Obama considers Draft Agricultural Soil Credit Standard

Concepts such as ‘additionality’ and ‘permanence’ as designed for industrial sequestration and mitigation projectts are not approprite for agriculture, according to the authors of a Draft Agricultural Soil Credit Standard that will be submitted to the Obama Administration which is designing its Cap & Trade system. The Iowa and Illinois Corn Growers Associations commissioned its consulting group Novecta to compile “an agriculture-based, industry-supported standard for the creation of carbon credits that can be marketed in a commodity trading system.” A committee of industry and trade reporesentatives are directing the project.

The Draft Standard features new, agricultural-based, definitions of additionality and permanence, two criteria which are critical to fungible carbon credits. “Typically, industrial credit projects are very stable and have specific points of measurement. Changes in carbon emissions or mitigation of emissions can be measured at a specific site over an agreed upon period of time, supporting the existing definitions of additionality and permanence. Agriculture does not fit well into the current model because production occurs in annual cycles influenced by seasonal activities and varying weather patterns. Soil types, irrigation, use of fertilizer, natural disasters, and individual producer situations contribute to the variability of agriculture,” says the Committee.

ADDITIONALITY REDEFINED

The Corn Growers have reconceptualised additionality to remove the ambiguity of the need to read motivations to determine intention. Ie. business as usual is no longer the source of perverse outcomes because farmers who have been sequestering for years are punished and the emitters rewarded for their late arrival. The replacement is much simpler: “GHG project activities shall result in carbon benefits additional to those that would have taken place in the absence of the activity and that are not already required by law or regulation.”

The Committee believes that additionality for agriculture “results from a cropping cycle that is either planted directly or is naturally occurring as in rangeland. If there is more carbon in the soil at the end of a crop cycle than there was in the beginning of the cycle, then "additionality" has occurred.” It says that this definition is “supported by existing science”. The Committee also assets that science also supports “the concept that
agricultural carbon becomes more stable over a period of time as it migrates to greater soil depths.”

Additionality also occurs when reducing emissions from standard agricultural practice such as the application of fertilizers or the use of farm equipment. The Standard considers that “additionality results from the ongoing augmentation and maintenance of existing soil carbon stocks as well as from avoided emissions.”

PERMANENCE REDEFINED

Permanence has also been redefined in a way more suitable to agriculture. The concept of collective persistence will ensure duration over time. Soil carbon reserve pools (implicit and/or explicit) would serve as a risk buffer to provide insurance of adequate credits should a Project Owner fail to produce agreed upon quantities.

Permanence is “a function of the farm aggregate collectively using credit practices of avoided emissions and carbon sequestration rather than the function of an individual producer.” While individuals might temorarily change their sequestration rate for whatever reason, not all farmers involved are likely to do the same. “As an aggregate there is a
collective persistence of carbon credits,” says the Committee which states that more work will be done to substantiate the claim that when the effects of large groups of producers are measured collectively, credit practices increase each year.