Farmers fall into the Additionality Trap?

Farmers are in danger of forfeiting their right to earn carbon credits for on-farm activities if they move too soon. They can fall into the Additionality Trap if they get involved in on-farm trials before joining an approved offset program. And there aren't many methodologies approved. This is perplexing for those groups working to submit applications for funds under the Government's Action On The Ground because it leaves them in no-man's-land. The Carbon Farming & Trading Association has requested that the Departments involved - DAFF and DCCEE - provide farmers with a mechanism for avoiding this pitfall. Here are the details:

Farmers who take part in the Government’s $99 million Action On The Ground program could fall into the “Additionality Trap” and be excluded from the Carbon Farming Initiative’s Carbon Credits scheme. The program aims to “to assist landholders trial and demonstrate ways to reduce agricultural greenhouse gas emissions and/or increase carbon stored in soil.” But farmers who change their practices as part of these trials before they are registered in an offsets project with an approved methodology will almost inevitably make themselves ineligible to earn offsets that they can trade.
The CFI’s Additionality Standard disqualifies any activity that is already underway (‘business as usual’). For a project to deliver genuine carbon abatement, it must result in a reduction in atmospheric greenhouse gas that is additional to what would have occurred in the absence of the project. Currently there are only 4 methodologies approved: methane flaring from waste, savanna burning, piggery methane flaring, and native forest planting. The priorities for Action On The Ground are reduction of methane and nitrous oxide emissions and increased storage of soil carbon. Activities that would be eligible for funding under the program include most of the main Carbon Farming practices, which means that the “Additionality Trap” throws the net wide:
• animal management and feed strategies that can reduce methane emissions
• management strategies to reduce soil nitrous oxide emissions including the use of chemical inhibitors
• planting, rotation, cropping or grazing practices to either reduce agricultural greenhouse gas emissions from soil and/or increase carbon stored in soil
• on-farm management practices and abatement technologies to reduce agricultural greenhouse gas emissions from agricultural wastes
• other practices and abatement technologies that can be demonstrated on-farm to have the potential to reduce agricultural greenhouse gas emissions and/or increase carbon stored in soil.
DAFF lists a number of practices to be trialled for soil carbon that would be adopted to earn offsets: “Action on the Ground is seeking applications for on-farm projects to trial and demonstrate practices that can be used to increase and maintain the amount of carbon stored in soil. Such practices may include, but are not limited to, crop rotation strategies to reduce or eliminate fallow periods, addition of pasture phase to crop practices and/or cropping pastures, soil amendments, offsite additions to soil (such as claying, addition of organic materials etc), increasing pasture cover and/or inclusion of perennial species, conversion from cropping to perennial pasture and restoration of degraded farm land.”
The “Additionality Trap” also disqualifies farmers in areas where the offset practices had become ‘common practice’. (If more than 5% of farmers in a district or industry segment have adopted the practice, new adoptees are deemed to not be motivated by CFI considerations and any abatement arising would have happened anyway.) Local NRM bodies engaging farmers in certain districts in “soil carbon trials” not only endanger participating farmers, but all others in the district.

“Ignorance of the basic principles of carbon farming and trading is dangerous for farmers and their advisers. We estimate the losses by farmers as a result of these types of incidents could amount to significant dollars,” says Michael Kiely of the Carbon Farming & Trading Association. “These farmers must be informed, if only so they can manage the risk.”
It is to be wondered if the Government's CFI training course would include practical trading information of this type or whether it will be a "Government Information Campaign."
“This is not the first time there has been a collision between government programs due to misunderstanding the CFI. The confusion over carbon credits for Henbury Station is a classic example of silos colliding.”

Ruling sought

The Association is seeking a ruling from the DCCEE and DAFF on the following issues:
Will there be a suspension of the “Business As Usual” provision of the Additionality Standard for those farmers involved in the Action On The Ground program?
Will there be a suspension of the “Business As Usual” and “Common Practice” provisions of the Additionality Standard for those farmers involved in “Soil Carbon Trials” staged by CMAs and DPIs?
Will there be a mechanism provided for farmers who intend to earn offsets for activities for which there has yet to be a methodology approved to register their intention?