species from among those typical of the reference ecosystem that are best suited to the location and likely future climate. This is important to ensure that projects achieve outcomes in spite of any changes in climate from the reference condition and future scenarios.

Anthesis Australia have provided a detailed written response: NRM Native Forest and Woodland Method Consultation_Anthesis Response vA.0.pdf. In this survey herein, we have provided a summary of this response and recommend that the Nature Repair Committee read the more detailed version in addition to the survey answers below.
We have specific feedback for the following aspects of the Method:

Considerations around the Scope
• Avoidance of separate NRM Method Stacking
To reduce the need for method stacking under the NRM Scheme, we highly recommend the current Method to provide for the inclusion of multiple ecosystems, the improvement of existing remnant vegetation and conservation, and ability to certify fauna biodiversity outcomes alongside flora. Our viewpoint comes from an understanding of how project activity-specific methods have worked under the ACCU Scheme and the barriers that have arisen in terms of project uptake and participation, scale of outcome (i.e. abatement), cost of implementation and duplications in requirements around monitoring and auditing. Enabling everything to occur under the one Method will reduce the administrative requirements and financial burden for project proponents and allow rolling these items into one type of reporting (e.g. as is being pursued by the IFLM method under the ACCU Scheme). Further detail of our reasons is outlined below.

• Eligible region
o Anthesis seeks clarification around why only the IBRA regions are being considered. We ask the Nature Repair Committee to reconsider the highly prescriptive and spatially restrictive areas for eligible regions. There are cleared and degraded areas beyond the proposed eligible area (noting QLD and the NT) which may present great potential for enhancement of biodiversity values.
o The current definition of ‘permanent planting’ limits the Method to rural areas and excludes urban landscapes, limiting potential biodiversity benefits. Improvement of biodiversity in urban areas, for which there is plenty of opportunity, can provide numerous social benefits and ecosystem services.
o These points are highlighted further in our review of Method sections 1 and 2 in the attached submission.

• Ecosystem
o While it is understood that this Method aims to enable integration between the ACCU Scheme Environmental plantings Method and NRM projects, the biodiversity outcomes of this Method could be increased by including projects that establish plantings on land that does not necessarily meet ACCU eligibility requirements (e.g., forest cover definition, forest potential) but would nevertheless benefit from restoration through planting. This could include ecosystems that lack a tree canopy, such as grasslands and shrublands. Therefore, this Method could enable scalability of biodiversity outcomes beyond those already likely as a result of the ACCU Scheme Environmental plantings Method.
o Including other ecosystems and vegetation types would also create more opportunities for additionality on top of existing ACCU projects.
o Remnant vegetation frequently occurs on properties that are eligible under the Method but activities to improve this vegetation are excluded. More holistic management of this vegetation along with plantings would increase biodiversity benefits.
o These points are highlighted further in our review of Method sections 1 and 2 in the attached submission.

• Project Activities
o In several instances, the Method indicates it only supports plantings. However, there are restoration efforts that can benefit from other management activities which would support the improvement of an alternative level of degradation. This would mean, in addition to areas that have been cleared, the inclusion of areas that are otherwise sparsely regenerated and degraded. It could also include conservation type activities for remnant vegetation protection. This would especially be true for 100-year permanence projects.
o It may be suitable to regarded as complementary activities It may be beneficial to treat management actions currently regarded as complementary to support plantings as activities in their own right.
o If the definition of a planting in the Method is limited to direct seeding and propagated seedling stock, it might limit scope for new and innovative methods or technologies. For example, reference ecosystem topsoil translocation could be another way of seeding an area that could create additional benefit for projects. It is suggested to keep the wording more deliberately “open” here.
o These points are highlighted further in our review of Method sections 1 and 2, and 3 in the attached submission.

• First Nations
We note that the Detailed Outline of the BAI states that all methods will give project proponents the option to undertake a project that delivers First Nations biodiversity outcomes (biocultural outcomes). The BAI provisions relating to First Nations knowledge, values and data would be supported by guidance material to assist proponents. Further, it states that methods are required to set out additional conditions and requirements for projects choosing this option. We note that there are various sections in the Method (ss6.5.2, ss6.14 (point 5), s8 project plan (item h) and Monitoring Report (ss13.9)) that provide inclusions for First Nations people and is in alignment with the BAI.
However, we note that the Method has very prescriptive and generic restrictions on fire management and burning. We recommend that the Nature Repair Committee engage extensively with First Nations people on fire management so that the BAI and Methods have better alignment, and so that First Nations Cultural knowledge and practices are more accurately incorporated in the Method requirements.
We also suggest that First Nations restoration knowledge and biocultural outcomes also be included more upfront in the scoping sections of the Method. This would encourage and enable First Nations knowledge and values to inform the project design, as appropriate and applicable.
We also note that the requirements under the definition of ‘suitably qualified person’ (a, b and c) may be prohibitive to First Nations knowledge and participation. First Nations peoples may not have formal qualifications in ecology and botany, but may have a really sound understanding of what needs to be planted and what can be sustained. Expanding on the definition of a suitably qualified person to include an item d., or in other sections, to foster First Nations participation and knowledge inclusion is highly recommended. Also refer to our subsequent discussion on fire management.

• Suitably qualified person
Sections 6, 8, and 13.9 specify that a suitably qualified person is required to undertake the initial site assessment and prepare the report, assign reference ecosystems and benchmark values, prepare the Project Plan, undertake monitoring and prepare the Monitoring Report. Currently, this is a large workload for one person and may create human resource bottlenecks. Typically, these tasks are pulled together by a team of people. Further, the current definition of a suitably qualified person requires them to be an ecologist or botanist. This may result in a large cost to project proponents. We suggest that these sections adjust the requirement so that a suitably qualified person simply needs to sign off on these tasks/elements.

• Initial Site Assessment
Currently, we view that the Method is highly prescriptive on the field measurement requirements and also does not reference the standard with which it is aligned to. We highly recommend that The Nature Repair Committee consider flexibility in approach and technology while ensuring convergence on outcome and statistical robustness. We wholly agree that the Method should allow proponents to put forward an alternative monitoring protocol providing a rationale or demonstrating the protocol meets the standard. Referencing the standard in which the method is aligned may assist with this. Further, assigning confidence levels to the protocol may assist with flexibility in approach and technology (e.g., as with Accounting for Nature) and also with project comparability.

• General Monitoring and Record-keeping requirements
There is a general trend whereby several items (i.e., disturbance and land use history, hydrological features of significance, natural regeneration, and threats) are required to be identified, but there are no ongoing monitoring requirements. Further, it is not clear how these aspects are being tied back to outcome. We note that for the identification of threats, the Biodiversity Assessment Instrument allows methods to set provisions for projects to report and publish a ‘not applicable’ assessment for the removal of threats. Therefore, this is a limitation of the BAI in this instance.
Guidance on areas that require to be identified (regeneration, covenant areas etc.) and possibly need to be excluded, should also be provided in the Method.

• Statistical robustness and representation
Section 13.7, paragraph 1 states that qualified assessors must certify that the assessment transects are representative of at least 90% of the activity area in which they are located. We wonder about the scenario in which the transects do not meet this representative threshold? For instance, a site assessment transect that did not establish well and is therefore not representative. Request the Nature Repair Committee to provide additional clarification on the case if representativeness is not achieved. This could be managed with linkage to the outcome confidence level suggestion (see Initial Site Assessment).

• Indicators
Table 6 on Benchmark Indicators presented in Section 6.6 do not align with the thresholds listed in Table 10 (Ecological indicator thresholds for certificate issuance) in Section 16.1. We recommend making these tables the same to reduce ambiguity.

Against each feedback point above we have (and where possible and appropriate) provided a suggestion and/or recommendation.

Section 5.3 paragraph 2, item a. requires that the land must have been comprehensively cleared more than seven years prior to the date of the project application.

As per the definition:
comprehensively cleared means the comprehensive removal of native trees by mechanical or chemical means from at least 90% of the land, defined at 10m x 10m scale, other than small trees (< 5 cm diameter at breast height) that survive the clearing event by virtue of their size.

In alignment with our recommendation to broaden the scope of the Method’s restoration remit, if the Nature Repair Committee were to follow this suggestion, then we recommend removing clearing requirements and leave them as part of the ACCU Scheme Environmental Planting method requirements and subsequent linkage rules.
If clearing requirement were to remain, we note that there is scope for misinterpretation in relation to the term “90% of the land” resulting in potential exclusion of areas. We suggest that the Nature Repair Committee provide clarity on whether the term “land” refers to the “property area” or the “activity area”. For example, if it is the former, this may exclude large properties which have had, for example, 50% cleared areas.

We also note that section 6.10 requires proponents to report significant disturbances including clearing within 10 years prior to the date of the assessment (or five years if change in landownership). It is not clear as to why historical disturbances need to be reported on beyond the 7seven-year eligibility requirement.
These points are elaborated on further in our review of sections 5 and 6 in the attached submission.

It is our understanding that the Method seeks to enable registration of both an ACCU Scheme (Environmental Plantings) and NRM-project on the same ‘activity area’.

It is not to Anthesis, however, clear to what extent, if at all, the NRM project would need to demonstrate additionality over and above a carbon project. It is therefore unclear how this aligns with the requirement in section 57 of the Nature Repair Act 2023 (‘NR Act’) that methods are additional where projects would result in activities that would otherwise not occur.

Accordingly, it is also not clear, and we request guidance on, whether this Method is intended to:
• Quantify and split the co-benefits out from the ACCUs (i.e., both project types can occur on the same land, with the ACCU Scheme crediting carbon outcomes and the NRM project crediting biodiversity outcomes), or
• Provide additional benefits to an existing carbon project (i.e., in the sense of the NRM project providing additional management and/or planting activities to enhance the carbon outcomes of the ACCU Scheme project).

In either case, we also note elsewhere in this submission, that as currently framed, this Method appears to miss the opportunity to encourage planting and/or revegetation in areas that may not achieve the ACCU Scheme’s forest cover potential requirement (i.e., 20%) but may achieve a lower crown cover threshold.

There is also a question around timing and scheduling of the individual ACCU and NRM Scheme projects and the implications for ACCU Scheme projects which have already sold ACCUs for a premium due to co-benefits, and an NRM project is later established.

In summary, there is an opportunity for the Nature Repair Committee to be clearer on the intention of the current NRM Method and thus provide more clarity on how ACCU Scheme and NRM projects will work together whilst addressing additionality under both the NRM and Carbon Farming Initiative Act (‘CFI Act’).

Areas of inconsistency that we have identified:

• First Nations knowledge, value and data
o The BAI stipulates that methods must not contain conditions or requirements that would prevent project proponents from engaging with First Nations people or using Indigenous knowledge and practices, as appropriate, in relation to the design of their project. As mentioned, we note that the Method has very prescriptive and generic restrictions on fire management burning and recommend extensively engagement with First Nations people on fire management and other restoration priorities.
o The inclusion of culturally significant entities is first mentioned in section 6.14. This could be mentioned earlier in the design requirements of the project.

• The Method has not set provisions that projects may use an alternative monitoring protocol (per section 2.6.2 of the BAI).

• The Method has not identified the monitoring standard with which it is aligned (per section 2.8 of the BAI).

• The Method does not satisfy the certainty/confidence requirements. For example, there is no mention of what level of confidence or certainty the monitoring protocol, data collection type and number of monitoring points bring.

• The BAI indicates that there should be a rating scale for the measurement of the commitment to protection of biodiversity.

• The BAI requires methods to set provisions for projects to assess the project status and change to threatened species and ecological communities using a rating system. No rating system is provided in the Method.

• Table 10 does not comply with section 2.6.2 of the BAI which states that methods must set provisions that to specify the time over which the biodiversity outcomes would be delivered. The timeframe in which projects would achieve their targets and thresholds would be highly varied. Suggest a review of the BAI requirement or more guidance around how time may be applied to biodiversity outcomes.

• The item 4 and item 5 (s6.3.1) requirements for the assignment of reference ecosystems to each defined land area uses the phrase ‘is likely to be’. We believe more guidance on what is meant by ‘likely’ would be beneficial and would ensure compliance with the Biodiversity Assessment Instrument (s2.6.1).

Anthesis Australia have provided detailed feedback in: NRM Native Forest and Woodland Method Consultation_Anthesis Response vA.0.pdf.

In summary:
• Currently, there is repetition in section 3 and Appendix A. Suggest having one section on definitions.
• We have noted that there is significant overlap in the monitoring protocols in Section 6 Initial Site Assessment and Section 13 Monitoring. Combining the details of the protocols (and even aligning the indicators measured), would simplify the document and avoid confusion and risk of error or discrepancies.