2. Gold plating the CFI

Problem: the DOIC has made it a prerequisite for inclusion on the Positive List and for a Methodology Determination that levels of abatement achievable by means of the nominated activity must be demonstrated. Ie., that the sequestration of sol carbon occurs. Why do we need duplication of proof? Why do we have to spend 3 years proving what we have to prove all over again in another 3 years? Practical solution: The practical solution is to move the “Point of Performance Proof” from the Laboratory to the Paddock where proof is measured in carbon sequestered. Securing peer-reviewed science for a new practice can take more than 3 years. There is no logical need for this requirement. All that is required to ensure that any offsets claimed are genuine is a scientifically-sound method of measuring Greenhouse Gases (emissions avoided or sequestered) so that a baseline can be determined and the volume of abatement can be totalled. The purpose of the Integrity Standards is to protect the buyer and support the value of ACCUs. But the demand for peer-reviewed science before the event is gold-plating the function when simple measurement before and after the abatement event is sufficient. This question affects 1. soil carbon practices, such as grazing management, 2. soil carbon practices such as applying compost or biochar. (See Appendix D)

APPENDIX D: Gold Plating the CFI

"Why should we have to prove that we can sequester carbon in trials before we go out and prove that we can sequester carbon in the field?" We put this question to the DOIC at the stakeholder meeting in Melbourne. A slide listed "insufficient evidence linking the activity to the abatement" as a common flaw of methodologies submitted to the DOIC. But we believe "providing proof before providing proof" is redundant. The Government could cut years of delay and hundreds of thousands of dollars out of the Methodology Development process by removing the prerequisite for Positive Listing that peer-reviewed data be submitted to prove that the activity is effective in providing abatement.  The answer we were given was that it is important for integrity of the abatement.

What is Integrity in the context of carbon trading? We have been told countless times that It is to make buyers of CFI ACCUs confident that they get what they pay for: real, genuine abatement.  The question is this: how much integrity is enough, how much science is necessary to satisfy the buyer, and is more better? If the science is needed to establish the amount of carbon sequestered, a sound measurement methodology is required. That should be sufficient to meet the needs of buyers. No buyer is in danger of being short-changed while the measurement methodology is sound. An activity that fails to perform in the field will generate no ACCUs for buyers to buy. "Learning by doing" is a principle endorsed by the IPCC. Growers who have confidence in their activity should be free to assume the risk of investing in implementing an activity. Demanding that they engage in expensive scientific trials that - in the case of soil carbon - must be conducted over 3 years, appears to be redundant. There are many growers who are highly skilled in techniques of sequestration, but who do not have peer-reviewed data.