What the Committee would like to hear from you
The Committee invites its stakeholders and interested members of the community to provide feedback on the proposed method.
You are encouraged to respond to the points outlined above as part of this process. If you submit your own document, we would like to hear from you on these points.
Should a moratorium on timber harvesting be considered a change in the baseline scenario?
In order for a carbon project to earn ACCUs, it must follow an approved method. All methods approved under legislation require project proponents to provide evidence that the greenhouse gas emissions abatement expected from carrying out project activities are additional (alongside other criteria), compared to a ‘business as usual’ (BAU) scenario in which the project does not go ahead. In other words, a project cannot earn ACCUs for continuing with BAU. Methods explain what evidence of additionality is required and how to present it.
The proposed INFM method involves the cessation of, or a substantial reduction in, timber harvesting on publicly owned native forest land. The proposed method allows a project proponent (i.e. a state government) to impose a temporary moratorium on timber harvesting while the feasibility of its ACCU project is assessed. According to the language in the proposed INFM method, such a moratorium would not affect the additionality of the project. That is, the proposed method treats the moratorium as a temporary state – necessary for the purpose of investigating the feasibility and implications of implementing a potential project – not as the new BAU scenario.
The BAU scenario may nevertheless involve future changes in conditions or practices that would deliver greenhouse gas emissions abatement. Any such abatement should be deducted from project-level abatement if it is expected in the normal course of events. The proposed INFM method deals with this by restricting the crediting period to 15 years and requiring revisions to the modified sustainable yield at years 5 and 10 and following major natural disturbances, which limits the impact of potential future changes in technology, markets and/or growing conditions.
The recent Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) reforms include sunsetting the exemption for Regional Forest Agreements (RFAs) and applying National Environmental Standards to RFAs.
Questions for consultation:
Should a moratorium on timber harvesting be considered a change in the BAU scenario?
If so, how should this be assessed when calculating the carbon abatement benefits of a new project?
Should there be a limit on the duration of a permissible moratorium and if so, how long should it be (i.e. how long before a ‘temporary’ cessation of harvesting becomes - by any reasonable assessment - BAU)?
To what extent are the method’s settings robust to the potential impacts of recent reforms to the EPBC Act?
Do you think the assumptions about leakage in the method are reasonable?
Leakage refers to any increase in emissions outside the project boundary which can be attributed, at least in part, to project activities.
Market linkages are one of the main drivers of leakage. For example, if a project involves reducing the output of a marketed product, customers who previously bought the product from the proponent may to switch to alternative suppliers. These other producers may in turn increase their output to meet the shift in demand, leading to increased emissions from their facilities.
Leakage is often beyond the direct control of a project proponent. Nevertheless, it is considered a consequence of the project and must be accounted for when estimating project abatement.
The proposed INFM method accounts for leakage in two ways:
Any measured increase in harvests (and associated emissions) within the same jurisdiction as the project is considered ‘direct’ leakage and is fully deducted from project abatement.
A standard 5 per cent deduction is applied to allow for potential ‘indirect’ leakage to forests outside the jurisdiction, and/or substitution effects (e.g. when consumers switch to non-wood products).
Questions for consultation:
Are the proposed leakage rules reasonable? Are there likely to be other drivers of increased timber harvests within the same jurisdiction as the project, beyond the activities of the project itself?
What experience or evidence is available to assess potential leakage from halting or reducing timber harvesting in native forests in Australia?
What would be the best way to account for leakage in the INFM method?
