What we told the Senate

Extracts from Carbon Farmers of Australia and the Carbon Farming and Trading Association (CFTA), Submission and Evidence appearing before The Senate Environment and Communications Legislation Committee in Inquiry into the Carbon Credits (Carbon Farming Initiative) Bill 2011 May 2011

2.12 To prevent progressive farmers from being penalised for practices they currently use to sequester carbon, the CFTA recommended farmers be eligible for credits for carbon they create in addition to a baseline, irrespective of the method(s) they use to do so.12 Mr Michael Kiely, Chairman of the CFTA, was careful to point out, however, that farmers 'should not be rewarded for what they are sitting on; they should be rewarded for what they create'.

2.43 For the CFTA, the permanence provisions were 'the deal killer'.44 Mr Michael Kiely, Chairman of the CFTA, stated: No farmer would be silly enough to agree to 100 years for soil carbon or 100 years for anything. A finance lender would want to know seriously the impact on the value of the property of agreeing to such a thing. We did some research into the 100 years thing and discovered it was a policy decision, not a scientific measure...We believe that 100 years is a perverse outcome. The result is said to be necessary so buyers can be confident they are getting value - that is, genuine abatement - so they get nothing. There is nothing available for them. We have found examples where the IPCC and the Verified Carbon Standard have allowed other periods of time recently - 20, 25, 30-odd years. We believe we could work within that sort of time frame.

2.57 Interestingly, Mr Michael Kiely of the CFTA believed '[t]he idea that fire and drought will destroy soil carbon has been very much overplayed by the science community'.60 Mr Kiely explained that two Australian carbon farmers of his acquaintance had 'increased their soil carbon by two and a half and three [percentage points] in the last 10 years, which was probably the worst 10 years that we have had, with the drought'.

3.8 Mr Michael Kiely, Chairman of the Carbon Farming and Trading Association (CFTA), highlighted numerous co-benefits associated with soil carbon sequestration and farming including:

¥ Greater yields and improved yield stability;

¥ Greater resilience to drought;

¥ Better cycling of nutrients;

¥ Increasing land value due to improvements in environmental quality;

¥ Cleaner and more reliable water supplies;

¥ Reduced flooding due to better water retention and slower run-off;

¥ More secure food and water sources;

¥ Reduced incidence and intensity of desertification;

¥ Increased soil biodiversity;

¥ Reduced soil erosion; and

¥ Reduced water pollution from pesticides and fertilisers.8

3.9 However, the Carbon Farmers of Australia and the CFTA were concerned that '[d]espite its potential role as a bridge to a low carbon future and all the co-benefits, Soil Carbon Solution faces institutional barriers to being traded as an offset'.9

Witnesses gave examples of variable timescales of permanence available under existing voluntary schemes, whereby credits can be purchased for 20, 25 and 30 year time frames: Mr Kiely - Permanence is the deal killer. No farmer would be silly enough to agree to 100 years for soil carbon or 100 years for anything. A finance lender would want to know seriously the impact on the value of the property of agreeing to such a thing. We did some research into the 100 years thing and discovered it was a policy decision, not a scientific measure. In some of the peer reviewed literature, we came across this proposition about avoided emissions - which are unquestioned; if you buy alternative energy, you are apparently substituting for burning a tonne of coal. Someone selling abatements for avoided emissions is not asked to guarantee that that tonne of coal will not be burnt any time in the next 100 years. It could quite possibly be; in fact it will beÉWe believe that 100 years is a perverse outcome. The result is said to be necessary so buyers can be confident they are getting value - that is, genuine abatement - so they get nothing. There is nothing available for them. We have found examples where the IPCC and the Verified Carbon Standard have allowed other periods of time recently - 20, 25, 30-odd years. We believe we could work within that sort of time frame.

For information about the Carbon Farming Conference & Expo and other Carbon Farming Week activities, click here.

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

'COmmon Practice' Uncommonly Complicated

The Additionality Rule has yet another unfortunate outcome: the Common Practice test on its own will create a bureaucracy the size of the current Department to administer its complexity. As the rule stands, a farming practice qualifies as "Additional" if it is not common practice in its industry, part of its industry or in the type of environment the farmer is working in. If it is not common practice it goes on the "Positive List". Who decides what’s on the list? The Minister and his advisors. How will they do this? The common practice test can only be applied if there exists accurate statistics of farm practices. This does not exist, so a major database exercise will be required. This database will need to be kept up to date, so farmers could find themselves filling in forms every year. Then there needs to be precise definitions of farm practices that take into account the variants of that practices. There will need to be some way of deciding when a variant is far enough removed from the original practice to be considered a new practice. There will need to be a cut off point that acts as the boundary beyond which everything is ‘common practice’. The levels of complexity grow exponentially when it is realized that the project must be measured against the others in the farmer’s industry or part of the industry and type of environment. Who decides what is a part of an industry and what isn’t? And type of environment – who decides what these are? The Minister and his advisers.

Once on the list your project is not guaranteed to stay there. Regular reviews of the ‘common practice’ situation will be conducted to decide who stays and who goes. Who decides who stays on the list? The Minister and his advisers. They won’t have time for much else.

For information about the Carbon Farming Conference & Expo and other Carbon Farming Week activities, click here.

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

Department reveals winners and losers lists under Senate questioning

If you want to take part in the Carbon Farming Initiative, you might be confused by two lists released on 25 May, 2011 by the Department of Climate Change and Energy Efficiency at the request of the Senate Committee inquiring into the CFI Legislation. There is a ‘positive list’ and a ‘negative list’ – the first is a menu of practices that might be deemed to be ‘additional’ and therefore acceptable to the Government, and the negative list might be deemed otherwise. Confusing because none of the practices listed have been given the OK to use a particular methodology. One – to do with burning savannahs – has a ‘meth’ up for public discussion. But does the list contain ‘sure things’ on the basis that they are not common practice? Time will tell - but this must be a clue. (Both lists appear below.)

What should the Government do?

As the Senate Committee reported: “To prevent progressive farmers from being penalised for practices they currently use to sequester carbon, the CFTA recommended farmers be eligible for credits for carbon they create in addition to a baseline, irrespective of the method(s) they use to do so.” (Michael Kiely, Chairman, CFTA, Proof Committee Hansard, 20 April 2011, p. 20.)

Illustrative example of Positive List of Additional practices

The types of activities which might be on the positive list include but are not limited to:

• establishment of a permanent environmental planting since 1 July 2007 (with a planted area greater than one hectare);

• establishment of trees for biomass energy;

• application of biochar to soil;

• capture and combustion of methane from legacy waste;

• early burning of savannahs to reduce the intensity and frequency of fires (burnt area greater than one square kilometre);

• culling feral camels;

• reducing enteric fermentation by livestock by:

• using tannins as a feed supplement for cattle;

• incorporating Eremophila in livestock feed (Eremophila is a genus of Australian native plants commonly known as "emu bush" or "poverty bush".);

• manipulating the gut flora in livestock; and

• selective breeding of livestock to reduce residual feed intake;

• capture and combustion of methane from manure;

• application of urea inhibitors to manure to reduce nitrification;

• application of nitrification inhibitors to fertiliser; and

• projects that have been assessed as additional under the Greenhouse Friendly program.

Illustrative example of Negative List of non-Additional practices

The types of activities which might be on the negative list include but are not limited to:

• Establishment of a forest - Interception of ground water as forests grow is likely to reduce water availability for other uses including environmental watering. The relevant jurisdiction does not have an accredited regime for meeting their National Water Initiative commitments to adequately manage water interception by plantations; and The proponent does not hold the appropriate high security water access entitlement to offset the plantations water use over the entire life of the plantation; and The project area is in a zone that receives more than 600mm annual rainfall, or more than 800mm if it also overlays a shallow saline groundwater table; and The total forested area for the project is greater than 2 ha; and The forest is not a permanent environmental planting.

• Establishment of a forest - Distortions to markets for agricultural land, resulting from the additive effects of up•front tax incentives and carbon revenue for commercial (harvest) plantings. Forest was established as a Managed Investment Scheme.

• Establishment of forest or non•forest vegetation. Land clearing to establish new carbon sink forests. Land was cleared of vegetation after 30 June 2008 or within three years of project commencement (whichever is more recent).

• Establishment of forest or non•forest vegetation. Draining swamps to establish new carbon sink plantings. A swamp was drained after 30 June 2008 or within three years of project commencement (whichever is more recent).

• Establishment of forest or non•forest vegetation. While weed species may sequester carbon, they create adverse environmental impacts on their local environment. Where species being established is a declared weed species in that jurisdiction.

• Cessation or avoidance of logging, clearing, clear•felling and selective harvest in monoculture plantations. Monoculture forests degrade over time as biomass moves to the debris pool and then decays. These forests can become a net source of emissions. Project involves foregone harvesting of a monoculture plantation forest.

• Cessation or avoidance of logging, including clearing, clear•felling and selective harvest in native forests. Landholders may seek to have covenants revoked in order to receive carbon credits. This would create risks for the environment. The area of land was under an in•perpetuity covenant prior to 24 March 2011, when the CFI legislation was introduced

• Any CFI activity - Governments may be pressured to repeal regulations to allow more activities to access CFI credits. This would create risks for the environment. Project was required by law prior to 24 March 2011, when the CFI legislation was introduced.

For information about the Carbon Farming Conference & Expo and other Carbon Farming Week activities, click here.

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

What Carbon Farmers Want

The Carbon Farming & Trading Association Wants the Government to:

• Take immediate action to agree a baseline methodology so farmers can start the process of sequestration without waiting 10 or 15 years for peer-reviewed science (at current rate of progress)

• Invoke UNFCCC Precautionary Principle: ‘Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing such measures.’

• Extend the precedent set by the DCCEE’s 5% “Risk of Reversal Buffer” to a statistically robust ‘Project Buffer Pool System’ that can replace peer-reviewed science as a means of managing uncertainty arising from measurement and permanence requirements of the Carbon Farming Initiative.

• Accept the ‘Project Buffer Pool System’ as meeting all technical requirements of Carbon Farming Initiative: A 1:1 buffer on a 15cm profile makes available for risk management the carbon stored in the corresponding 15cm unit plus that stored in the 15cm-30cm profiles of both units plus that stored in the 30cm-100cm profiles. A 75% buffer represents 95% confidence interval (certainty).

• Accept that Project Buffer Pool on 25 year contract enables system to meet Kyoto 75 year permanence requirement.

• Demand similar practical innovation from government agencies tasked with finding ways to make soil C sequestration work rather than reasons why it can’t work.

An enlightened soil scientist in Australia

Dr Rich Conant is enlightened. He questions the conventional view of soil carbon sequestration. For instance, the 100 year rule. He thinks it sucks.

His Comment on CFI Consultation Document: “Even a generous interpretation of the treatment of permanence in this document seems very likely to exclude all sequestration practices." Richard Conant is currently a Smart Futures Fellow at Queensland University of Technology in Brisbane Australia and an ecosystem ecologist at the Natural Resource Ecology Laboratory at Colorado State University. "The 100-yr time frame is long enough to create a system of multiplegeneration conservation easements. Unless the value of credits is high, the incentive to sign up seems likely to be small compared with the productive value of the land. Moreover, the 100-yr figure is still arbitrary and suggests that the issue of permanence has not been fully considered. The issue is that short-term storage of carbon in the biosphere is of little drawdown of atmospheric CO2. It seems to me that the goal of a sound biosequestration program is to maximize drawdown. In theory, this can be achieved with a series of short-term programs as well as it can be achieved with a long-term program. The most robust approach would be to recognize this limitation and address it directly rather than put off the day of reconciliation to future generations while minimizing drawdown in the near term.”

Wentworth Group pings CSIRO untruth: "there is no peer reviewed science"

The truth is out: There is no peer-reviewed data on the potential of Australian soils to sequester carbon. The CSIRO pretends that there is such data and makes statements of 'fact' such as this one: ‘current research would suggest the abatement likely to be achieved, in the short term at least, is likely to be modest.’ (Dr Brian Keating to the Senate Committee Inquiry into the CFI legislation) . But the House of Representatives Committee inquiring into the same legislation reports that "Mr Peter Cosier of the Wentworth Group of Concerned Scientists noted the importance of robust peer reviewed science, commenting on the lack of research that effectively determines the capacity of Australian soil to sequester carbon: ... there is no peer reviewed science of sufficient robustness to provide anybody with a reasonable estimate."

SOIL ECOLOGY, AGRICULTURE AND THE GREENHOUSE EFFECT: SHOWING HOW APPROPRIATE MANAGEMENT OF SOIL ORGANIC MATTER COULD HAVE BENEFITS FOR THE ATMOSPHERE

AUSTRALIAN JOURNAL OF SOIL AND WATER CONSERVATION, Vol. 6, No. 1, pp 27-30, Feb. 1993

SUMMARY

The soil ecosystem is comprised of abiotic and biotic fraction whose interaction determines soil stability. The biotic fraction of soil can be managed to provide greater stability and carbon sequestering potential, with significant benefits for the terrestrial environment and the atmosphere

The soil ecosystem has been described as a principal component of all agricultural ecosystems, the stability of which is essential to the development of sustainable agriculture (Senanayake 1990, 1991). The move to develop management strategies that achieve sustainable land use requires a good working knowledge of the ecosystem. Many functional components of the ecosystem have been researched in Australia (e.g. CSIRO, 1983), providing a good base for soil ecosystem management research.

SAVE OUR SOILS: CSIRO'S SOS PLEA - GREENHOUSE GASES CAN BE TRAPPED UNDER OUR FEET

Two of Australia's most pressing environmental problems - land degradation and the greenhouse effect - can be tackled at the same time, and Australia will be better off. That's according to Dr Roger Swift, Chief of the CSIRO's Division of Soils, who told a seminar in Adelaide today that the latest scientific research was showing clearly that reversing land degradation could soak up large amounts of the main greenhouse gas carbon dioxide - and help agriculture too.

"It's a terrific win-win opportunity for the environment," Dr Swift said. "Several new studies have found that land degradation and vegetation clearance are major sources of greenhouse gases in Australia - much larger than we previously thought.

"Carbon dioxide in the atmosphere is the main greenhouse gas. But the Earth's soils hold two or three times more carbon than our atmosphere, mostly in the form of decaying organic matter, or humus. When we over-exploit our soils, we mine that organic matter and the carbon escapes as carbon dioxide to the atmosphere.

"The good news is that the best way to improve soils is to add organic matter to them. By adding organic matter to degraded soil - and improving its structure and nutrition for future generations - we can also create a major sink for greenhouse gases. Remedying one problem will also help remedy the other."

Dr Swift said studies in the United States and Australia had found that as much as 50 per cent of the carbon which once existed in agricultural soils had been lost since the land had been turned over to farming.

Australian farm soils were much less fertile to begin with, he said, but until very recently scientists did not realise just how starved of carbon they were becoming. Because Australia had long been subject to regular bushfires, much of the land now used for farming contained a lot of small particles of charcoal.

Charcoal was made of carbon, but in soil it was largely inert, and was not available to growing plants. And there was so much old charcoal in Australian soil that it bumped up measurements of organic matter.

"If you discount the charcoal - some of which has been lying inert in the soil for decades, and perhaps centuries - then the true state of Australia's soils starts to look very much worse than we thought," Dr Swift said.

"In some of the farm soils we've measured, as much as half the carbon remaining is in the form of ancient charcoal.

"That is bad news, but it is also a great opportunity. If we improve our farming techniques so that we are restoring organic matter to the soil, not mining it out, we will be putting back some of the carbon which has escaped to the atmosphere."

Dr Swift said the worst-degraded lands in Australia tended to be those which were of marginal value for agriculture anyway; areas where the soil and climate made farming a risky business.

By progressively changing our use of such marginal land - allowing it to revegetate - and concentrating on improving soils in better areas, Australia could begin to reverse the loss of organic matter, and carbon, across a vast land area.

"The same road which leads to sustainable and prosperous farming also leads to helping alleviate the greenhouse effect," he said.

He said improved soil management could help stave off global warming, but it did not detract from the need to reduce greenhouse gas emissions. it was one more weapon to add to the anti-greenhouse armoury.

Dr Swift was giving a seminar titled "Soils and the Carbon Cycle" to a gathering of scientists from Adelaide's major soil research institutions at South Australia's Waite campus.

CSIRO MEDIA RELEASE 95/88

Embargoed until 12 noon on Thursday, September 7, 1995