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15 NOVEMBER 2022
Soils and Vegetation, Emission Reduction Fund
Department of Climate Change, Energy, the Environment and Water
John Gorton Building, King Edward Terrace
PARKES ACT 2600 via email: erfforests@industry.gov.au
Dear Sir/Madam,
Proposed amendments to requirements for commercial forestry projects – the water rule
We welcome the opportunity to comment on the proposed removal of the water rule1 from the
Carbon Credits (Carbon Farming Initiative) Rule 2015 (the CFI). We acknowledge the Department of
Climate Change, Energy, the Environment and Water’s (the Department’s) work on Australia’s climate policy, including administration of the Emissions Reduction Fund (ERF).
Forestry projects have a key role in offsetting the environmental impacts of Australia’s high- carbon emission sectors. Small businesses operate in a highly regulated environment with the water rule a key regulatory barrier to increasing commercial forestry activity that will maximise our carbon capture potential and increase participation in the ERF. The water rule also provides a barrier to generating new opportunities for the small businesses within, and on the edge of, the forestry sector. As such, we provide the following comments.
1. We support removing the water rule for plantation forestry projects that are to be
approved under the Emissions Reduction Fund. Removal of the 600mm water rule will
support the Australian Government’s commitment to ‘a billion more plantation trees – the right
trees at the right scale in the right places’, and enable small businesses operating within, and
on the edge of, the forestry sector to support regional jobs, communities, and economic
growth.2
2. Consideration should be given to removing the requirement for plantation forestry
projects to remain in, or be located within limited proximity to, national plantation
inventory. The 50km and 100km distance requirements for short-term and long-term
plantation forestry rotations (respectively) may restrict our future potential to meet demand
for carbon offsets and forestry-based products.
Developing forestry assets in saturation is valuable for the purposes of maintaining industry
skills and knowledge, as well as supplier access to, and supply for, processors and export
markets. However, development of new forestry inventory and rotation strategy is reliant on a
long-term outlook and market strategy. Land owners should be empowered to invest where it
is a good business decision for them; based on their appetite for risk, the appropriateness of
their environment (climate and soils), and broader economic or market conditions.
1
The water rule: plantation forestry and farm forestry projects in high rainfall locations need to meet water interception conditions before they can participate in the Emissions Reduction Fund.
2
Department of Agriculture, Water, and the Environment. (April 2022). Farm Forestry Growing Together.
Level 2, 15 Moore St Canberra ACT 2601 | 1300 650 460
GPO Box 1791 Canberra City 2601 | www.asbfeo.gov.au
Further to the scope of the consultation questions posed by the Department, to support the intent of the ERF and encourage increased small business investment in forestry assets, we provide the following comments:
• Consideration should be given to removing the rainfall restriction contained in the Carbon
Credits (Carbon Farming Initiative—Measurement Based Methods for New Farm Forestry
Plantations) Method 2015. Removal of the 400mm rainfall restriction would encourage wide-
scale investment in farm forestry projects to support emissions reduction, secure future
domestic hardwood timber supplies, improve linkages with forest industries, and increase
economic returns for farmers.3 Farm forestry projects may also better complement existing
agricultural activities and land classes compared to new plantation forestry projects.
• Consideration should be given to streamlining commercial farm and planation forestry
related legislation across government jurisdictions. Reducing the regulatory requirements
for new plantation and farm forestry will increase the capacity for small and family farm
businesses to participate in forestry and the ERF. We suggest regulation be ‘right sized’ for
small business whilst maintaining strategic assessments regarding land-use conflict,
consequences for agricultural productivity and associated public infrastructure requirements.
Thank you for the opportunity to comment. If you would like to discuss this matter further, please contact Ms Sarah Blyton on 02 5114 6128 or at sarah.blyton@asbfeo.gov.au.
Yours sincerely,
The Hon. Bruce Billson
Australian Small Business and Family Enterprise Ombudsman
3
Department of Agriculture, Water, and the Environment. (April 2022). Farm Forestry Growing Together.
Level 2, 15 Moore St Canberra ACT 2601 | 1300 650 460
GPO Box 1791 Canberra City 2601 | www.asbfeo.gov.au
