In defence of CMAs on Additionality

In defence of CMAs, their Additionality predicament is easy to see. Soil carbon came out of left field, catching many off guard. Some dismissed it can 'a silver bullet' and suspicion was so high one CMA struck the term 'soil carbon' from its communications. The targets set for CMAs could be easily achieved were the soil carbon solution unleashed. So, without realising that the Additionality Principle existed (and convinced by the campaign to talk down the prospect of soil carbon offsets that they would never eventuate), various programs were run to engage farmers in soil carbon sequestration. There could be no intention to harm the interests of farmers. But those defining the parameters of the National Carbon Offset Standard should be aware of the Additionality Dilemma and weigh the consequences of a strict Kyoto interpretation. The flexibility built into the Prime Carbon soil carbon unit - based on the now proven theory of in-soil photosynthesis - offers farmers who have already made a shift to carbon farming an easy way to achieve Additionality..
Government aqencies should make submissions to the Domestic Offset Integrity Committee to rectify the injustice of punishing early movers by reinterpreting the ADDITIONALITY PRINCIPLE.


The stars indicate CMA Targets that could be achieved with a market-based solution.

It's Official: Best Farmers Will Be Penalised

Government agencies such as Catchment Management Authorities may have led farmers to disqualify themselves from earning money for growing the carbon in their soils. Farmers who switch to green farming practices before the Government’s new Domestic Offsets Integrity Committee (DOIC) decides on a method of measuring soil carbon will be shut out of the market, if Kyoto principles are strictly observed.
Maya Stewart-Fox, Director, Emerging Markets, Department of Climate Change & Energy Efficiency indicated in her presentation to the Carbon Farming Conference that the Government wants a strict interpretation of the Kyoto principles. If DOIC insists on a black and white approach to the Additionality Principle, many thousands of Australia’s best farmers will be denied access to the market for soil carbon offsets because they have already made the change to ‘carbon farming’ and don’t need an incentive to achieve the Government’s goal.

The reasoning behind the Additionality is explained below.

The number of farmers affected by this “Additionality Dilemma” would be in the thousands, and they would be the best farmers in their districts. How did this happen? Plainly the CMA’s involved were not sufficiently aware of the Additionality Principle when they were advising their ‘clients’.

What options exist for farmers affected? They are few: 1. Cop it sweet and accept the advice of so many advisers that they should not look upon carbon offsets as a revenue stream, but only as a side-benefit. The farmer, according to these advisers (invariably not farmers themselves), should be satisfied with the environmental and production benefits. 2. Burn and plough rigorously to reduce your soil carbon levels and establish a new ‘business as usual’ from which you can possibly remake the change and qualify. 3. Join other affected farmers in a class action against the government agencies to recover the lost revenue. 4. Lobby the government agencies, farmers associations and other advisers who promoted the advice mentioned in point 1. to put pressure on the Commonwealth Government to abandon the Additionality Principle for Agriculture.

As a general word of warning, commentators such as farmers' associations, government extension services, and others whose role involves giving advice to farmers on matters relating to carbon markets should be aware that there is a possibility that such advice might be construed by a court as relating to financial or investment decisions, exposing the advice-giver to an action in law for losses incurred as a result of acting on their advice. In cases where the advice-giver holds out to have expert knowledge on which the farmer can rely, there is a possibility of a class action.

The Carbon Coalition's advice is for the CMAs involved to seek legal advice on the issue and to join the Coalition's campaign to have the Additionality Principle reconfigured for the Agriculture sector.

Our advice on Additionality, 2008 - THEY WERE WARNED

THE FOLLOWING BLOG ENTRY FROM 2008 - THE CARBON COALITION RANG THE BELL

Getting ready to trade? What about “Additionality”

According to the experts, all projects that aim to earn carbon credits must pass the “Additionality” test. This is to prove that the emissions prevented or sequestered were the result of deliberate action designed to qualify for carbon credits and not the result of ‘business as usual’, ie. would not have happened anyway.

We cannot tell you what to do because the Government has got to decide. But here is the system presented by the UNFCCC. It is a 4-step process that analyses the project to ensure that it would not have happened without the revenue from the carbon credits.

STEP 1. Identification of alternatives to the project activity consistent with mandatory laws and regulations. Were there other viable options beside the carbon-related activity?

STEP 2. Investment analysis: Of the options, is the proposed project activity unlikely to be the most financially attractive or unlikely to be financially attractive?

STEP 3. Barrier analysis: (1) Is there at least one barrier preventing the implementation of the proposed project activity without the promise of credits; and (2) Is at least one alternative scenario, other than proposed project activity, not prevented by any of the identified barriers?

STEP 4. Common practice analysis:
(1) No similar activities can be observed?
(2) If similar activities are observed, are there essential distinctions between the proposed project activity and similar activities that can reasonably be explained?

NOT ADDITIONAL: A Project is not additional if it would be a financially-attractive option without the carbon credits and there are no insurmountable barriers preventing implementation that make the carbon credits essential.

ADDITIONAL: A Project is additional if, compared to other investment options, it is either financially unattractive or faces insurmountable barriers without the ingredient of carbon credits plus it is not common practice in the location or has unique features which make it a risky option.

COMMENTARY: These tests for Additionality were designed for CDM projects, usually clean energy projects in ’developing’ countries, not soil sequestration at home. But like so many Kyoto Principles invented for one purpose, they are likely to be applied inappropriately to other categories of climate change solution. The Investment Analysis would knock carbon farmers out because their low input regimes can turn a profit when high input farmers are struggling. The Common Practice test would rule no till cultivation out in WA and SA where more than 50% of farmers practice it.

But there is no escaping it. Additionality is the top rating issue with Voluntary Market offset buyers, according to the annual survey by Ecosystem Marketplace & New Carbon Finance.

Will “Additionality” rob you of soil carbon credits?

A report in Australian Farm Journal (June, 08) featured a farmer getting his first cheque from Landcare CarbonSmart for locking away land for 100 years, planting trees on it. The farmer said the planting would have happened anyway, without the small amount Landcare pays. And here’s where the Kyoto Accounting Principle “Additionality” rears its ugly head.

The Rule is: “Business-As –Usual” doesn’t qualify. It must be a change in land management in direct response to the climate change challenge and it must be dependent on the additional money for it to happen.. The carbon sequestered must be ‘additional’ to what would have been the case anyway.

It’s not hard to see a whole raft of farmers who have already moved to carbon farming techniques being locked out of the carbon credit market because the Kyoto accountants say they made the change without the promise of carbon revenues; or they are unable to prove that their intention was to sequester CO2 and their motive was money.

If the Government sets a date before which changes to carbon farming are not eligible and that date doesn’t go back far enough, then the pioneers who did the hard yards – like Col Seis who invented pasture cropping and has socked away hundreds of tonnes of carbon per hectare – will miss out. With 85% of WA farmers no-till and 50% in SA, you can see the scale of the injustice.

The Carbon Coalition has been told by high-ranking public servants that the Government is keen to avoid “perverse outcomes” such as farmers left out of the scheme returning to the plough and stubble removal and set stocking for a spell so they can qualify for the credits. (The worst outcome.)

Why has no advice been given out to protect the interests of farmers willing to change to do their bit? Because while they would mention additionality in the long list of reasons why soil carbon could not ever be traded, they never thought the day would ever come when farmers would need to know about it.

There are several reasons why Additionality could be a blockage to maximizing our response to climate change:

1. It relies upon the fiction that a person’s intention can be known and that documents can prove it.
2. It ignores human nature and the impact on a carbon farmer who made the move early and missed out seeing their destructive neighbour being rewarded.
3. It is an absolute failure in its everyday application in the Clean Development Mechanism (CDM) market. Billions of dollars are being paid to Chinese energy companies for projects that clearly are not within the bounds of Additionality.

Additionality was introduced for CDM market. It is an international system established by the Kyoto process that allows rich countries to meet emissions targets by funding clean energy projects in developing nations. The market for CDM credits is is worth nearly $20bn a year, but this is expected to grow to over $100bn within four years.

Two senior Stanford University researchers examined more than 3,000 Chinese projects applying for or already granted up to $10bn of credits from the UN's CDM funds. They concluded that the majority should not qualify. "They would be built anyway," says David Victor, law professor at the Californian university. "It looks like between one and two thirds of all the total CDM offsets do not represent actual emission cuts." All new hydro, wind, and natural gas fired projects in China claim credit for emissions reductions under the CDM, each makes the argument that it would not have been constructed but for the carbon offsets. But the Chinese Government has policies to support clean generation. Even more revealing, nearly three quarters of all registered CDM projects were complete at the time of approval, suggesting that CDM money was not needed to finance them. International Rivers’ Patrick McCully, who makes the allegation, says: “ Judging additionality has turned out to be unknowable and unworkable. It can never be proved definitively that if a developer or factory owner did not get offset income they would not build their project."

Carbon Coalition First Cab off the Rank for Carbon Farming Initiative

The Carbon Coalition handed over the first submission of methodologies under the National Carbon Offset Standard (NCOS) to the Commonwealth Government on Wednesday, 27th October at the Coalition’s Carbon Farming Conference in Dubbo NSW. It was received by Maya Stewart-Fox, Director, Emerging Markets, Department of Climate Change & Energy Efficiency who addressed the Conference.
The submission outlines methodologies for 5 different farm activity areas: soil carbon sequestration, emissions from fertiliser use, revegetation on defined areas, water efficiency and reduced use of lime. These units have been designed by Coalition member Prime Carbon in response to an invitation from Climate Change Minister Greg Combet who announced that the Government was looking for 'firms to come forward with new approaches for other domestic offsets that are not currently counted towards our Kyoto target, including soil carbon and forestry.’
The Government announced the make up of the Domestic Offset Integrity Committee which will assess submission as part of the Carbon Farming Initiative. It includes soils expert Professor Annette Cowie, who spoke at the Conference.

Pictured at handover of the first series of Carbon Trading Methodologies by the Carbon Coalition at the Carbon Farming Conference in Dubbo 27 October, 2010 (left to right) Louisa Kiely (Director, Carbon Farmers of Australia, conference organisers), Maya Stuart-Fox, (Director, Emerging Markets, Department of Climate Change & Energy Efficiency), Bret DeHahr (National Facilitator, Landcare), and Ken Bellamy (Prime Carbon, designer of offset methodologies).
PICTURED Ken Bellamy (Prime Carbon) and Maya Stewart-Fox (DCCEE) shared the podium at the Carbon Farming Conference.

Come back James Porteous

("Trading carbon" in ECOS 14 September, 2010) ECOS spins the prayer wheel: [our responses in brackets]: "Several hurdles need to be cleared if Australian farmers are to become carbon traders. First, there is no well-established, cost-effective method of accurately measuring and monitoring soil carbon." [How many resources have been devoted to it to date? The injustice. Starve a problem of research attention then criticise it for having made no progress. Besides, Veris On-The-Move NIS Probe technology can measure soil carbon with a 90% confidence rate.] "Second, while NCOS offers guidelines for voluntary trading, there is no guarantee that the scheme will take off." [There is no guarantee that the Sun will rise tomorrow.] "And third, scientists still don’t have a very good idea of how effectively the various ‘carbon-friendly’ management strategies actually increase soil carbon." [So what? Ben Norton's work on the collective inability of scientists to reproduce soil and vegetation responses to management that thousands of farmers on three continents have experienced - in the McClymont Lecture 1998 - suggests Science will never recognise the potency of Carbon Farming.]

Prayer wheel: "... accurately monitoring changes in soil carbon is currently prohibitively expensive." [One proposed methodology eliminates a major cost factor by setting Bulk Density at a constant of 1 - which eliminates the need for expensive analysis while favouring the buyer. This is the type of creative, imaginative thinking needed for solving this and the other puzzle.

Prayer wheel again: "Central to the third problem – the question of effectiveness – is the issue of ensuring that sequestering soil carbon is indeed a good way to mitigate or reduce greenhouse gas emissions. Ultimately, this will depend on how policy dictates that farmers who plan to trade carbon use their land." [Government cannot dictate land management practices for trade. ANy farmer who wants can submit a methodology to any one of the string of certifying bodies in the world (VCS, Gold Standard, etc.) can trade under their standards. "....There are a number of approaches that, although they will increase the amount of carbon sequestered, will also increase emissions –which farmers don’t need to account for in the current iteration of Australia’s voluntary market." [Current Government policy is to incentivise farmers to reduce emissions rather than to 'dictate' to them what they will do. This pathway was chosen because the measurement of emissions at enterprise level is more problematic than measurement of soil carbon. No one has suggested that farmers will be forced to account for their emissions under any scheme proposed. Why does this issue continue to be raised as a barrier to trade?]
And so on... This article is just another iteration of the Complexities Syndrome that afflicts those suffering Future Shock. As Rattan Lal told the soil science community in 2007, "The train is leaving the station. Get on board."


PS. Whatever happened to James Porteous? He "got it."

Soil scientists say farmers don't need the money

"There’s a virtual consensus among soil scientists that Australian farmers shouldn’t need any extra incentives to increase their levels of soil carbon." Thus spake Ecos, the mouthpiece of CSIRO, which, according to legend, is the hungriest research body when it comes to funds, so say the many scientists it has worked with in collaborative projects. Now the author of this line in a Sept. 15 article on trading soil carbon - Adam Barclay - was either being naive or deliberately provocative. No matter, for here we have the reason why so many scientists work actively against farmers' rights to sell the carbon they grow. They don't believe that the farmers deserve to be paid for performing environmental services. Which explains the torrent of articles like this one, that raise complexities without seeking to resolve them, implying they make trading soil C impossible. Most of these complexities are either solvable by someone with an imagination, something few scientists possess, or they are irrelevant window dressing.
For the sake of accuracy and for the public record we will do a thorough job on the many absurdities in this ECOS article soon.

Mary MacKillop, Patron Saint of the Unreasonable

"The reasonable man adapts himself to the world; the unreasonable one persists in trying to adapt the world to himself. Therefore all progress depends on the unreasonable man." George Bernard Shaw, "Maxims for Revolutionists"

I knew them as Sister Bede and Sister Terese. They were my Mother's Grandfather's sisters. They were brown Saint Joseph's nuns. Irish Catholic women who joined Mary MacKillop's band of revolutionists who believed the poor should be educated to be freed from their serfdom. I was taught by brown St Joseph's nuns. They didn't look like revolutionists. But they were very confident and outgoing. Lovely women with a strong social consciousness.. Perhaps I was infected with their founder's defiance of institutional authority. When her independence offended the Irish Catholic bigots who served as bishops in the colonies, and they tried to bring her to heel, she did not succumb. She went to Rome and convinced the Pope to break with tradition and free her Order from priestly control. Mary MacKillop, Patron Saint of the Unreasonable. Please give us the strength to be unreasonable when ancient rules block humanity's progress.

Moneychangers in the Temple

Whenever soil carbon sequestration is reduced to a transaction between a buyer and a seller, the process is transformed, at the hands of the reducer, to a grimy money matter when what is taking place is a genuine attempt to correct an imbalance that threatens everyone. I detect a tone of disapproval whenever the trade is mentioned, as if the farmer should do the right thing for no recompense and that this holy vocation should not be sullied by moneychangers in the temple. The paranoia that someone might get rich on the proceeds of sequestration is just that, paranoia. The reality is that the market will meander and falter for some time because the price will be set far too low for farmers to risk getting involved. Measurement will never be exact, but estimated (as is tree carbon). But the real progress will be made when the need to wait for perfect science is recognised as a dangerous distraction. Prof. Annette Cowie and Dr Graeme Pearman have both said recently that to wait for perfect science will be too late. We need every landholder to start maximum sequestration, whether we can measure it or not. So long as we know the amplitude and the frequency of flux we can calculate a mean score that will allow trade to proceed. The way I see it, a buyer buys a tonne of CO2-e not to consume or wear it, but to know it has been immobilised for a period of time. If one customer gets half a tonne and another gets a tonne an a half, both should be satisfied that they got value. But there is more to the strategy than thre transaction. We must work within the dynamic reality of carbon. It cannot be prevented from cycling because it is carbon and must do so. But we can 'stall' it long enough to give renewables time to reach a baseload capability which can meet the world's needs. So the real process that is going on is not a series of simple transactions. It is the change of behaviour by the land manager we need, a change in behaviour for long enough that it becomes a change of attitude which eventually becomes a change of culture. And that is Permanence. In any scheme we are involved with the units will be retired on the first trade to prevent exploitation by market manipulators, farmers will never be called upon to make good losses by drought, etc. because they will put up an extra tonne as surety for every tonne sold, which errs on the side of the buyer, and the distribution of thousands of growers across climate zones will spread the risk. Contract duration will be based on what is acceptable to growers, otherwise there is no point. The price of measurement is reduced by setting Bulk Density at a constant value of 1. This eliminates an expensive step and also errs on the side of the buyer. Trade is not the main game. It is a catalyst for a process that aims to fulfill a role of soil and atmospheric rebalancing. Not one that aims to satisfy a set of accounting rules that are not relevant to the task at hand. Which is behaviour change by the greatest number, including the intransigent majority, deaf to the entreaties of CMAs, Landcare Groups, and extension officers to do the right thing by the environment. Money makes their world go round.

"Doubt is our product": The Uncanny Similarity of Strategy

There is an astonishing likeness between the strategy used by CLimate Skeptics to derail action against Climate Change and the strategy used by those opposing the trade in soil carbon offsets. The Grand Strategy that led to success for the Climate Change Denialists was developed by the American Petroleum Institute, and leaked in 1998 to the New York Times in the form of a memo that stated: “Victory will be achieved when…recognition of uncertainty becomes part of the ‘conventional wisdom.’” It was the same strategy used by tobacco companies to fight the fact that smoking causes lung cancer. A tobacco company memo from the late 1960s, which observed: “Doubt is our product since it is the best means of competing with the ‘body of fact’ that exists in the mind of the general public. It is also the means of establishing a controversy.” (1)

The following is a prime example of the Anti-Science of Soil Carbon: Complexity is a reason why soil C should not be traded, rather than as a problem seeking a solution."There are numerous complicating factors that will need to be addressed and dealt with explicitly in any market-based GHG trading scheme that involves C-sequestration into grazed ecosystems." (2) (See The 10 Complexities below.)

It was after several months of exposure to similar false assertions of complexity that the Victorian Parliamentary Committee of Inquiry into Soil Carbon Sequestration decided: “Due to the significant scientific and economic uncertainties associated with soil carbon sequestration, the Committee concluded that a cautious and conservative approach should be taken in establishing incentive mechanisms to encourage soil carbon sequestration in Victoria.”

Nearly every one of the 10 Complexities can be eliminated with a small amount of common sense. But this scientist is not interested in solutions. Complexity means risk. Risk means insecurity. Insecurity means fear. And to make sure the policymaker reading this paper feels the fear, the scientist becomes hysterical: “The existence of the above and other real-life complexities will render market-based C-trading schemes involving pastures, exposed to the risks of complicated, ill-conceived, ill-understood, poorly regulated financial instruments and arrangements that are replete with opportunity for fraudulent scams and inappropriate diversion of community wealth to the personal fortunes of scheme managers and traders, while not delivering the scheme objectives, reminiscent of those involved in the Global Financial Crisis of 2007-2009.”

The 10 Soil Carbon Complexities:

"These include, linked emission and/or uptake of methane and nitrous oxide associated with management changes for achieving changed C-sequestration, the impact on C-stocks of wildfire frequency and intensity, compensatory non-domesticated animal grazing, and large scale movement of high-C surface topsoil by flood and wind, difficulties of defining baseline C-stocks and baseline GHG fluxes from each patch of land under consideration especially when the requisite baseline is in the past, long time-frames (several decades) required and high expense for measuring change in C-stocks in each patch of land under a scheme, the high actual input-value or opportunity-value of the mineral elements associated with increased organic C stocks, the special status of any lands that have already been defined as “Kyoto Lands” by coming under Kyoto Protocol arrangements, and the interaction of C-sequestration with other environmental externalities that are coming under different management policy arrangements such as interactions with hydrological and biodiversity policies."


(1) Chris Mooney, "Some Like It Hot As The World Burns", MotherJones May/June 2005 Issue
(2) Roger M. Gifford, CSIRO Plant Industry, “Carbon sequestration in Australian Grasslands: Policy and Technical Issues”, Proceedings of FAO workshop on The role of grassland carbon sequestration in the mitigation of climate change
Rome, 15-17 April 2009

Important link between polluters and farmers

The Carbon Farming Conference is “probably one of the most important conferences that the region could have", according to Nationals MLC Duncan Gay. "The importance of the interaction between farmers and carbon polluters is integral to the future. Carbon is deficient in our soil and it is important to take measures to fix it.”

Conference pie has meat, not just pastry, says Matt Cawood

"A lot of conferences are memorable for the networking you do between sessions. The Carbon Coalition conferences are memorable for the sessions, as well. Other public discussions of soil carbon tend to be along the lines of "perhaps, but ...". The Carbon Coalition conferences ask "why not?". That's a much more productive place to be starting from.'

Matt Cawood, Muddy Green.

Muddy Green is a meaty blog on enviro-agricultural-food integrity issues.

New ways to enrich soils

The Carbon Farming Conference and Expo at Dubbo on 27-28 October, has an astonishing line-up of soil treatments:
Coal or fly ash is available in vast quantities because power stations have mountains of by-product after coal is burned, most of which is buried in landfill. Scientists are testing different combinations to make controlled release fertiliser.
Chailings is charcoal made from coal mine tailings. Farmers have proved for themselves that production can be boosted by the application of raw coal dust. Chailings are processed for greater effectiveness.
Compost can create odor and take a great deal of turning to reach its point of peak effectiveness. But a new on-farm system eliminates both problems. Spray inoculant over the compost and it turns itself,
Exhaust fume burial is a novel approach to disposing of emissions by processing them into a fertiliser and wrapping them around the seed.
Soil biology stimulants or ‘triggers’ work by ‘waking up’ native microbes rather than by delivering the microbes to the soil. This means the stimulant can be delivered in a spray pass with herbicides. This makes it economic to treat broadacre operations.
Soil biology catalysts are agents that respond to the needs of the plant by delivering the correct nutrient when it is needed.
There are 30 speakers scheduled on the program.
For further information, 02 6374 0329
Conference web site: www.carbonfarmingconference.com.au