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To: Department of Climate Change, Energy, the Environment and Water (DCCEEW)
Re: Removal of the ‘water rule’ from Carbon Credits (Carbon
Farming Initiative) Rule 2015
15 November 2022
Introduction
AMEC appreciates the opportunity to provide industry consultation on the proposed removal of the
‘water rule’ for forest carbon credit projects discussion paper. AMEC is supportive of the proposed changes to the Carbon Credits (Carbon Farming Initiative) Rule 2015, which should make it easier for more carbon farming opportunities through plantation forestry and create more carbon credits under the ERF.
About AMEC
The Association of Mining and Exploration Companies (AMEC) is a national peak industry body representing over 530 mining and mineral exploration companies across Australia. Our members are mineral explorers, emerging miners, producers, and a wide range of businesses working in and for the industry. Collectively, AMEC’s member companies account for over $100 billion of the mineral exploration and mining sector’s capital value.
Mineral exploration and mining make a critical contribution to Australia’s economy, directly employing over 274,00 people. In 2020/21 Industry generated a record high $301 billion in mining exports, invested $3.2 billion in exploration expenditure to discover the mines of the future, and collectively paid over $39.3 billion in royalties and taxes.
General Remarks
AMEC supports the proposed removal of Section 20AB (‘water rule’) from the CFI Rule. We consider that the commitment from DCCEEW will improve the opportunities for carbon farming which will increase the supply of carbon credits. With the recent reforms to the National Safeguard Mechanism and commitments from the newly elected Federal Government to reduce carbon emissions by 43% below 2005 levels by 2030 and net zero by 2050, it is vital to support companies in their efforts to reduce their carbon emissions. However, AMEC maintains that the increased carbon farming capabilities should not negatively affect the ability for mineral exploration companies to access ground.
Are there any other benefits and/or impacts that should be considered in the decision to remove the water rule?
As a result of removing the ‘water rule’, DCCEEW hopes to see the growth of new plantations and the
Australian forest industries and contribute to reducing emissions produced within Australia. This will boost the number of regional jobs in communities involved with plantation forestry. However, AMEC considers that there may be some unintended consequences for the mining and mineral exploration industry that may need to be addressed.
We have concerns regarding:
• Existing titles;
• Compensation;
• Objections.
AMEC believes that State jurisdictions should first consider the following matters before consenting to new forestry carbon farming initiatives:
• All granted and pending mining leases, and associated general purpose leases and
miscellaneous licences (unless the tenement holders agree) are excluded; and
• It is ensured that carbon farming cannot be used as a valid reason to object to the grant, or
activities on, of mining or mineral exploration tenure.
These points have the potential to increase costs for explorers and miners, and increase delays to timeframes for land access, and create an inequity for those seeking to develop the mines of the future.
AMEC supports the Multiple Land Use Framework-use of land – and believes that industries such as exploration, mining, agriculture, pastoral and carbon farming can co-exist.
Are there any other amendments to the CFI Rule that could support the removal of the water rule (section 20AB)?
AMEC has no other amendments to the CFI Rule to suggest that would need to be made to support the removal of the water rule. However, AMEC is supportive of similar reforms that DCCEEW could implement to remove potential barriers to carbon abatement opportunities in the future.
Are there any other supporting actions under the ERF that could be taken to facilitate removal of the water rule?
With the removal of Section 20AB, there should be transitional arrangements put in place to review or allow for previously disallowed forestry carbon farming proposals. These arrangements will allow for quicker and easier transition from carbon farming proponents to register their asset under the ERF and to start producing carbon credits available to the market. It would also create a higher level of transparency regarding the CFI Rule and the new amendments.
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Final Remarks
Carbon farming remains a critical issue for the mining and mineral exploration industry, as Australia makes the transition to reduce carbon emissions by 43% below 2005 levels by 2030 and reach net zero by 2050. As it allows AMEC member companies to offset their carbon emissions to after reducing and mitigating any possible emissions. AMEC always appreciates the ability to provide feedback and we wish to continue to be consulted upon these issues.
For further information contact:
Neil van Drunen Nicolas Parry
Director WA, NT, SA and Industry Policy Policy Advisor WA, NT, SA neil.vandrunen@amec.org.au nicolas.parry@amec.org.au
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