Science Fiction, for Certain

Measurement The key issue with measurement for the purposes of trade is not accuracy but certainty. The buyer needs to know that they are getting at least as much value as they are paying for. Every transaction requires an assessment of risk. There are several ways to manage risk in commerce: accurate measurement where possible and a margin for error based on a high degree of probability where it is not. There are several ways that soil carbon can deliver 95% certainty. But buyers of offsets based on avoided emissions - such as alternative energy - have no guarantee that the tonne of coal that was left in the ground as a result of their purchase will stay there for any length of time. Yet sellers of these offsets are not required to guarantee that this tonne of coal will remain unburned for 100 years. It can be measured accurately but it can't be guaranteed at even 5% certainty. The Kyoto Protocol is structurally biased against biosequestration. The 100 year rule has no technical or scientific basis - it was a policy decision. It is not based on the decay profile of a tonne of CO2 as we have been led to believe. The Permanence Requirement is a legal fiction. The fact that it was even considered for soil carbon proves that either the IPCC was ignorant of agricultural reality or there was a conscious attempt to block agriculture because the architects of Kyoto have a prejudicial view of farmers as climate vandals who should not be rewarded for doing the right thing anyway. The CSIRO's ECOS magazine let slip in September 2010 that 'there is a virtual consensus among scientists' that farmers should need no incentive to build soil carbon. Senior CSIRO scientists have described anyone associated with the trade in carbon farming offsets as ethically challenged. Scientific objectivity is another fiction. The dearth of soil carbon data... who chooses what will be studied and how? How many learned papers appear to prosecute the case against soil carbon? How does the buyer of soil carbon science (us) measure what we get for our money? What does unsound science look like? It looks the same as sound science to the untrained eye. Policy makers should learn to tell the two apart.

Why is it so?

How is it that they tell us we cannot measure soil carbon with sufficient accuracy to trade it... but they are able to measure it accurately enough to tell us that soil carbon can only be increased in miniscule increments?

Climate Change Department Abandons Carbon Farming?

A Department of Climate Change discussion paper denies that Carbon Farming will become as big as the wool industry, putting it at odds with the Government’s chief advisor Professor Ross Garnaut. The paper predicts that landfill operations will contribute more than agriculture to the nations effort to reduce greenhouse gas emissions by 2020.

It is ‘a very flawed document’ according to industry representatives. “It severely discounts what farmers can contribute, including overlooking the soil carbon that can be captured in the 90% of agricultural land that is used for grazing,” according to Michael Kiely of the Carbon Farming & Trading Association. “By focusing on the 8% of land used for cropping the Department loads the dice against Agriculture because grazing has a much higher potential for carbon farming.”

The Department’s Paper makes every post a loser for the Carbon Farmer. For instance, it discounts CSIRO estimates for carbon abatement in cropping land because the N2O emitted as part of the process will need to be mitigated. There is no mention of the fact that the farmer can earn offsets for reducing the N2O emissions while at the same time earning offsets for capturing carbon.

The high costs of carbon farming is cited as a reason why uptake can be expected to be slow among farmers. But most practices for increasing soil carbon are low cost or involve cost shifting through product or process substitution.

A long list of routine activities are given as barriers to a fast start for Carbon Farming, such as the development of methodologies and briefing farmers and financiers. “The industry has been working on these issues for more than a year, so we are well down the track,” says Michael Kiely. “The main barrier to uptake by farmers are the blockage called Additionality and the risks called Permanence. No farmer will accept a liability for 100 years, especially for a low price.”

The Discussion Paper is based on several questionable assumptions: 1. Voluntary market offsets will always sell at a discount. “But domestic offsets were selling in Switzerland for 130 Euro while CDMs fetched only 15 Euros during 2010. And representatives from Mitsubishi Bank in Japan informed us that Japan is close to meeting its obligations using only a voluntary market.” 2. The Kyoto Protocol will carry over in its current form when the 2008-2012 obligation period ends. Yet the Department is actively campaigning to overturn the provisions making nations account for emissions from bushfire and drought. 3. The Minister must take advice from the Domestic Offset Integrity Committee. Yet ultimate Ministerial responsibility cannot be delegated.

The timing of the Document is also questionable, given its prescriptive tone, despite the claim that its object is to prompt discussion with stakeholders.

“The Government claims that the Initiative seeks to encourage innovation, yet this Paper appears to prosecute the case against land sector abatement. But there are solutions in the pipeline that can address the uncertainties that surround soil carbon.”

The main contribution made by the Paper is the declaration that the Department believes that, on its current trajectory, Carbon Farming may be useful only in the medium to long term. This belief is based on the assumption that we must wait for science to provide the answers, no matter how urgent the issue or slow the progress. “We now know that science has little to offer us in this time of urgency. We have neither the time nor the money for a scientifically-precise solution. Asking science to invent a market mechanism unaided is asking too much. It is a task for actuaries, merchant bankers, commodity market economists, and financial architects.”

Michael Kiely

Chairman

(02) 6374 0329

For more information about the Carbon Farming & Trading Association click here.

CSIRO misleads Senate Inquiry?

The CSIRO's Dr Brian Keating came as close as legally possible to giving false evidence to the Senate committee inquiring into the Carbon Farming legislation without falling foul of the law. He told what was technically the truth, but left out the fact that would change the facts.

He told the senators that ‘current research would suggest the abatement likely to be achieved, in the short term at least, is likely to be modest.’ True. But ‘current research’ does not include findings about the potential of 80% of the techniques used to build soil carbon. “Current research” covers nothing newer than 20 years old. It includes conventional, carbon mining practices, but not grazing management, pasture cropping, compost teas, biological inoculants, exhaust burial, Natural Sequence Farming – or the combinations of these techniques. “Current research”, the CSIRO will agree, is not very current.

Dr Keating neglected to tell the Committee that the CSIRO is in no position to comment on the potential of farmlands to store carbon because it chose not to study the performance of most modern practices. Instead it invested the $26.5m Soil Carbon Research Project money in studying conventional practices that are unlikely to qualify as offsets because of the Additionality principle called “Common Practice”. Dr Jeff Baldock, who leads the Project, has admitted that it covers only 20% of the relevant practices.(1)

Not all scientists think ‘current research’ is so negative about soil sequestration. In its submission to the Senate Inquiry, the Wentworth Group of Concerned Scientists used Brian Keating’s own work to paint a very different picture: “CSIRO has estimated the biophysical potential of the Australian landscape to store carbon.(2) Whilst only a proportion of the total potential is practically achievable and will take time to build the capacity for it to take effect, if Australia were to capture 15% of the biophysical potential of our landscape to store carbon, it would offset the equivalent of 25% of Australia’s current annual greenhouse gas emissions for the next 40 years.(3)”

The fact that Dr Keating has been appointed as a gatekeeper of the Carbon Offsets system as a member of the Government’s expert panel for judging methodologies – the Domestic Offsets Integrity Committee (DOIC) – allows him to be prosecutor, judge and jury in the CSIRO’s case against soil carbon. It would appear to be inappropriate and compromising to engage in the debate surrounding soil carbon.

This incident is only the latest outbreak of anti-soil carbon activity from the CSIRO, which includes the Soil Carbon Mythbusters national tour, the notorious “Hidden Cost of Soil Carbon Sequestration” scientific sleight of hand paper, and the announcement that there is ‘a virtual consensus among soil scientists’ that farmers should not be paid to grow soil carbon levels(4).

“Modern carbon farming is low input. It does not rely on expensive chemicals or genetic materials owned by foreign corporations who sponsor CSIRO research. It is understandable that the market-based co-funding model chosen by government has had this outcome. We don’t expect the CSIRO to bite the hand that feeds it. But we do expect transparency in its dealings with parliamentary committees,” says Michael Kiely, chairman, Carbon Farming & Trading Association.

1. Personal communication, October 2010.

2. CSIRO, 2009. Analysis of greenhouse gas mitigation and carbon biosequestration from rural land use. Edited by Sandra Eady, Mike Grundy, Michael Battaglia and Brian Keating for the Queensland Premiers Climate Change Council.

3. Wentworth Group of Concerned Scientists, 2009. Optimising carbon in the Australian landscape: How to guide the terrestrial carbon market to deliver multiple economic and environmental benefits. October 2009.

4. ECOS, September 2010.

Sydney Morning Herald 21 April 2011: “While forest carbon and soil carbon sinks are opportunities worth pursuing, current research would suggest the abatement likely to be achieved, in the short-term at least, is likely to be modest," Dr Keating told a Senate environment committee examining the CFI.

For more information about the Carbon Farming & Trading Association click here.

Tony Windsor - Hero of the New Agricultural Revolution

The Soil Carbon Solution has many friends in high places. None more important than Tony Windsor MP. This week he told the press that he wanted soil carbon offsets to provide an income stream for farmers and make agriculture more sustainable. ALthough he didn't say so, it sounds as though this will be a condition of his support for the Government's Price on Carbon legislation. He said he would support the package "if it's at all possible to do something meaningful... But if it's just going to end up as some sort of bullshit political arrangement, I won't,". Soil health is something meaningful. "There would be real benefits accruing if you could turn some of the income stream into pursuing more sustainable production," he said. "Irrespective of how great the global impact would be, there would be a positive national impact, and I guess in some ways it is a bit of an insurance policy."

Professor Ross Garnaut is another supporter of the Soil Carbon Solution. He recommended last week that soil carbon sequestration be linked to the emissions trading scheme, with up to 14 per cent of the revenue available for offsets by 2020. The final Garnaut report to the government on May 31 will include a budget on how to include the carbon offsets created by soil sequestration in the emissions trading scheme.

In search of a "Meth"

A 'Meth' is insider's lingo for 'a Methodology', ie. a process for generating a carbon offset under a program like the Carbon Farming Initiative. Carbon Farmers of Australia (the not-for-profit trading arm of the Carbon Coalition) is part of a consortium that includes carbon offset pioneer Ken Bellamy and IT object technology pioneer and farmer Gerry Carroll. This consortium is dedicated to breaking though the barriers against soil carbon offsets by innovating around the Integrity Standards and Measurement requirements set down in the Legislation.

If you hear the comment "They're only in it for the money..." please explain: all methodologies submitted to the Government's expert panel are, on approval, made freely available online so anyone can pick them up and use them and make money from them. This doesn't seem fair - to hand over intellectual property for free - when collectively the consortium members have invested more than $1m to get to this point. We have suggested to the Government that it follow the example of the Verified Carbon Standard and allow the methodology developer a small licence fee whenever it is used.

Why do this? To encourage innovation (which is one of the Government's objectives). We believe that there are people sitting on 'meths' that could get the process of restoring soil health, afraid that they will lose the value of their 'invention'.

Recommendations to the Minister

“So you want to rewrite the rules to suit yourselves?” Dr Brian Fisher, ex-executive director, ABARE (Australian Farm Institute Conference, 2007)

The Soil Carbon Solution

The Carbon Farming & Trading Association recommends that the Government extend its policy of giving Agriculture special status in Climate Change policy to grant special status to soil offsets on the grounds that the benefits to the community and the environment are of such a magnitude that to allow accounting rules to deny us them is a perverse outcome of an equal magnitude.

We recommend that a special class of offsets for soil carbon be defined that will enroll as many farmers as possible to sequester as much carbon as possible as fast as possible.

We recommend that, to meet that objective, the 100 year rule be replaced by a range of time frames to allow flexibility.

We recommend that the environmental definition of additionality be adopted, by which all carbon added above the baseline is deemed additional.

We recommend that the common practice test for additionality be abandoned because it contradicts the objective outlined above.

We recommend that the ‘business as usual’ rule, which penalizes Landcare farmers and other progressive landholders who have taken up carbon farming techniques early and rewards laggards who continue to degrade their soils.

We recommend that the offset unit be initially offered on the domestic voluntary market as an interim measure while measurement and other issues are resolved.

We recommend that the Australian Government expand the ambit of its campaign within the IPCC to have the need to account for non-anthropogenic emissions deleted from Article 3.4 into a broader initiative to fashion a regime sympathetic to sectors subject to biological cycles such as Agriculture.

Shocking facts

The following facts emerged during our search for solutions to our problems with the Legislation:

The Government says it wants broad involvement in the Carbon Farming Initiative, but the Bill puts several blocks in the way of farmer involvement:

• FACT 1: The 100 Year Permanence requirement puts such risk on the individual farmer that few are likely to get involved.

• FACT 2: The 100 Years Rule is not based on anything technical, such as the time CO2 hangs around in the atmosphere. (That would make it the 55 Year Rule, 55 years being the projected decay horizon of CO2.) 100 years is an arbitrary figure, plucked out of the air by the IPCC as a yardstick for comparing the potency of different Greenhouse Gases.

• FACT 3: The IPCC and the VCS have both approved periods such as 20, 25 and 60 years for biosequestration projects.

• FACT 4: 100 Years is a fiction. Offsets that rely on renewable energy to avoid emissions from burning coal are no more secure than those based on soil because no one can guarantee that the coal not burned today will not be dug up and burned at any time in the next 100 years. Yet offsets from avoided emissions do not need to guarantee the offset’s integrity for 100 years.

• FACT 5: The “Common Practice” Additionality requirement has the potential to exclude more than half the number of farmers in any district from earning offsets of any kind.

• FACT 6: Landcare farmers are very likely to be excluded from soil carbon offsets due to the “Business As Usual” Additionality requirement.

• FACT 7: To this day there is no scientific proof that grazing management works. Peer-reviewed science has proved many times that it is incapable of replicating the results that farmers get using Carbon farming techniques. Yet the limits of our sequestration potential are being set by peer-reviewed science.

• FACT 8: “There’s a virtual consensus among soil scientists that Australian farmers shouldn’t need any extra incentives to increase their levels of soil carbon,” according to CSIRO’s ECOS magazine. Does this explain why there is so little science supporting soil carbon sequestation?

Each of these facts punches a hole in the Kyoto Protocol’s façade of scientific integrity. Its rules are based on fictions and prejudice. The same flexibility that it allows itself should be allowed to soil carbon sequestration. Otherwise it will defeat the purpose of the Legislation.

PATHWAY TO AN OFFSET

Pathway to soil carbon offsets

The Carbon Credits (Carbon Farming Initiative) Bill as tabled is a strict, letter-of-the-law Kyoto interpretation which means one of two things: 1. The Minister isn’t aware that soil carbon offsets are not possible if Kyoto is applied literally. 2. The Minister is aware and wants creative ideas from us to retrofit Kyoto to Agriculture instead of the reverse. We believe it is No.2. The outcome will depend on how tolerant of creativity and risk he is.

There are three ways we can submit creative solutions to the Government:

1. By sending them direct to our contacts in the relevant Department or the Minister’s office.

2. By submitting them as part of a ‘Methodology’ to the Domestic Offsets Integrity Committee.

3. By submitting them to the Senate and House of Representatives Inquiries.

We use all 3 channels.

SOlL CARBON OFFSETS INEVITABLE

No long term without a short term

On our analysis, soil carbon offsets are inevitable. The world may not realize it yet, but there is no long term without a short term – and all offsets other than soil carbon can only have major impact in the long term. Climate Change is being driven by emissions that are 50 and 100 years old. Avoided emissions today will have an effect in 50-100 years. Forests planted today will not reach maximum capacity for 15-20 years. But the rangelands and pastures that stretch over 5 billion hectares are ready to turn small increases in carbon into massive draw down of CO2 in the next 50 years. This buys time for the necessary adjustments to be made.

Lobbying for Soil Carbon: Senate Inquiry & House of Representatives InquiryLobbying for Soil Carbon: Senate Inquiry & House of Representatives Inquiry

The Carbon Credits (Carbon Farming Initiative) Bill 2011 was tabled in Parliament on 24 March. We are making separate submissions to the Inquiries into the Legislation conducted by the Senate Environment and Communications Legislation Committee and by the House of Representatives Climate Change, Environment and the Arts Committee. They are due to report in mid May. The Minister wants the Bill passed by 1 July, 2011.

After that date, methodologies for offsets can be approved by the Domestic Offsets Integrity Committee and start operating. Of the dozen or so categories the Government recognizes, the first to be approved are expected to be forests (afforestation and reafforestation), savanna burning, manure management (piggeries) – because their methodologies are pre-existing or uncomplicated. Avoided emissions from fertilizer should follow and methane avoidance should follow that. Soil carbon - the problem child of the offset family – is expected to come in last, if at all. Some, mainly scientists and professional advisers, believe it will never happen.