Movements – a Viable CFI methodology

Under debate for some time has been whether reforestation, and afforestation should be part of the CFI. It was thought only conservation planting was viable as a measure under Natural Resource Management (NRM) rules. In more recent times part of discussion was a concern that political movements would be disruptive.

Two announcements made by the Australian Government on these matters by newsletter on 12 April 2013 may be helpful for the debate. Namely:

  1. First reforestation and afforestation project approved, and
  2. No changes to methodology development following changes to the Cabinet.

Posted on April 8, 2013 by co2land, Makers – a Viable CFI methodology the point was made it is not a simple process to develop CFI Methodology and program rules are a major factor in participating, and the recent Government announcements will address most of those points (but not the coalitions position).

On point 1: The Clean Energy Regulator under the Carbon Farming Initiative has announced the first project using the Carbon Credits (Carbon Farming Initiative) (Reforestation and Afforestation) Determination 2013. There are now 53 projects approved under the Carbon Farming Initiative. All projects declared eligible under the CFI Act are published on the Register of Offsets Projects.

On point 2: Work on the development and assessment of Carbon Farming Initiative methodologies undertaken by the Department of Climate Change and Energy Efficiency (DCCEE) will continue apace under new Ministerial Responsibilities announced recently by the Prime Minister.

DCCEE’s energy efficiency functions will be have been transferred into the Department of Resources, Energy and Tourism (DRET) while the remaining policy functions currently performed by DCCEE, including the CFI, will be have been transferred to the newly-named Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education (DIICCSRTE).

Former DCCEE staff working on the CFI and other land sector measures will move to DIICCSRTE and continue their work accordingly.

Whether participating in CFI or not is still very much a matter of it depends on the location and the carbon sequestration rates that would be possible for it to be viable.

If we start by avoiding the cost of participation discussion, one non-scientific way to help you decide is to ask: Did the area to be used have really large trees present in the past? If yes it could be very viable. It follows that nature will want to regenerate those areas into large carbon rich forests. In gathering your evidence you could include old local history photos of the areas showing the large density of trees on them. In choosing a more scientific way: Gather the Lot & DP numbers and/or GPS points, and the CFI environmental tools should be useful to tell the landholder the likely sequestration rates. However, as we said in the former Co2Land org post the uncontrollable factor in proving if it is viable is the price of carbon. Notice it was not said the ‘carbon price’ as that is an artificial price set for the transition period.

If we focus on the cost of developing a methodology for inclusion into the CFI program register the major factor is cost in terms of the capability to enter into initiative. You may find innovation is required for a “creative” way to recover the cost of developing a methodology. Or is it? It follows that once published on the climate change website it becomes public information. However, it will still take some effort and there will be a need to lobby Government to allow the methodology to be used by another entity. In equity you should anticipate any agreement might require a royalty payment to the original developer.

If you can overcome the matter of cost, it becomes a question of what CFI environmental tools you refer to for the CFI Mapping and Reforestation Modeling tools. Also the methodology costs will depend on the level of verification and any additional research required, in many cases there are sufficient prior studies (such as survival & growth rates in the targeted region) and accepted calculation methods to do this could be found from a literature search, or you could talk to others trying to develop the same thing. It is understood the web page: http://www.greeningaustralia.org.au/our-projects/land/bio4 will promote further research on this matter.

One suggested project to study as a background search is the NSW Blacktown Council and their Regenesis Project. That project has lessons that can be of benefit to be aware of in your deliberations. One example lesson is they had a significant grant to develop their concepts and actually generated the first carbon credits only to have a later policy decision rule projects within urban boundaries to be ineligible. Notwithstanding, the core of their work is valid. You can view the Regenesis projects on the website – www.australiancarbontraders.com and then click on the Regenesis link on the front page.

So frustration will continue and innovation continues to be encouraged – for those eligible – and that suggests you need friends to be recognized as able to be innovative. At cross purposes you might argue!  An anonymous friend, name provided but withheld, said “in an entirely different forum some years ago we flagged this as a problem for the then announced Innovation Strategy. The senior public servant delivering the local launch responded: We can’t have people solving problems in unique ways that we can’t predict, you wouldn’t know where would it all end up!

It would seem the core problem with the current grant model is that it is primarily a funding model for the usual suspects, as practiced the truly (open) competitive component is only a small % of the funding available.

We need a better approach that covers needs of Universities and commonwealth and state research agencies separately.”

Then we hear funding has no longer been provided for strategic innovation!

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Contaminated Land – Obligations to manage

In conversation, we discussed an old tannery site, and it occurred ‘obligation’ to manage was not understood, or meant different things to different people. For instance, a Carbon Manager would say it is more than accounting and reporting, it is about bringing about a change in thinking of the moral and legal rights in terms of the strategic directions to exist in a carbon constrained world – that is to manage the objectives of the change.  A Commonwealth Officer might say the extent to which an obligation requires management is highly dependent on the existing or proposed future need, and the management need is to present a number of risk of that that will be decided, or in turn generate obligations as a strategy. The later could be a recommendation to do nothing.  It gets down to the officer can say as no legal obligation exists, regardless of the evidence, we can do nothing until it requires management and the risks can in turn generate obligations for funds. Sounds familiar does it not!

Why funding as the trigger? It is the means of executive power.  What about the moral need to save the planet? The current trend is evaluations and the measure is the cost – benefit and reactions that convert into immediate comforts. Another issue is that we no longer learn by experiences, we are swayed by opinions and the need for immediate comforts.

If we concentrate this post on contamination of land, the decision-making, and factors of risk management, capability and efficiency of expenditure we can see an interesting overture of what is management. It we think of the range of historical uses for land that has resulted in a wide range of contaminates we can note examples of nuclear activities, military training, radio transmission, fire fighting, printing, fuel storage and numerous infrastructure responsible for hazardous materials. Then there is another problem where pre-existing contaminated sites are then used to add other contaminates with the justification it is already contaminated, so the risk is lower.  It might surprise you but in 2011 the Australian government audit of its properties found approximately 30% to have known contamination issues, and the remaining have issues yet to be identified. That is not a typo, it was written – yet to be identified, and much of the concern is waste dumping. If you wonder how many properties of concern in the audit, the Department of Finance and Deregulation’s 2011 Land Audit reported 1197 properties of which 355 are known and 842 are potential issues.

Asking the question on what is the legal obligation to act on the site, it was clear the Carbon manger and the government officer had a different management view. Yet, both claim a long term view. The former is the actions will ensure a long term benefit, the later saying funds would address the risks in the long run!

To analyse the obligations of the Commonwealth, there is no legal obligation to remediate because contamination is present..  The more likely driver is the presence of risks which can generate obligations to fund remediation. These risks can include:

  • Workplace, health and safety risks and associated legislative obligations;
  • Public safety risks and associated liability exposure;
  • Potential degradation of Commonwealth assets;
  • Ecological impacts; and
  • Off-site impacts beyond the boundary of Commonwealth Land.

The key to all above is the extent to which contamination requires management is highly dependent on the existing or proposed future use of the land. It is not the moral obligation to make it right.