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

The concept of the method is sound and the initial focus on forests and woodlands where plantings mostly occur is logical. We also support the inclusion of assessing baseline condition and monitoring of condition change over time.

The method as presented is not readily capable of being implemented and has significant inconsistencies with the BAI and ACCU Scheme requirements and would be extremely challenging to regulate.

To ensure the method is capable of application, we suggest an expert group of active environmental planting practitioners should be consulted to pilot and provide feedback about the practical application on the ground. We highly recommend this consultation is conducted early as part of co-design processes on future nature repair methods as standard practice.

Some key points of concern in the method include:
1. It mandates 1980s style sampling techniques which have evolved and we now have more accurate approaches and new technologies available (such as Lidar). For example, the method includes physically marking transects with no clear allowance for innovation, such as GPS marking. The method also has a high reliance on tape measures in the field, with no flexibility for the application of modern sampling techniques that are more accurate. There are already established methods that have gone through rigorous scientific review that outline how a method can measure ecological condition in a way that is technology agnostic and able to accept more accurate and lower cost modern sampling data (e.g. Accounting for Nature method NV-10)
2. That the method collects sometimes data that it does not appear to be used in method calculations, duplicates other data collected, and includes duplication of reporting. For example, it requires both line intercept and quadrats, with little use of quadrats. Climate Friendly believes quadrats alone can deliver all the required data. Initial reports and project plans also included duplicative content.
3. Does not balance method risk with required field sampling.
4. Includes spatial scales suited to remote sensing products being applied to botanical field sampling intensity. Resulting in extreme levels of field sampling, with little clear gain. For example, a 0.2ha spatial scale is not suitable for field sampling of botanical information as would require sampling all 0.2ha areas to identify native/non-native species.
5. Does not focus on the key threat to biodiversity that the method intends to resolve, which is the lack of suitable woodland and forest habitats. The inclusion of focus on additional threats such as fauna and feral animals adds substantial cost and will reduce uptake. We believe threats of feral animals for example, would be best managed through separate methods, or through separate voluntary modules within the one method.
6. It includes analysis of historical threats such as historical analysis of past natural disasters, when this is not a great predictor of future threats to projects under the method. For example, historical fire analysis of open paddocks under the method as required, would not provide useful insights to the risk of fire in the future in the emerging forests and woodlands. We believe a greater focus on assessing likely future natural disasters, rather than past ones, would provide greater benefit to the scheme.
7. Has inconsistencies and unclear alignment with the ACCU scheme and the in development IFLM methodology.
8. Includes no transitional arrangements for existing EP projects. Transitional rules could be developed through requiring an initial baseline of existing vegetation and reporting of progress over time. Inclusion of transitional projects would have market formation benefits, as while the number of existing projects remains novel, some would already be eligible for a certification relatively quickly, allowing for price discovery early in the Nature Repair market operation.
9. Requires analysis of what occurred in the past in relation to how clearing did or didn’t occur. The definitions would require historical ground validation to ascertain the land management that resulted in prior forest loss. We do not believe the required information is available in many cases and the method provides insufficient flexibility for cases where historical information is not available.
10. Is not well aligned with practical application of environmental plantings restoration. For example, the use of 10x10m dimensions in plantings would result in undesirable restoration outcomes along non-linear features such as rivers or along property boundaries that are not N-S and E-W aligned. Climate Friendly propose that 10x10m should be the maximum resolution, with an ability for both higher resolution mapping and also allowing non-linear plantings.
11. The tool PLANR that the method refers to is not yet complete, with key elements unable to be tested to ensure applicability. Tools that methods rely upon are often where practical problems arise, so we would suggest that further method consultation is completed once the draft method can be assessed in concert with the completed PLANR.
12. The tool PLANR does not meet the requirements of the method. PLANR uses NCAS which is based on Landsat data and has a spatial scale of 25x25m, which does not comply with the method requiring 10mx10m resolution.
13. Definitions require refinement. For example, the definition of crown refers to a ‘horizontal transect’, but does not define at which height the transect should occur. Our preference is that the definition should state crown is to measured at the broadest area of the canopy to allow satellite monitoring.
14. Is overly reliant on relatively inefficient field tools, such as line intercept transects, quadrats and field observations for crown height and extent. When remote sensing products are far more accurate and have greater sample coverage for measuring structural elements of forests and woodlands. We do however support the complimentary use of botanical surveys for validation of remote sensing information and to assess the species diversity.
15. The method does not future proof the eligible regions. We would recommend that the method refers to the inclusion and any listed terrestrial ecological community. With the map provided as an indication of eligible areas. This would enable future listed ecological communities to be included, without legislative changes to the method.
16. The practicalities of planning and undertaking a restoration project and the method are not well aligned. The true planting area is rarely exactly known at the stage of project registration. A ‘planned’ planting area is know at the point of project registration, which often changes as physical restoration is undertaken due to biophysical features or land manager decisions. The method would benefit from including a planned area of planting at registration, as opposed to the current draft which requires that the reported activity area at registration ‘must’ be planted in its entirety.
17. The Inclusion of DBH measures of <5cm for including/excluding areas is not cost effective or practical in our view. The <5cm threshold would require mapping every individual stem in the planting area which would be cost prohibitive. We suggest alignment with the Environmental and Mallee Plantings ACCU Scheme method which requires assessment of whether the implementation area had been forest in any recent period.
18. We suggest that the initial site assessment is part of the project plan, rather than two separate documents. We also recommend that the project plan is aligned with Land Management Strategies/permanence for the ACCU Scheme to avoid duplication.
19. Assessment of reference condition at a 3ha should be replaced with a minimum accuracy threshold for the process of ground validating mapping (e.g. 85% accuracy). This would allow proponents to determine the most suitable spatial scales for mapping of similar areas, significantly reducing costs.
20. The method allows assigning a different native vegetation type in cases of ‘compelling evidence’. We suggest the method would be improved if there was guidance on what is, or is not, compelling evidence.
21. Several of the list of vegetation groups in Table 3 do not support forests or woodlands. So either they should be removed (e.g. shrublands, tussock grasslands, hummock grasslands, chenopod shrublands, sedgelands and rush lands), or the method scope should be broadened to enable restoration of ecological communities that do not attain forest cover. Our preference would be to broaden the method to allow restoration through planting of shrublands, tussock grasslands, hummock grasslands, chenopod shrublands, sedgelands and rush lands.
22. The method requires full botanical species ID, yet the method calculations don’t seem to use this information. A lower cost alternative would involve identifying the 5 dominant trees, 5 shrubs, 5 vines, 5 grasses and forbs, with an additional count of species (not ID) in each category. This is being used in NV-10 in Accounting for Nature and results in large savings of field time, without impact on assigning reference to benchmarks or calculating condition.
23. The method requires botanical surveys to occur at times of optimal. We propose that sampling has to instead occur at same season each year, to ensure botanists are able to work across the year, delivering efficiencies. This would provide a conservative ecological condition score, which would still incentivise sampling during periods of optimal growth.
24. Table 6 benchmarks require improved clarity. The definition of canopy height requires clarity on whether this is the average or maximum, and the spatial area over which to assess height.
25. Section 6.7 appears to require surveys of fauna species. Climate Friendly does not believe the method should require monitoring of fauna. If fauna monitoring is required, it is important that the methodology is clearly defined. Similar clarity is required in relation to methods for assessing ‘significant contaminants’.
26. The method requirement to assess a 500m buffer seems impractical without flexibility in the buffer width along property boundaries.
27. Section 6.9 appears to require full assessment of all listed species, including fauna. This is prohibitively expensive as sampling would require night and day surveys for bats, birds, mammals and reptiles. Climate Friendly propose a desktop assessment of listed species identified through the Protected Matters Search Tool and ALA. As well as any opportunistic observations that occur during field sampling.
28. Historical assessment of past disturbance does not appear to have a clear purpose or substantial benefit. All areas in the eligible region are impacted by fire, flood, drought. So this should be simply assumed, and focus in the method should be on mitigating impacts of these natural disturbances in the future of the project.
29. The assessment of natural regeneration is impractical and costly as it would require field observation of every stem in the activity area, many of which are tiny and hard to see in tall grass. Climate Friendly propose alignment with the Environmental and Mallee Plantings ACCU Scheme method, through requiring that the planting area not have achieved forest cover during the baseline period.
30. The activity target area thresholds for non-native cover of grass/forbs seem very difficult to achieve in many key listed communities where high exotic weeds exist. Climate Friendly propose to several options: first, have lower thresholds for grasses/forbs, second, allowing projects to include or not include grass/forb targets, third, to change the categories to have a category that does not include grass/forb targets but is limited to shrubs and tree restoration.
31. The definition of aggregate ecosystem requires improved clarity on whether this is an area weighted measure, or simple average of scores.
32. The method includes restrictions on fire, then suggests this is not intended to impact cultural burning or prescribed burning. We suggest more clear language, such as ‘it does not restrict’, rather than ‘is not intended to restrict’.
33. The restriction deep ripping could be improved by defining how to assess ‘containing remnant vegetation’. Suggest that be this element be aligned with the baseline states with deep ripping excluded in areas with >50% native grass cover.
34. It is unclear why the timing of fencing and installation of irrigation has to be restricted. We believe proponents should have the flexibility to undertake fencing and installing irrigation at any point they feel it is required to maintain or improve ecological condition. We suggest deletion of the restrictions.
35. Climate Friendly suggest that the assessment of significant absence and mortality should not occur in the field, but through comparison of data on planting density and the field monitoring data of trees and shrubs over time.
36. Table 10 thresholds are too high for tree cover and will likely result in perverse market features. Reaching 5m or 1/3 of height could take more than a decade in some woodlands. This would result in a focus in the market to restore tall eucalypt forests as they could attain a certification in a short time period. Climate Friendly propose aligning with the Australian definition of forest cover (2m) with the additional options of 1/3 of mature height.
37. Clarity in notification requirements would be beneficial for compliance. There may need to be consideration of different thresholds for mortality of grasses and forbs verses trees and shrubs. It may be worth considering restricting the notification threshold to tree and shrub mortality, due to the more ephemeral nature of grasses and forbs.

Some solutions have been noted above. However, the method will require greater consultation to address these concerns and we recommend a strengthened stakeholder consultation process.

Refer to comments above. There are issues with the need to ascertain the cause of past clearing, where historical field data is often unavailable. As an alternative, we propose alignment with the Environmental and Mallee Planting method approach to assessing eligible land through historical remote sensing analysis of a lack of forest cover during the baseline period.

This method has not been designed to be stacked or interoperable with ACCU methods. Please refer above for examples of misalignment. We also note that most lessons learnt in application of the CFI Act seem to have been missed. We suggest greater co-design in relation to ACCU method alignment with CMI and its member organisations in the future to ensure interoperability.

The BAI and specifically the guidance for method development seems to have largely been ignored with many inconsistencies in the draft method.

We recommend more refined consultation processes in the drafting phase prior to release of drafts for more formal consultation. This would ensure that consultation drafts are close to final products and can proceed to legislative drafting in a more expedient manner.