DOMESTIC OFFSETS INTEGRITY COMMITTEE
Reasons for Refusal to Endorse Methodology Proposal
Addition of feed additives to reduce methane emissions from enteric fermentation
in ruminants
The Domestic Offsets Integrity Committee (DOIC) advises that it has decided to refuse to
endorse methodology proposal Addition of feed additives to reduce methane emissions from
enteric fermentation in ruminants (Ref: 2012FE043) because it does not satisfy the
requirements for a methodology determination specified in Section 112 of the Carbon
Credits (Carbon Farming Initiative) Act 2011 (the Act).
The reasons for the DOIC’s decision to refuse to endorse the methodology proposal are set
out in Tables 1 and 2 below. These reasons will also be published on the Department’s web
site within 28 days of the decision in compliance with Section 112 (14A) of the Act.
Table 1 – Requirements to be met for methodology proposal endorsement by the DOIC
Section*
Requirement
Statement
112(3)(a)
Complies with the offsets
integrity standards
See Table 2 below.
112(3)(b)
Does not refer to a state or part
of a state
Complies.
112(3)(c)
Complies with regulations made
for the purpose of 106(4)(e)
No regulations specified.
112(3)(d)
Includes calculation of a baseline
for a project.
The proposal covers a broad range of very
different feed additives. Some of these are
already in common use whereas others are
untested. Further, the impact of feed additives
will depend on the nutritional make-up of the
cows’ normal diet.
The methodology does not provide instructions
to enable baselines to be set for different
supplements, which take account of the different
types of feed and additives that cows would
normally receive in the absence of the CFI
project.
112(3)(g)
Applies methods specified under
the National Greenhouse and
Energy Reporting Act 2007 (NGER
Act) where appropriate.
The methodology proposal does not provide for the
estimation of fuel use in accordance with the NGER
Act.
* Section of the Carbon Credits (Carbon Farming Initiative) Act 2011
Table 2 – Offsets Integrity Standards
Section*
Requirement
Statement
133(1)(a)
Covered by the additionality test
regulations.
The methodology covers a broad range of food
supplements, some of which are already in
common use.
133(1)(b)
Estimations of emissions
reduction, sequestration and
emissions are measurable and
capable of being verified.
Different feed additives have different emissions
reduction potential. The methodology does not
provide instructions for estimating abatement
associated with different food additives.
Further, beyond a certain level, feed additives can
become toxic to cattle and ineffective in reducing
emissions. The methodology does not take account
of these effects.
133(1)(c)
Methods specified in the
methodology are not inconsistent
with the methods set out in the
National Inventory Report.
There is insufficient information to determine
whether the methods in the proposal are consistent
with the methods in the National Inventory Report.
133(1)(d)
The methodology is supported by
relevant scientific results
published in peer-reviewed
literature.
The proposal does not take account of evidence of
the varying effects of different food additives on
both methane emissions and cattle.
133(1)(e)
Net abatement is calculated after
deducting the emissions
generated as a result of carrying
out the project.
The greenhouse gas assessment boundary is
incomplete. It does not include emissions from fuel
use.
133(1)(f)
Methodologies related to
sequestration projects should
provide for adjustments that take
account of cyclical variations.
The methodology does not need to provide for
adjustments for cyclical variations because it is not
related to a sequestration project.
133(1)(g)
Estimates, projections or
assumptions included in the
methodology are conservative.
The methodology proposal does not provide
instructions for calculating the abatement from
different feed additives that take account of the
nutritional composition of cows’ existing diet
133(1)(h)
Applies methods specified under
the National Greenhouse and
Energy Reporting Act 2007 (NGER
Act) where appropriate.
The methodology proposal does not provide for the
estimation of fuel use in accordance with the NGER
Act.
The proposal does not account for differences in
the gas assessment boundary for different types of
feed additives. Additives such as fats/oils are
bi-products that would be produced anyway and
would not need to be included in the project
boundary. Additives such as tannins or nitrates
would be produced because of the project and may
need to be included.
* Section of the Carbon Credits (Carbon Farming Initiative) Act 2011