CARBON FARMING INITIATIVE
Application to Vary a Methodology Determination
[Carbon Credits (Carbon Farming Initiative) (Reforestation and Afforestation—
1.1) Methodology Determination 2013]
[Carbon Conscious Ltd]
This form must be used when making an application to the Domestic Offsets
Integrity Committee under section 116 of the Carbon Credits (Carbon Farming
Initiative Act) 2011 for endorsement of a proposal for the variation of a
methodology determination.
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Disclaimer
The material in this document is made available for general information only and on the
understanding that the Commonwealth is not providing advice, nor indicating a commitment to a
preferred policy position. Before relying on any material contained in this document, entities should
familiarise themselves with the Carbon Farming Initiative (CFI) and obtain professional advice
suitable to their particular circumstances. While reasonable efforts have been made to ensure the
accuracy, correctness and reliability of the material contained in this document, the Commonwealth
does not accept responsibility for the accuracy or completeness of the contents or any inferences,
and expressly disclaims liability for any loss, however caused and whether due to negligence or
otherwise, arising directly or indirectly from the use of, inferences drawn, deductions made, or acts
done in reliance on, this document or the information contained in it, by any person.
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As a Commonwealth agency, the Department of Climate Change and Energy Efficiency is bound by
the Privacy Act 1988 (Cth). Any personal information that you submit as part of an application for
assessment of a draft methodology will be collected and securely stored by the Department. Any
personal information collected about you will only be used in relation to your application. Your
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the future.
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Department of Climate Change and Energy Efficiency
GPO Box 854
Canberra ACT 2601
Phone: + 61 2 6159 7000
Website: www.climatechange.gov.au
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Any entity that submits an application for endorsement of an application for variation of a
methodology determination as part of the CFI warrants that they own or have a licence to use all of
the relevant intellectual property rights in the application submitted.
Copyright in this document vests in [applicant to insert the appropriate name].
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All material in this publication is licensed under a Creative Commons Attribution 3.0 Australia
Licence.
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Table of contents
Instructions for applicants ...................................................................................................................... 4
Section 1: Methodology Determination Title and Applicant Details ...................................................... 6
Section 2: Expert consultation ................................................................................................................ 6
Section 3: Revised methodology determination glossary ...................................................................... 7
Section 4: Justification for variation ....................................................................................................... 7
Section 5: Explanation for variation ........................................................................................................ 9
Section 6: References............................................................................................................................ 32
Section 7: Appendices ........................................................................................................................... 32
Section 8: Disclosure ............................................................................................................................. 33
Section 9: Declaration ........................................................................................................................... 33
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Instructions for applicants
This template must be used to make an application for endorsement of a proposal to vary a
methodology determination under section 116 of the Carbon Credits (Carbon Farming Initiative) Act
2011 (the Act). Applicants should complete this form in accordance with Section 3.5 of the
Guidelines for Submitting Methodologies.
This form contains sections for applicants to provide:
1)
details of the relevant methodology determination;
2)
a general statement, including supporting evidence, outlining why the specified
methodology determination should be varied;
3)
supporting evidence to enable the Domestic Offsets Integrity Committee (DOIC) to assess
whether the varied determination would comply with the offsets integrity standards
prescribed in section 133 of the Act, and the requirements of the Carbon Credits (Carbon
Farming Initiative) Regulations 2011 (the Regulations);
4)
a copy of the methodology determination with the proposed variations clearly marked;
and
5)
justification, including supporting evidence, as to why each proposed variation should be
made.
If the application for variation is endorsed by the DOIC and subsequently approved by the Minister,
it will be made into a revised methodology determination and registered on the Federal Register of
Legislative Instruments.
As the methodology determination is a legislative instrument, instructions must be clear, detailed
and complete and all technical terms must be defined. Care must be taken to ensure the instructions
are written so that there is little or no room for them to be misinterpreted.
All proposed revisions must be set out in the table at Section 5 and accompanied by an explanation
as to why the revision should be made, as well as supporting evidence to justify all assumptions,
assertions and estimations.
The inclusion of diagrams, graphics and flow charts is recommended to assist in the understanding of
descriptions or statements.
If an applicant wants any information to be exempt from public disclosure, the information must be
clearly marked ‘CONFIDENTIAL’. An explanation of why this information should not be published
during the public comment period must be provided in Section 8 of this form. Where the DOIC
requires more information from an applicant on why the information should not be published, it
may seek additional information from the applicant.
A glossary of terms specific to the proposal for a revised methodology determination must be
provided in this form. The definitions of terms in the methodology glossary must be consistent with
definitions in the Act.
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Applications for variation of a methodology determination must be made to:
By post:
DOIC Secretariat
Department of Climate Change and Energy Efficiency
GPO Box 854
CANBERRA ACT 2601
Or
By email to:
DOIC@climatechange.gov.au
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Section 1: Methodology Determination Title and Applicant Details
Methodology determination title and applicant details
Title of the
Carbon Credits (Carbon Farming Initiative) (Reforestation and Afforestation—
methodology
1.1) Methodology Determination 2013
determination that
is the subject of the
application:
Specified date on
which the
methodology
determination was
made:
27 May 2013
Name of applicant:
Anthony Fitzgerald
Company:
Carbon Conscious Ltd
Position:
Commercial Manager
Telephone:
0400007749
Email:
afitzgerald@carbonconscious.com.au
Address:
26 Railway Rd Subiaco WA 6008
Postal address (if
different to above):
PO Box 1338, Subiaco, WA 6904
Section 2: Expert consultation
Please provide the names and organisations of technical experts you have consulted in the
development of this application. You must have permission from the expert individual or
organisation to include their names prior to submitting this template.
Name
Organisation
Does this expert endorse all or a
part of the application for
variation? (refer to relevant
section if applicable)
Dan Huxtable
Equinox Environmental
All
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Section 3: Revised methodology determination glossary
Provide an alphabetical glossary of terms that are specific to the application for variation of a
methodology determination. Note that many terms are already defined in the Act, the Regulations
and the Guidelines. Please refer to these documents before defining a new term.
Please add more rows if required.
Term
Meaning of term
Section 4: Justification for variation
General statement of justification
Outline the reasons why the methodology determination specified in Section 1 should be varied.
All proposed variations will maintain the integrity of project CO2e measurement and accounting
while significantly reducing measurement costs. And,
Variation 1
The variation will allow an alternative that in some circumstances would result in reduced field
measurement costs due to economies of scale.
Variation 2
The variation would improve cost effectiveness by reducing the frequency at which allometric
equations would need to be up-dated.
Variation 3
The variation will put beyond doubt that stratum specific and regional allometric functions and
allometric domains can be expanded during PSPAs as well as full inventories. It will also clarify that;
appropriate trees to be selected for total destruction and addition to the function data, are trees to
the upside of the previous upper limit of the allometric domain
Variation 4
The variation will correct an anomaly and result in large scale projects being treated in the same
manner as small scale projects.
Variation 5 and Variation 6
The variation could result in a more conservative post growth disturbance / emission event ACCU
calculation a but the cost savings will in most cases out way the loss of claimed ACCUs.
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Please provide additional information to support the statements above. Include supporting evidence
and justifications for any assumptions or estimations relied upon.
Variation 1 – Initial Stratification Requirements:
The current methodology prescribes that a stratum MUST only include an area where the initial
planting occurred in a planting window of 180 days. This prevents amalgamation of multiyear
plantings into a single stratum and can prevent an amalgamation that would deliver economies of
scale.
It is proposed to provide a Stratum definition that allows the option of including or not including a
180 planting window as a defining term of stratum. That is if a proponent chooses to a stratum can
be defined to include a 180 day planting window or the proponent can choose a stratum definition
that does not include the 180 day window.
The variation will incorporate into this methodology a feature from Methodology Determination
2013 and Carbon Credits (Carbon Farming Initiative) (Reforestation and Afforestation—1.2)
Methodology Determination 2013.
An example of missed opportunity for economies of scale can be demonstrated by two full
inventories of E.Kochii plantations Carbon Conscious Ltd conducted in 2013. The stratum were
homogonous by way of species and region but were stratified as 2009E.Kochii and 2010E.Kochii
under the 180 day window definition. When the full inventories datum were combined for an ex
post analysis, it was demonstrated that:
1. Instead of the 425 non destructive plots and 60 destructive trees required for the separated
stratum, a survey of the area amalgamated would have required 225 non destructive plots
and 45 destructive trees to arrive at calculated CO2e within the required PLE of 90:10%.
2. Field work costs would have been reduced from $120,000 to $70,000.
Using the knowledge gained in 2013 it has been demonstrated at desk top level that in stratum yet
to be measured, forests planted in 2009,2010,2011 could be amalgamated into a 750ha stratum.
The amalgamation is forecast to reduce field work costs from $197,000 to $89,000.
See attached Equinox Environmental paper ‘Ex Post Analysis of 2013 CFI Inventory’
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Variation 2 – Allometric Domains
It is proposed to change the treatment of trees that have predictive variables greater than the
allometric range.
Currently the Methodology prescribes that when establishing an allometric function trees that have
the lowest value and highest value predictive characteristic must be included in the sample that is
destructively sampled. This lowest and highest value becomes the ‘allometric range’ for which the
function is valid. It also prescribes that when trees outside the ‘allometric range’ are encountered
they must be recorded as present and then attributed a zero biomass.
It is proposed that rather than being allocated a zero biomass, these larger trees are allocated a
biomass equivalent to trees at the high end of the allometric range. For example, if the allometric
range is a stem diameter of 1-15cm, and a tree has a stem of 17cm, then the tree can be included in
the results of the biomass survey as though it has a stem of 15cm.
It is recognised that the existing treatment of trees under the minimum value serves a best practice
and conservative approach. Given that relationship between predictive measures and biomass are
not linear with an R2 of 1 it is also accepted that for the sake of being conservative that absolute
predictions of the actual biomass of a tree with characteristics above the allometric range are not
made. However, it seems unnecessarily conservative to assume that a tree that has grown to have a
predictive characteristic above the range will have zero biomass or a biomass lower that a tree at the
top end of the allometric range.
It is proposed that in the case of trees with a predictive measure greater than the highest measure in
the allometric range that ‘the tree characteristic should be recorded and the tree should be
allocated the biomass equivalent of the largest tree in the allometric range’.
The variation will still result in a conservative calculation of biomass (and subsequently CO2e),
passes a law-of-biology reasonableness test, and allows proponents to take a commercial decision to
trade a more conservative calculation (than would have been made if the allometric domain had
been extended) for the cost of extending the allometric range.
See attached Equinox Environmental paper ‘Ex Post Analysis of 2013 CFI Inventory’
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Variation 3 – Updating Regional Allometric Equations
The proposed change is to clarify that an allometric function and allometric domain for a stratum
specific or regional allometric function MAY be expanded while conducting a permanent sample plot
assessment (PSPA) and to define the data set from which additional biomass trees will be selected.
Stratum specific allometric functions will be established during the first full inventory of a stratum.
Subsequently the function may be converted to a regional allometric function. The data set used to
create the original allometric will include trees with the greatest predictive value at that time. It
follows that when a proponent subsequently executed a PSPA that some trees will have grown and
their predictive measurement will be above (outside) the allometric range.
When a Full Inventory of PSPA is conducted and trees are found to have measurements outside the
allometric domain the allometric function cannot be applied to that tree. The proponent has the
choice of recording the tree as present and then attributed a zero biomass or updating the
allometric function and domain.
The Methodology describes the steps necessary to update allometric functions and domains but the
wording is conflicting and it seems likely that an overuse of reference to previous sections rather
than the description of required action have led to the original intent being lost. At 5.32(1)(b) the
Methodology states the up-dating stratum specific functions technique as described relates to the
update being completed as part of a Full Inventory. At 5.33 (7)(b) reference is made to converting
PSPs into Biomass Sample Plots for the purpose of selecting trees for destructive sampling thereby
prescribing that an allometric function and domain could be updated during a PSPA. And at 5.32(4)
when referring to the way the minimum 10 biomass sample trees will be selected section 5.31 (4)
describes that the smallest as well as largest tree from a data set must be selected.
Given that the use of PSPAs are intended and that by the time a PSPA is conducted some trees will
be above the allometric region limits, it follows that (while it may have been lost in drafting) the
Methodology should allow allometric functions and domains to be updated during PSPAs as well as
subsequent Full Inventories. It also follows that the trees of interest in updating the allometric would
be trees with a characteristic range not previously in the range and that they will be trees above the
previous range.
Despite what seems the intent, the wording is unclear and leads to double loop conclusions. For
example CCF asked the Clean Energy Regulator for its interpretation as to whether allometric
equations and ranges can be updated during a PSPA. The CER agreed that they can be conducted
during a PSPS but also concluded that the biomass sample trees could not come from the PSPs on
the grounds that nothing can be done on a PSP that is not being done to the whole stratum (email
exchange attached). CCF proposes that if a tree in a PSP becomes a biomass sample tree and is
therefore not there to be measured in future PSPAs that any error will be to the conservative side.
For example, removing the 10 largest trees from a full inventory that measured 8,641 trees in 2013
would have resulted in a reduction on 0.21% of calculated biomass or 36 ACCUs, and in another
stratum where 3032 trees were measured the affect of not including the largest ten would have
been a reduction of 0.41% in biomass or 24 ACCUs.
An example of the processes of establishing stratum specific and regional allometric functions and
domains is contained in the allometric report submitted by Carbon Conscious Ltd (CCF) with an
offsets report in 2013 (appended). Having developed the functions and allometric range CCF is in a
position to apply the function during PSPAs on stratum in the region provided that the measured
trees are within the allometric domain of: species being E.Kochii, the trees are live standing, the tree
size range is 0.27 – 21.0 dry kg of whole tree biomass, the number of stems is 1-10, and the
equivalent stem diameter is 1.7-9.7cm.
With a circa $70,000 spread in field work costs between a PSPA and full inventory one of the
significant elements of the Methodology is the ability to conduct PSPAs in the intermittent years
between full inventories at 5 year intervals. The inconvenient truth for CCF (or any proponent) is
that with each passing year of executing PSPAs more and more trees will be above the allometric
10
range. It follows that a proponent must therefore not apply the function to trees with measurement
above the upper limit or update the allometric function and domain to include trees of the size not
previously included.
In years when a proponent had just completed the non destructive measurements of trees in PSPs
with the intention of using a PSPA to support an offset report the most cost effective way to expand
the allometric function and domain would be to rank the measured trees, select no less than 10,
have them destructively sampled, add the data to the original data, refit the function, and redefine
the allometric domain.
Currently the prescribed selection of additional biomass sample trees is to: rank all trees from
smallest to largest, divide into 5 size categories, select the smallest and largest, and pseudorandomly select the remainder so each category is appropriately represented. Based on the trees
measured in the 2013 CCF allometric report (attached), if this was applied the result would be that 8
of the selected trees would be of a size already within the allometric domain with only 2 delivering
additional knowledge.
With the purpose being to expand the allometric function and extend the domain, the appropriate
ranking of trees and selection of a minimum 10 for destructive sampling is therefore marginally
different to that used when the original allometric definitions were established. Trees measured in
the PSPA or full inventory that have a predictive measure within the existing domain would be
excluded, and those above the existing domain would be recorded in a sub-set. The trees in the subset would be ranked from smallest to largest and divided into 5 size categories. Of the ranked and
divided sub-set data: the smallest and largest would be selected with the remainder pseudo-random
selected resulting in data from a minimum 10 trees outside the previously established and tested
domain. The selected trees would then be destructively sampled and the data added to the previous
allometric function data set – function expanded and new allometric domain defined.
See Equinox Allometric Report 2013 Offset Report CCF CFI Project
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Variation 4:
The methodology prescribes action if a growth disturbance affects the lesser area of 10ha or 5% of a
project area(s). An event that triggers the threshold will require expensive action (for example if the
event was a fire the methodology prescribes that within 6 months a full inventory be conducted of
both the affected area and non affected area. While a lesser of 10ha or 5% area event may be
significant in terms of a small stratum (less than 200ha), a 10ha event is not significant in terms of
the loss of captured CO2e on larger scale project areas.
It is proposed that the area defined as the action threshold relating to a growth disturbance or
significant emission be redefined so that the same proportion (5% of the area) of a project is the
threshold no matter the scale of the project.
The following examples where in 2014 sequestered CO2e is assumed 13mt/ha and in 2016 28mt/ha
demonstrate of various the inconsistency in treatment of large scale projects (box 1 and 2).
By using a ‘lesser than 10ha or 5% of area’ threshold once a project is over 200ha the threshold
becomes 10ha. In the examples Project 1 is 200ha and if in 2014 or 2016 10ha were affected and all
previously sequestered CO2e lost, the loss represents only 50% of the statistical variation (10%PLE)
and 5% of the absolute total.
The inconvenient truth is that given the administrative costs of the CFI projects of 200ha will not be
a reality so the impacts of the threshold on larger areas need consideration.
As project area increases the proportionate impact falls to such a level that the impact of a 10ha
event is not material. Losing 10ha from the:

2,000ha project means the loss would be 0.5% of the area and therefore represent 0.5% of
ACCUs and the loss represents 5% of the allowable PLE.

6,000ha project means the loss would be 0.2% of the area and therefore represent 0.2% of
ACCUs and the loss represents 2% of the allowable PLE.
As such the existing hurdle definition is disproportionately skewed against large scale stratum. If
the trigger threshold was redefined to be ‘an area of 5% or more of a project area(s) then while the
absolute ACCU loss increases as project size increases the loss in terms of a percentage of allowable
PLE remains constant at 50% (far right section of boxes 1 and 2).
Box 1: Calculation Affect Loss of 10ha or 50ha or 5%ha in 2014
Area
ACCUs
10%
10ha as ACCUs Loss as
Stratum
ha
2014
PLE
% Area Loss 10ha % PLE
Project 1
200
2,600
260
5.0%
130
50%
Project 2
500
6,500
650
2.0%
130
20%
Project 3 1,000
13,000
1,300
1.0%
130
10%
Project 4 2,000
26,000
2,600
0.5%
130
5%
Project 5 6,000
78,000
7,800
0.2%
130
2%
Project 6 8,000
104,000
10,400
0.1%
130
1%
Box 2: Calculation Affect Loss of 10ha or 50ha or 5%ha in 2016
Area
ACCUs
10%
10ha as ACCUs Loss as
Stratum
ha
2016
PLE
% Area Loss 10ha % PLE
Project 1
200
5,600
560
5.0%
280
50%
Project 2
500
14,000
1,400
2.0%
280
20%
Project 3 1,000
28,000
2,800
1.0%
280
10%
Project 4 2,000
56,000
5,600
0.5%
280
5%
Project 5 6,000
168,000
16,800
0.2%
280
2%
Project 6 8,000
224,000
22,400
0.1%
280
1%
50ha as ACCUs Loss as
% Area Loss 50ha % PLE
10%
5%
3%
1%
1%
650
650
650
650
650
100%
50%
25%
8%
6%
50ha as ACCUs Loss as
% Area Loss 50ha % PLE
10%
5%
3%
1%
1%
1,400
1,400
1,400
1,400
1,400
100%
50%
25%
8%
6%
5%
as ha
10
25
50
100
300
400
ACCUs
Loss 5%ha
130
325
650
1,300
3,900
5,200
Loss as
% PLE
50%
50%
50%
50%
50%
50%
5%
as ha
10
25
50
100
300
400
ACCUs
Loss 5%ha
280
700
1,400
2,800
8,400
11,200
Loss as
% PLE
50%
50%
50%
50%
50%
50%
See also CCF Managing CO2e Reversal Events
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Variation 5:
Note*: If variation 4 is executed, the threshold of 10ha referred to in this proposed variation will be
replaced by 5% of the area(s).
Currently the methodology prescribes action that MUST be taken in the event of a Growth
Disturbance Event that is a fire affecting more than 10ha, including:
1) The fire-affected and non-affected parts of the stratum must be mapped and 2 new stratums
defined.
2) A full inventory must be conducted on both the fire-affected and non-affected within 12
months.
3) In the case of the fire-affected stratum
a. an estimate of the fire emissions from any fire affected stratum, and the standard error
associated with this estimate, must be calculated in accordance with Equations 26a to 27d;
and
b. for the purposes of calculating carbon stock changes and standard error for carbon stock
change in accordance with Equations 3a and 3c, the carbon stocks and the standard error for
initial carbon stocks must be assumed to be zero for the fire affected stratum.
The issues with the current tightly defined action are that it ignores the reality that:
1. In the majority of cases the most economically rational treatment of the affected area would
be to assume zero sequestered CO2e on the affected area for at least some years after the
event (cost of measuring the residual greater than value of residual) until the stand recovers.
2. It would be possible and more efficient to calculate the ACCUs on the unaffected area by
conducting a permanent sample plot assessment (PSPA) as opposed full inventory.
The proposed variation retains the option of the current approach and introduces the option of
taking an approach that is more conservative and will arrive at a post event position where less
ACCUs are claimed. Having the alternatives would allow a proponent to assess whether the marginal
extra cost of a full inventory against a PSPA (in order of $50-80,000) will be met by adopting the
current approach and calculating maximum ACCUs, or whether (as will most often be the case) that
the more conservative approach of less ACCUs but lower costs will maximise economic outcome.
13
Variation 5 (continued):
It is proposed that when a project area(s) is affected by a growth disturbance or significant emission
event, when that event was a fire, and the event affects an area greater than 10ha* but not the
entire project area(s) that a proponent MAY adopt the existing practices or May adopt the following
actions:
1. The fire-affected area will be mapped and a new ‘fire-affected’ stratum will be created.
2. Until the next full inventory the area of the non-affected stratum will be calculated as the
pre-event area less that area mapped into the fire-affected stratum.
3. A PSPA must be conducted on the non-affected stratum within 12 months thereby
identifying the total carbon stocks on the non-affected area.
4. The total carbon stock on the fire-affected stratum at the time of the event will be
calculated by dividing the total carbon stock at the last pre-event offset report and
multiplying by the area of the fire-affected stratum and dividing by the area of the pre-event
stratum.
5. The results from point 4 can be used in equations 26a-27d to calculate the CO2e emitted.1
6. The carbon stock on the fire-affected area will be assumed to be zero.
7. When the offsets report based and claim for ACCUs based on the PSPA of the non affected
area(s) are submitted the claim for ACCUs for the Project will be calculated as A = B – C – D
where:
A is the number of ACCUs being claimed, B is the cumulative CO2e on the non affected
stratum as calculated in the PSPA, C is the cumulative CO2e (ACCUs) claimed previously, D is
the amount of CO2e calculated as emitted a result of the fire event.
8. The next full inventory on the non-affected stratum MUST be conducted not later than 5
years post the full inventory conducted before the event and MAY be conducted earlier.
9. In years subsequent to the event the CO2e stocks of the fire-affected stratum MUST be
deemed to be zero until such time as:
a. A full inventory is conducted on the fire-affected stratum, or
b. The fire-affected area is reincorporated back into the non-affected area and a full
inventory is conducted on the re-amalgamated stratum.
A case study of the cost/benefits of the proposed variation is appended “CCF-Case Study of
Proposed Variation 5 and 6”
1
Effectively until the next Full Inventory on the affected area MPC stratum ,j,Ri in Equation 26a will be zero.
14
Variation 6
This proposed variation is similar to variation 5 the difference being that it would apply to growth
disturbances that are not fire events. Effectively the only difference in the proposal will be that there
will not be a need to calculate emissions from a fire.
Note*: If variation 4 is executed, the threshold of 10ha referred to in this proposed variation will be
replaced by 5% of the area(s).
Currently the methodology prescribes action that MUST be taken in the event of a Growth
Disturbance Event (with the event being other than a fire) affecting more than 10ha, including:
1. The affected and non-affected parts of the stratum must be mapped and 2 new stratums
defined.
2. For the purposes of calculating carbon stock changes and standard error for carbon stock change
in accordance with Equations 3a and 3c, the carbon stocks and the standard error for initial
carbon stocks must be assumed to be zero for the affected stratum.
The Methodology is silent on the timing of the full inventories but given the section on the
treatment of disturbances that are fire it seems implied that as in the case of a fire event it would be
within 12 months.
The issues with the current tightly defined action are that it ignores the reality that:
1. In the majority of cases the most economically rational treatment of the affected area would be
to assume zero sequestered CO2e on the affected area for at least some years after the event
(the cost of measuring the affected area greater than value on affected area) until the stand
recovers.
2. It would be possible and more efficient to calculate the ACCUs on the unaffected area by
conducting a permanent sample plot assessment (PSPA) as opposed full inventory.
The proposed variation retains the option of the current approach and introduces the option of
taking an approach that is more conservative and will arrive at a post event position where less
ACCUs are claimed. Having the alternatives would allow a proponent to assess whether the marginal
extra cost of a full inventory against a PSPA (in order of $50-80,000) will be met by adopting the
current approach and calculating maximum ACCUs, or whether (as will most often be the case) that
the more conservative approach of less ACCUs but lower costs will maximise economic outcome.
15
Variation 6 continued
It is proposed that when a project area(s) is affected by a growth disturbance when that event was
not a fire, and the event affects an area greater than 10ha* but not the entire project area(s) that a
proponent MAY adopt the existing practices or May adopt the following actions:
1. The affected area will be mapped and a new ‘affected’ stratum will be created.
2. Until the next full inventory the area of the non-affected stratum will be calculated as the preevent area less that area mapped into the affected stratum.
3. A PSPA must be conducted on the non-affected stratum within 12 months thereby identifying
the total carbon stocks on the non-affected area.
4. The total carbon stock on the affected stratum at the time of the event will be calculated by
dividing the total carbon stock at the last pre-event offset report and multiplying by the area of
the affected stratum and dividing by the area of the pre-event stratum.
5. The carbon stock on the affected area will be assumed to be zero.
6. When the offsets report based and claim for ACCUs based on the PSPA of the non affected
area(s) are submitted the claim for ACCUs for the Project will be calculated as A = B – C where:
A is the number of ACCUs being claimed, B is the cumulative CO2e on the non affected
stratum as calculated in the PSPA, C is the cumulative CO2e (ACCUs) claimed previously.
7. The next full inventory on the non-affected stratum MUST be conducted not later than 5 years
post the full inventory conducted before the event and MAY be conducted earlier.
8. In years subsequent to the event the CO2e stocks of the affected stratum MUST be deemed to
be zero until such time as:
a. A full inventory is conducted on the affected stratum, or
b. The affected area is reincorporated back into the non-affected area and a full
inventory is conducted on the re-amalgamated stratum.
The case studies supporting variation 5 are relevant to this variation.
16
Section 5: Explanation for variation
Please list each section, subsection and paragraph of the methodology determination that you propose to vary and each proposed variation. You must
provide an explanation as to why each proposed variation should be made. Please add more rows if required.
Section
Subsection/
Paragraph
Proposed variation
Part 3
3.2
VARIATION 1
Explanation
Since submitting and
operating under V1.1
REPLACE THE SECTION AS WORDED:
Carbon Conscious has
3.2 Requirements for a stratum
observed: that it is not
(1) A stratum is made up of:
uncommon for the
(a) an extant project forest area; and
variance within a stratum
(b) the area of land that lies within the crown radius of the extant project forest area defined by a single year is
specified in (a).
as great as the variance
(2) The extant project forest area of a stratum must have been planted with one or more would be if stratum with
species of project trees within the planting window.
other common
Note Project proponents may further define strata based on any of the following:
characteristics but
–
the planting window
different planting years
–
observed or measured growth trends;
were combined so that
–
growing regions;
–
climatic conditions;
planting year was not
–
soil types;
considered in
–
disturbance history;
stratification. The
–
land management units;
amendment would not
–
management regime; or
–
any other characteristics that may be likely to influence project tree growth.
reduce the validity of
inventory measurement
conducted (statistical
tests will ensure enough
plots are measured) but
the amendment will
make a material
difference to the cost of
inventory measurement.
17
WITH THE WORDS FROM V1.2 AS FOLLOWS
3.2
Minimum requirement for a stratum
A stratum must have been planted with one or more species of project trees.
Note Project proponents may also define a stratum based on any of the following:
– project tree age with trees being planted within the planting window;
– tree species;
– observed or measured growth trends;
– growing regions;
– climatic conditions;
– soil types;
– disturbance history;
– land management units;
– management regime; or
– any other characteristics that may be likely to influence project tree growth.
Further, the
methodologies Carbon
Credits (Carbon Farming
Initiative) (Reforestation
and Afforestation—1.1)
Methodology
Determination 2013 and
Carbon Credits (Carbon
Farming Initiative)
(Reforestation and
Afforestation—1.2)
Methodology
Determination 2013 are
not materially different.
The requested variation
is copied from
determination: Carbon
Credits (Carbon Farming
Initiative) (Reforestation
and Afforestation—1.2)
Methodology
Determination 2013.
18
Part 6
6.12
REPLACE THE SECTION AS WORDED:
Again the words from
Carbon Credits (Carbon
Farming Initiative)
Subdivision 6.2.3
Calculating initial carbon stocks for a stratum
(Reforestation and
Afforestation—1.1)
6.12
Calculating initial carbon stocks for a stratum
Methodology
(1) For a stratum that is composed of project trees planted on or after the declaration Determination 2013.
date:
Are replaced with those
(a) the initial carbon stocks for the stratum (ICStratum,j) is zero; and
from
(b) the standard error for the initial carbon stocks for the stratum (SEICStratum,j) is Carbon Credits (Carbon
zero.
Farming Initiative)
(2) For a newly created stratum that is entirely composed of project trees planted (Reforestation and
before the declaration date and previously referenced in an offsets report under an Afforestation—1.2)
alternative stratum identifier:
Methodology
(a) the initial carbon stocks for the newly created stratum (ICStratum,j) is zero; and Determination 2013.
(b) the standard error for the initial carbon stocks for the newly created In this instance the key
change is a replacement
stratum (SEICStratum,j) is zero.
of the planting FINISH
(3) For a stratum that is partially composed of project trees planted before the
date with planting START
declaration date and that have been referenced in an offsets report, the calculation
date when calculating the
of the initial carbon stocks for the stratum must:
initial stocks in stratum
(a) be carried out in accordance with Equation 4a; and
where planting
commences before the
(b) incorporate a standard error calculation in accordance with Equation 4b.
Declaration date. The
(4) For a stratum that is entirely composed of project trees planted before the
effect of the change is to
declaration date that have not previously been referenced in an offsets report, the
make the amended
calculation of the initial carbon stocks for the stratum must:
calculation more
(a) be carried out in accordance with Equation 4a; and
conservative in that a
lesser amount of CO2e
(b) incorporate a standard error calculation in accordance with Equation 4b.
will be calculated,
however proponents will
be in a better financial
19
𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗
𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
=
× 𝑌𝐶𝐹𝐼,𝑗
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
Equation 4a
where:
𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
initial carbon stocks for the 𝑗th stratum, in tonnes of CO2-e (t CO2-e).
𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
closing carbon stocks for the 𝑗th stratum for reporting period 𝑅𝑖 in
tonnes of CO2-e (t CO2-e), calculated in accordance with Equation 5a.
𝑅𝑖 =
first reporting period for the 𝑗th stratum, as a calendar date.
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
age of project trees in the 𝑗th stratum for reporting period 𝑅𝑖,
calculated as the difference in absolute years between the planting
finish date and the date for reporting period 𝑅𝑖.
𝑌𝐶𝐹𝐼,𝑗 =
difference in absolute years between the planting finish date for the
𝑗th stratum and the declaration date.
𝑆𝐸𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
𝑆𝐸𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
× 𝑌𝐶𝐹𝐼,𝑗
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
position due to the cost
savings that will result
from the economies of
scale by combining
stratum across planting
years.
Equation 4b
where:
𝑆𝐸𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
standard error for initial carbon stocks for the 𝑗th stratum, in
tonnes of CO2-e (t CO2-e).
𝑆𝐸𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
standard error for closing carbon stocks for the 𝑗th stratum for
reporting period 𝑅𝑖 in tonnes of CO2-e (t CO2-e), calculated in
accordance with Equations 5b and 6b.
𝑅𝑖 =
first reporting period for the 𝑗th stratum, as a calendar date.
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
age of project trees in the 𝑗th stratum at the end of reporting
period 𝑅𝑖, calculated as the difference in absolute years between
20
the planting finish date and the date at the end of reporting period
𝑅𝑖.
difference in absolute years between the planting finish date for
the 𝑗th stratum and the declaration date.
𝑌𝐶𝐹𝐼,𝑗 =
WITH THE WORDS AS FOLLOWS
Subdivision 6.2.3
6.12
Calculating initial carbon stocks for a stratum will differ according to
whether or not the stratum definition included a planting window.
Calculating initial carbon stocks for a stratum when planting window IS included in
the stratum definition.
(1) For a stratum that is composed of project trees planted on or after the declaration
date:
(a) the initial carbon stocks for the stratum (ICStratum,j) is zero; and
(b) the standard error for the initial carbon stocks for the stratum (SEICStratum,j) is
zero.
(2) For a newly created stratum that is entirely composed of project trees planted
before the declaration date and previously referenced in an offsets report under an
alternative stratum identifier:
(a) the initial carbon stocks for the newly created stratum (ICStratum,j) is zero; and
(b) the standard error for the initial carbon stocks for the newly created
stratum (SEICStratum,j) is zero.
(3) For a stratum that is partially composed of project trees planted before the
declaration date and that have been referenced in an offsets report, the calculation
of the initial carbon stocks for the stratum must:
(a) be carried out in accordance with Equation 4a; and
(b) incorporate a standard error calculation in accordance with Equation 4b.
(4) For a stratum that is entirely composed of project trees planted before the
21
declaration date that have not previously been referenced in an offsets report, the
calculation of the initial carbon stocks for the stratum must:
(a) be carried out in accordance with Equation 4a; and
(b) incorporate a standard error calculation in accordance with Equation 4b.
𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
× 𝑌𝐶𝐹𝐼,𝑗
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
Equation 4a
where:
𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
initial carbon stocks for the 𝑗th stratum, in tonnes of CO2-e (t CO2-e).
𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
closing carbon stocks for the 𝑗th stratum for reporting period 𝑅𝑖 in
tonnes of CO2-e (t CO2-e), calculated in accordance with Equation 5a.
𝑅𝑖 =
first reporting period for the 𝑗th stratum, as a calendar date.
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
age of project trees in the 𝑗th stratum for reporting period 𝑅𝑖,
calculated as the difference in absolute years between the planting
finish date and the date for reporting period 𝑅𝑖.
𝑌𝐶𝐹𝐼,𝑗 =
difference in absolute years between the planting finish date for the
𝑗th stratum and the declaration date.
𝑆𝐸𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
𝑆𝐸𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
× 𝑌𝐶𝐹𝐼,𝑗
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
Equation 4b
where:
𝑆𝐸𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
standard error for initial carbon stocks for the 𝑗th stratum, in
tonnes of CO2-e (t CO2-e).
𝑆𝐸𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
standard error for closing carbon stocks for the 𝑗th stratum for
22
reporting period 𝑅𝑖 in tonnes of CO2-e (t CO2-e), calculated in
accordance with Equations 5b and 6b.
𝑅𝑖 =
first reporting period for the 𝑗th stratum, as a calendar date.
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
age of project trees in the 𝑗th stratum at the end of reporting
period 𝑅𝑖, calculated as the difference in absolute years between
the planting finish date and the date at the end of reporting period
𝑅𝑖.
𝑌𝐶𝐹𝐼,𝑗 =
difference in absolute years between the planting finish date for
the 𝑗th stratum and the declaration date.
6.12
Calculating initial carbon stocks for a stratum when planting window IS NOT
included in the stratum definition
(1) For a stratum that is composed of project trees planted on or after the declaration
date:
(a) the initial carbon stock for the stratum (ICStratum,j) is zero; and
(b) the standard error for the initial carbon stock for the stratum (SEICStratum,j) is
zero.
(2) For a newly created stratum that is entirely composed of project trees planted
before the declaration date and previously referenced in an offsets report under an
alternative stratum identifier:
(a) the initial carbon stocks for the newly created stratum (ICStratum,j) is zero; and
(b) the standard error for the initial carbon stocks for the newly created
stratum (SEICStratum,j) is zero.
(3) For a stratum that is partially composed of project trees planted before the
declaration date and that have been referenced in an offsets report, the calculation
of the initial carbon stocks for the stratum must:
(a) be carried out in accordance with Equation 4c; and
23
(b) incorporate a standard error calculation in accordance with Equation 4d.
(4) For a stratum that is entirely composed of project trees that have been planted
before the declaration date and that have not previously been referenced in an
offsets report, the calculation of the initial carbon stocks for the stratum must:
(a) be carried out in accordance with Equation 4c; and
(b) incorporate a standard error calculation in accordance with Equation 4d.
(5) The initial carbon stocks for a stratum specified in subsection (4) must be calculated
using the following formula:
𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
× 𝑌𝐶𝐹𝐼,𝑗
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
Equation 4c
Where:
𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
initial carbon stocks for the 𝑗th stratum, in tonnes of CO2-e (t CO2-e).
𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
closing carbon stocks for the 𝑗th stratum for reporting period 𝑅𝑖 in
tonnes of CO2-e (t CO2-e), calculated in accordance with Equation 5a.
𝑅𝑖 =
first reporting period for the 𝑗th stratum, as a calendar date.
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
age of project trees in the 𝑗th stratum for reporting period 𝑅𝑖,
calculated as the difference in absolute years between the planting
start date and the date for reporting period 𝑅𝑖.
𝑌𝐶𝐹𝐼,𝑗 =
difference in absolute years between the planting start date for the
𝑗th stratum and the declaration date.
(6) When calculating the initial carbon stocks for a stratum specified in subsection (4),
the standard error must be calculated for the current reporting period (𝑅𝑖) using the
following formula:
𝑆𝐸𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
𝑆𝐸𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
× 𝑌𝐶𝐹𝐼,𝑗
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖
Equation 4d
24
Where:
𝑆𝐸𝐼𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗 =
standard error for initial carbon stocks for the 𝑗th stratum, in
tonnes of CO2-e (t CO2-e).
𝑆𝐸𝐶𝐶𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
standard error for closing carbon stocks for the 𝑗th stratum for
reporting period 𝑅𝑖 in tonnes of CO2-e (t CO2-e), calculated in
accordance with Equation 5b or 6b as appropriate.
𝑅𝑖 =
first reporting period for the 𝑗th stratum, as a calendar date.
𝐴𝑔𝑒𝑆𝑡𝑟𝑎𝑡𝑢𝑚,𝑗,𝑅𝑖 =
age of project trees in the 𝑗th stratum at the end of reporting
period 𝑅𝑖, calculated as the difference in absolute years between
the planting start date and the date at the end of reporting period
𝑅𝑖.
𝑌𝐶𝐹𝐼,𝑗 =
difference in absolute years between the planting start date for the
𝑗th stratum and the declaration date.
25
VARIATION 2
5
5.23 (2) (c)
REMOVE THE WORDS
(c) An allometric function must be applied only to project trees that occur within the allometric
domain for that allometric function.
AND REPLACE WITH THE WORDS (c) and ADD THE WORDS (d)
Inserts words that allows
allometric to be
conditionally applied to
trees with measurement
above max in allometric
domain
(c) An allometric function may be applied to project trees that occur within or above the upper
limit of the allometric domain for that allometric function, if
(d) The predictive measure of a project tree is above the upper limit of the allometric domain
that tree is to be attributed the same result as a tree at the upper limit of the allometric
domain.
5
5.24 (3)
REMOVE THE WORDS
(3) To avoid doubt, an allometric function must not be used if the information requirements
specified in subsection (1) cannot be met.
AND REPLACE WITH THE WORDS
(3) To avoid doubt, an allometric function must not be used if the information requirements
specified in subsection (1) (i) and (1) (ii) cannot be met.
Clarification that
allometric function can
be applied if some trees
have predictive measures
greater than the top end
of the allometric range
(4) To avoid doubt, if the predictive measure of a tree is greater than the upper limit of the
allometric domain that tree is to be attributed the same result as a tree at the upper limit of
the allometric domain.
5
5.41
ADD THE WORDS
(e) To avoid doubt, if predictor measures collected from the project tree during the full
inventory or PSP assessment DO exceed the allometric data range the allometric function is
applicable if trees above the allometric domain are treated according to 5.23 (2) c and d.
Allows allometric
function applicability test
to be passed with given
conditions.
26
VARIATION 3
5
5.32
ADD THE WORDS
The section clarifies that
it now incorporates
(9)
This section applies where a stratum specific function:
updating a stratum
(a) has been developed in accordance with section 5.31; and
specific allometric using
biomass sample tree data
(b) is being updated as part of a PSP assesment.
sourced during a PSP
(10) A project proponent must create a data subset by selecting from the PSP
assessment in addition to
assessment data set the identifiers of trees that returned a predictive measure
the original update
greater than the upper limit of the existing allometric domain.
during a full inventory.
(11) From the data subset at (10) subject to (12) biomass sample trees must be selected
The variation means that
in accordance with 5.31 (3) to (8).
the same processes will
(12) From the data subset at (10) least 10 biomass sample trees must be selected.
be carried out as
(13) The data collected from the biomass sample trees in accordance with previously but it is now
subsections (10) to (12) must be combined with the allometric dataset used to possible to use PSP
develop the original stratum specific function.
assessment data and
trees in addition to the
Updated regression function
previous TSP trees during
(14) The processes specified in sections 5.25, 5.27 and 5.28 must be applied to the a Full Inventory.
allometric dataset that has been combined in accordance with subsection (13).
(15) In the case where the minimum regression fit requirements specified in subsection
5.27(3) are met, the updated stratum specific function may be applied within the
stratum from which the allometric dataset was derived without applying the
validation process specified in section 5.42.
(16) In the case where the minimum regression fit requirements specified in subsection
5.27(3) are not met, the project proponent may develop a new stratum specific
function by combining the dataset collected from the biomass sample trees
assessed at subsections (9) to (12) with a minimum of at least a further 10 biomass
sample trees assessed.
27
5
5.33
ADD THE WORDS
(15) When a proponent conducts a full inventory or a PSP assessment and encounters
project trees with predictor measurements greater than the upper end of the
allometric domain of a regional function the regional function may be updated in
accordance with 5.31.
Clarifies that a regional
function and allometric
domain can be updated
and extended following
the techniques relevant
to updating and
extending stratum
specific functions and
domains.
28
VARIATION 4
3
3.4 (3)
EDIT SO THAT ABSOLUTE 10HA IS REPLACED WITH A DEFINITION OF 5% OF HECTARES
(3)
If the growth disturbance affects an area of more than 5% of the hectares in a stratum,
the project proponent must, before submitting the offsets report that relates to the
time when the growth disturbance occurred, revise the affected stratum in accordance
with this section.
(4)
If the growth disturbance affects an area of 5% of the hectares or less in a stratum, the
project proponent may, before submitting the offsets report that relates to the time
when the growth disturbance occurred:
3.4 (4)
Allows redefinition as per
application
VARIATION 5 and 6
3
3.4 (6)
EDIT AS FOLLOWS
(6)
3
3.4 (7)
Clarifies that only
If only a part of the stratum is affected by the growth disturbance, then the stratum is affected area must be
revised by mapping and excising that portion of the stratum affected by the growth mapped
disturbance and defining this area as a separate stratum which:
ADD THE WORDS
Clarifies that proponent
can elect to assume
(b) the carbon stocks and the standard error for ongoing carbon stocks must be
affected area has zero
assumed to be zero for the disturbance affected stratum until:
CO2 if measurement of
(i) such time as a full inventory is conducted on the disturbance affected small amount deemed
stratum or;
economically irrational
(ii) the disturbance affected stratum can be demonstrated to have
characteristics that qualify the area to be returned to the unaffected
stratum and a full inventory is conducted on the re-amalgamated
stratum; and
(iii) if a full inventory or re-amalgamation of the affected stratum is not
completed within 5 years of the event the affected stratum must be
removed from the project.
3
3.4 (8)
EDIT AS FOLLOWS
Introduces an alternative
29
to a full inventory
(a) a full inventory may be conducted in both the fire affected stratum and the stratum
from which the fire affected stratum was excised, within 12 months after the fire
event
3
3.4 (8)
6
6.36 (1)
ADD THE WORDS
Confirms a full inventory
or PSP assessment
(b) if a full inventory is not conducted on the fire affected stratum 7(b) applies:
available to proponent
(c) a PSP of full inventory assessment must be conducted on the non affected stratum, and defines how the area
within 12months after the fire event;
of the non affected area
(i) If a PSP assessment is undertaken the area of the non affected stratum will be will be defines in terms of
area without the need to
defined as the area of the pre-event stratum less the area mapped as affected.
remap before the next
full inventory is
conducted.
(b)
the fire event exceeds the area threshold of 5% of project area(s) hectares;
Changed to incorporate
variation 4
6.36 (1)
(d)
an inventory is conducted in both the fire-affected and non-fire-affected strata within
12 months of the date of the fire event in accordance with section 3.4.
If variation 5 and 6
adopted a PSPA may be
executed on non affected
and the affected may be
ignored with assumption
zero carbon stock
Equation 26a
If full inventory of fire affected area conducted mean plot carbon stocks for plots within fire
affected stratum 𝑗 for reporting period 𝑅𝑖 in tonnes per hectare of CO2-e (t.ha-1 CO2-e),
calculated in accordance with Equation 11a or if full inventory of fire affected area not
conducted assumed to be zero.
Alternative of calculating
emissions if full inventory
of affected conducted ort
not conducted
30
Please provide any additional information to support the explanations provided above. Include supporting evidence and justifications for any
assumptions or estimations relied upon.
Deliberately left blank. Matters covered in previous sections and attachments.
31
Section 6: References
Provide a full citation for all reports, papers and journal articles cited in this application.
Huxtable D, 2014 CFI ex‐post analysis of 2009‐2010E. kochii Inventory, unpublished report for CCF.
Huxtable D, 2013 Allometric Report, unpublished report submitted as part of 2013 CCF Offsets
Report on CFI Project.
Fitzgerald A, 2014 Managing CO2e Reversal Events V1.2, unpublished based on CCF 2013 full
inventory analysis.
Fitzgerald A, 2014, Case Study Supporting Proposed Variation 5 and 6, unpublished based on
modelling results of 2013 full inventory and forecast outcomes of full inventories or PSPA.
Pers. Comm Anthony Fitzgerald and Clean Energy Regulator emails updating allometric domain.
Peck A, Sudmeyer R, Huxtable D, Bartle J & Mendham D 2012, Productivity of Mallee
Agroforestry Systems: The effect of harvest and competition management regimes, RIRDC
Publication No 11/162; Rural Industries Research and Development Corporation, Canberra.
K. Paul et al. 2013, Improved estimation of biomass accumulation by environmental planting and
mallee plantings using FullCAM, Report for The Department of the Environment, CSIRO Sustainable
Agriculture Flagship, Canberra, Australia.
Section 7: Appendices
List below and append all relevant documentation necessary to assess this application, including
cited reports, papers and journal articles that are not publically available.
Applicants must attach a copy of the relevant methodology determination with the proposed
variations clearly marked.
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Section 8: Disclosure
Clearly identify documents or parts of documents included as supporting information to the
submission that are marked CONFIDENTIAL and should not be published. Confidential information
must not be included in any of the sections of this form.
Provide a reason why the document or part of document should not be published.
Acceptable justification would include that the information should not be published if it reveals, or
could be capable of revealing:

trade secrets; or

any other matter having a commercial value that would be, or could reasonably be
expected to be, destroyed or diminished if the information were disclosed.
Document/part of document
Reason for confidentiality
Section 9: Declaration
This application must be signed by a duly authorised representative of the applicant. The person
signing should read the following declaration and sign below.
Division 137 of the Criminal Code makes it an offence for a person to give information to a
Commonwealth entity if the person providing the information knows that the information is false or
misleading. The maximum penalty for such an offence is imprisonment up to 12 months.
By signing below, the signatory acknowledges that he or she is an authorised representative of the
applicant, and that all of the information contained in this application is true and correct. The
signatory also acknowledges that any of the information provided in this application may be copied,
recorded, used or disclosed by the Department of Climate Change and Energy Efficiency for any
purpose relevant to the CFI. Information will not be publicly disclosed by the Department where it
has been identified as confidential by the applicant.
Full name of the
person signing as
representative of the
applicant
Anthony Irwin Fitzgerald
Position
Commercial Manager
Signature
Date
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