A Quandary – Nit-pick or constructive critique of CFI ERF

The quandary for most of us when we express our thoughts is we can be regarded as excessive or obsessive for seeking out an agenda – the agenda to change that might be procedurally correct, but fails to address the main issue. For instance the Emissions Reduction Fund – Irrigated Cotton draft determination and associated documents (the consultation process closed 12 December 2014). The main issue, as with other Carbon Farming Initiative methods, is that it is harder for leading growers to be rewarded, as there is no recognition of past improvements.

In the main we found the draft cotton determination, draft cotton explanatory statement and the draft cotton equations, as is, to be sound. It has its process thought through well enough and while we could say some of the flow could be improved any further submission could appear to be nit-picking as opposed to constructive criticism.

Was there room for constructive critique? Yes, but these are areas we might like to adjust the eligibility criteria. Also a little tweaking of what appears too broad in the descriptions. They are areas that could be argued as wrong, but they really are areas for the regulations or legislation to be adjusted. When you access the process of a determination your role amounts to comment on the process that is laid out in the draft determination. It is not the appropriate place to express frustration with the rules. Expressing your frustration is really the domain of the politics.

Being we mentioned the ERF – Irrigated Cotton draft determination, we should let you know what is it about. The first thing is it is the opportunity for growers to obtain certificates called the Australian Carbon Credit Unit (ACCU) under the Act 2011 called the Carbon Farming Initiative (CFI). The reference to the Emissions Reduction Fund (ERF) is part of the CFI Amendment Bill 2014. The fund is designed to help reduce Australia’s emissions by providing and incentive for business, landowners, state and local governments, community organization and individuals to adopt new practices and technologies which reduce emissions. The ERF does include incentives for business activities and farming practices. To find more go to: http://www.cleanenergyregulator.gov.au .

A bit more about our thoughts on the determination and consultation on the Draft Energy Reduction Fund: Irrigated cotton.

  • The ‘system’ is for irrigated cotton growing mainly in Queensland, NSW and Western Australia.
  • The incentive is to encourage Nitrogen fertiliser use efficiency and efficiency is a measure of the ratio of lint yield to nitrogen applied via synthetic fertiliser (kg lint yield per kg N).
  • An increase in nitrogen fertiliser use efficiency is equivalent to a decrease in emissions intensity from synthetic fertiliser use in irrigated cotton (t CO2-e per kg lint yield).
  • Because nitrogen fertiliser use efficiency is calculated using both nitrogen fertiliser use and yield, credits for emissions reductions can be generated by reducing fertiliser use while maintaining or increasing yield, or by increasing yield without a corresponding increase in fertiliser use. This approach also ensures that credits for emissions reductions cannot be generated through a contraction of yield without a reduction in fertiliser use.
  • The draft Determination therefore enables irrigated cotton growers to adjust nitrogen fertiliser rate according to paddock yield potential in the project area, provided that nitrogen fertiliser use efficiency increases.
  • There is support for a broad range of activities to improve the efficiency (reduce the emissions intensity) of fertiliser use in irrigated cotton, including activities to improve lint yield without a corresponding increase in nitrogen fertiliser application rate, and activities to modify the rate, timing, method and efficiency of nitrogen fertiliser application.
  • Proponents have the flexibility to select management actions that suit their individual circumstances.
  • In this draft, cotton is the only crop in the production system eligible for generating credits for a reduction in emissions from synthetic fertiliser use.
  • Emissions from other crops grown in rotation with cotton, with the exception of green manure, are excluded from this draft Determination.

What is Synthetic fertiliser?

Inorganic are sometimes called synthetic fertilizers since various chemical treatments are required for their manufacture.

Synthetic fertilisers do not include solid or liquid organic products created using waste products of other industries that do not meet these labelling and minimum nitrogen content standards. For example, synthetic fertilisers do not include manures, such as poultry litter or beef feedlot manure, or mulches and composts, such as composted ginning trash.

What is a Green Manure?

A green manure is a legume that is planted in a paddock to improve the soil for a subsequent cotton crop. A green manure crop is not harvested and the above ground growth is returned to the soil. Examples of green manure are vetch, faba beans, chickpeas and annual clovers. Non-legume crops which require nitrogen fertiliser are not included in the definition of green manure

What is Organic fertiliser?

Organic fertilizers are usually (recycled) plant- or animal-derived matter. The main “organic fertilizers” are, in ranked order, peat, animal wastes, plant wastes from agriculture, and sewage sludge.

If you picked up on peat as a organic fertilizer and the reference that it has no nutritional value to the plants, but improves the soil by aeration and absorbing water. You might ask why is biochar not a fertilizer?

Bio char

It gets down to two issues:

  1. Bio char is described as a sequester of carbon and as such binds carbon to its properties.
  2. So broad is the definition that it is seen to be the product of ‘burning’.

The later point is where it gets interesting and frustrating. This is because the technology for fine chars is thermochemical decomposition of organic material at elevated temperatures in the absence of oxygen. In another speak, Bio char is created by pyrolysis of biomass.

We do not argue that is a fertilizer. What we argue is it is an agent to improve the efficiency of fertilizer use.

Another potential for confusion is linking soil carbon to bio char. Soil carbon is a condition and bio char is a conditioner. If you think one is the constant and the other the agent for change it makes sense does it not?

That leaves the issue of if it is helpful why is it excluded from the incentives?

Maybe the question is better put this way: Plants don’t need carbon, soils do. Biochar is but a hazardous waste from pyrolysis, looking for a below-the-radar application. Do we have that application? But that is for another discussion and a case study!

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Makers – a Viable CFI methodology

Recently a discussion group was asked for information on the area needed to make a Carbon Farming Initiative (CFI) methodology viable. I follows the answer is not as simple as it should be and part of the problem is the rules can change and even the responsible entity itself might change. This statement is not an example of a remote possibility, it is very much what is likely to happen.

First issue: The market.

Currently a Australian Carbon Credit Unit is reported as holding steady at approximately the Carbon Price Mechanism expectation of $23 (actually ACCU spot price is $22.60 at 4 April 2013). Compared to the trading prices of others. For example the Carbon + Market Daily (www.cedaily.com.au) shows European Union Allowances (EUA eligible on Australian Scheme from mid 2015 – June 2016: AUD $7.48 – no change) 
* Certified Emission Reductions (CER eligible on Australian Scheme from mid 2015 – June 2016: AUD $0.67 – up 6.4%) 
* New Zealand Units (NZU spot can’t be used to meet liabilities under the Australian scheme: NZD $1.97 – down 2.5%) 
* Australian Carbon Credit Units (ACCU spot Kyoto units issued under the CFI that can be used to help meet Australian scheme liabilities: AUD $22.60 – no change). They also report of conflicting market drivers, and this is in addition to the Coalition threats to dismantle the carbon price mechanism, that the European market is struggling to hold above EUR5 on moderate volumes. Problems include:

1) An increasing likelihood that backloading will be passed as more countries come out in support of the proposal; and

2) High auction volumes relative to emitter demand.

3) Increased selling in the New Zealand market as more participants’ look to switch out of their NZUs and into cheaper international units.

4) June 2016 prices for EUAs and CERs reflect the cost of these units to an entity liable under the Australian scheme’s floating price phase.

5) The EUA (December 2013 contract) is a focus as this drives price movements and is a key indicator of EU (European Union) market sentiment.

Conclusion – first issue: Transactions involving carbon give rise to substantial risk (including regulatory risk) and are not suitable for all investors. It is recommend that you seek your own independent legal or financial advice before proceeding with any investment decision

Second issue: Carbon Auction Rules.

The Clean Energy Regulator is likely to be required to offer 60 million carbon units in 2013-14 under draft carbon auction rules. The potential is the opening price is at 60% of the international market price. Follow the link of the

exposure draft of a carbon auction determination, and it will outlines arrangements for auctions that are set to begin next financial year.

If you are relying on an incoming Coalition Government to repeal the determination, you should note s113(9) of the Clean Energy Act allows the Regulator to hold auctions even without the determination. It might not be so simple as a statement to win votes – it is written in stone so to speak.

Conclusion – Second issue: Without control of the senate, or if the senate is hostile, a Coalition repeal instrument would be disallowable. This introduces additional risk, and additional to regulatory risk. As in the first issue it is recommended you seek your own independent and financial and legal advice.

Third Issue: ACCU methodology.

It costs up to $1M to develop a methodology acceptable under CFI. Once accepted the transaction cost to create the ACCU’s is said to be about $70,000. Although it is not a definite cost, it can be less but a reasonable guide and it requires you to look carefully at the potential yield of each project and whether you can smear the transaction cost across the entire project to determine the minimum size for it to be a worthwhile program.

One way to develop a methodology and reduce your cost base is to apply to the 

Methodology Development Program (MDP) for a grant to develop the methodology. The 

MDP is a 
$19.6 million for the development of methodologies for use in the Carbon Farming Initiative. The fund is administered by the Department of Climate Change and Energy Efficiency (DCCEE).

However, recently the Government has moved from 26 March 2013 that DCCEE be in transition to be part of a new super department called the Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education. 

It is reported as a move the Australian Government hopes will be seen as logical and a way to portray that climate change is taken seriously across all of government and across all portfolios. Details changes are yet to be fully announced, albeit it is known the Climate Change Adaptation Strategy has changed with 140 projects, 33 university programs and 100 researchers affected – source ABC.net.au.

Conclusion – Third issue: Before expending too much time on the methodology. The suggestion is you follow up on who would administer the program post transition to the super department, and the will to continue with the program. Any changes will have cost implications for your efforts.

If only we had certainty!