What is a position paper when it does not necessarily represent the views of the Government or any Government Minister – It could be a discussion paper and one very recent issue on the CFI related discussion is a position paper prepared by the Land Division of the Department of Climate Change and Energy Efficiency to promote discussion ahead of developing program guidelines for the Non-Kyoto Carbon Fund. The paper titled Non-Kyoto Carbon Fund Discussion paper for public comment – November 2012.

If you are wondering what does it mean, firstly you need to understand that the Non-Kyoto Carbon Fund is about abatement activities that do not count towards Australia’s emissions targets. It is about a market based incentive for CFI credits that do not have access to other markets. Equally important the Fund will not duplicate other grant-based or research and development funding provided under the Clean Energy Future Plan.

So why do it?  To encourage investment and promote innovation all related to reducing emissions or store carbon and would not have been contributing in other ways to Australia’s emissions targets. A big part of this objective is the ‘learning by doing’.

Looking closer at the Carbon Farming Initiative it is a legislated framework to ensure that abatement is real, permanent and additional. If you want to investigate what is thought of this statement you can read CO2Land orgs post  Real, Additionality, RECs

Posted on August 14, 2012 by co2land “Curiosity lead to checking out the reporting standard AS/NZS ISO 14064, finding it is silent on the word or term ‘real’ and completely avoids the topic of additionality, was fascinating given that you can’t even conceive of an offset without the concept of additionality!

CO2Land org now ponders: If ‘real’ cannot be a guarantee of a good project outcome. It follows that the use of the word or term ‘real’ can be seen as a initial or promised activity increase and not be seen as a guarantee of an increase in the carbon offset (it could be real activity and still lead to a decrease of carbon offsets). So if I say it was real at the time I acted; it was an act in good faith only. The issue with the word ‘real’ is it literally means the activity is a cause of change.

This lead to thinking of the impact this has on the Carbon Farming Initiative as legislated when the Gold Standard and Carbon Fix require that projects be “real”, but no international standard could explain what they mean by using the terms.

CO2Land org looked a little harder (we don’t want this post to be no more than ‘hot air’) and found:

◦    Specifically ISO 14064-2 (project accounting) does not include ‘Real’ because during development of ISO 14064-2 ‘Real’ was regarded as a programmatic rule/criteria, which is outside the scope of ISO 14064-2.

◦    ISO 14064-2 is a standard rather than a program

◦    ISO 14064-2 (Clause 5.4) specifies the following requirement in regards to additionality: “The project proponent shall select or establish, justify and apply criteria and procedures for demonstrating that the project results in GHG emissions reductions or removal enhancements that are additional to what would occur in the baseline scenario.”

◦    Additionality is incorporated into ISO 14064-2 is based on the core principles of ISO standards in general, i.e. that ISO standards not be a barrier to trade (WTO-TBT – anyone following development of ISO 14067 (product) will know this is a major issue). As such, ISO standards must be policy-neutral (extended to include program-neutrality). This is of course very important for market confidence.

◦    ISO 14064 deals with the concept of additionality by requiring that the GHG project has resulted in GHG emission reductions or removal enhancements in addition to what would have happened in the absence of that project. It does not use the term “additionality”…Thus the project proponent may apply additionality criteria and procedures, or define and use boundaries consistent with relevant legislation, policy, GHG programmes and good practice.”

◦    Although the concept/requirement of additionality is within the requirements of ISO 14064-2, the simple reason why the ‘term’ additionality is not present within the requirements of ISO 14064-2 is because of certain sensitivities/perceptions/politics of certain parties involved in the development of the standard. ”

If we press on with the currect discussion paper: You should be aware the Non-Kyoto Carbon Fund will only purchase credits issued under the Carbon Farming Initiative (CFI) and the department states the rigorous CFI integrity standards apply to both Kyoto and non-Kyoto projects.

To quote the Department: “The CFI is based on internationally accepted principles for ensuring that abatement is real, permanent and additional; and incorporates safeguards against adverse impacts — for example on biodiversity, water availability and employment. It allows landholders to generate carbon credits for abatement actions, whether or not they contribute to Australia’s emissions targets. All abatement — including Kyoto and non-Kyoto abatement — is subject to rigorous integrity standards, which cover:

• Measurement:  each CFI project must use an approved CFI methodology to ensure that abatement is measurable and verifiable. CFI methodologies are supported by peer reviewed science and assessed by an independent expert committee (the Domestic Offsets Integrity Committee).
• Additionality:  abatement must go beyond legal requirements and common practice within a comparable industry and/or region.
• Leakage:  measurement methods must account for leakage and variability and use conservative assumptions.
• Permanence:  sequestration from establishing trees or building soil carbon must be permanent.

The CFI is administered by the Clean Energy Regulator. It is supported by legislation and includes measures to minimise fraud and dishonest conduct. The CFI framework gives buyers confidence that offsets make a genuine contribution to climate change mitigation. “

Co2land org does not intent to verbatim the paper and you can easily get a download of  the discussion paper at:  http://www.climatechange.gov.au/government/initiatives/carbon-farming-initiative-non-kyoto.aspx .

But if you prefer we can explain what is Kyoto versus non-Kyoto activities. Kyoto protocol was ratified by Australia in 2007 and we agreed to to limit our national emissions in the period 2008-2012 (the first commitment period) and the Government has recently announced its intention to join a second commitment period, consistent with our domestic commitment to reduce emissions by 5 per cent from 2000 levels by 2020.

The Non-Kyoto Carbon Fund promotes land sector abatement that does not contribute to Australia’s internationally committed emissions targets, but represents genuine abatement nonetheless. Some non-Kyoto activities are likely to transition into the Kyoto framework (or its successor) over time.

The Kyoto Protocol establishes an internationally-agreed framework for measuring and reporting greenhouse gas emissions. Australia ratified the Kyoto Protocol in 2007, agreeing Land sector activities that contribute to Australia’s Kyoto Protocol emissions target (Kyoto activities) include:

• activities that reduce agricultural emissions;
• reforestation (land that was clear of forest before 1990); and
• avoided deforestation (those present in 1990).

Under a second Kyoto Protocol commitment period (from 2013), it will be mandatory to account for forest management.

Rules:

* The carbon pricing mechanism allows CFI credits from Kyoto activities can be used as offsets.

* You can use the CFI to credit abatement from activities that do not currently contribute to Australia’s Kyoto Protocol emissions target (non-Kyoto activities).

* Credits generated from non-Kyoto activities will be eligible under the Non-Kyoto Carbon Fund, but cannot be used as offsets under the carbon pricing mechanism.

Transitioning activities into the Kyoto framework

• International climate change negotiations are ongoing. What we have the moment is an intention to join a second commitment period.
• Forest management and other voluntary land sector activities were not followed in the first commitment period because of risk. Risks that the gains from carbon sequestration could become losses from natural events, such as bushfire and drought. New provisions allow countries to exclude emissions from major natural disturbances when accounting for forest management and reforestation.
• Accounting for forest management will become mandatory for parties under a second Kyoto Protocol commitment period.
• Other land sector activities — including the storage of carbon in agricultural soils, grazing land management and the restoration of wetlands — will remain voluntary. Or at least until the Government assesses the impacts in Australia’s national accounts.
  • If activities enter the national accounts, credits from those activities would become allowable offsets under the carbon pricing mechanism and would no longer be eligible under the Non‑Kyoto Carbon Fund.
  • Fence sitters will be delighted. There will be arrangements to help stakeholders to manage uncertainty around the timing of any transition.

What happens if non-kyoto activities are brought into the Kyoto framework? The proposal is :  A voluntary opt-out clause would allow Non-Kyoto Carbon Fund participants to choose to sell to other buyers, if activities become eligible offsets under the carbon pricing mechanism.

What happens from here?  “The Department of Climate Change and Energy Efficiency will continue to consult with stakeholders on the design of the Non-Kyoto Carbon Fund. Interested parties are encouraged to make submissions on the proposals outlined in this discussion paper.

Draft program guidelines will be published in the first half of 2013, for further stakeholder comment. This will be followed by the release of final program guidelines prior to program commencement.”

In the mean time, if you are an interested stakeholder – Submissions are accepted until 14 Dec 2012 from stakeholders. Follow the full discussion and make your comments as described and email to cfi@climatechange.gov.au .