DOMESTIC OFFSETS INTEGRITY COMMITTEE
Reasons for Refusal to Endorse Methodology Proposal
Reduction of emissions of methane through the application of a feed supplement to
dairy cows
The Domestic Offsets Integrity Committee (DOIC) advises that it has refused to endorse the
methodology proposal for Reduction of emissions of methane through the application of a
feed supplement to dairy cows (Ref: 2012LD027) 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 methodology covers the whole dairy
industry, which comprises five sectors with
distinct feeding regimes. The methodology does
not provide instructions to enable baselines to
be set for each of these different sectors, which
take account of the different amounts and types
of feed that cows would 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 (positive list).
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. As the methodology does not
specify which particular feed additives it covers, it is
not possible to calculate project abatement.
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 methodology proposal does not take account
of evidence of the different effects of different food
additives on cows’ health and methane emissions.
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
would need to be included.
* Section of the Carbon Credits (Carbon Farming Initiative) Act 2011