CARBON FARMING INITIATIVE
Application to Vary a Methodology Determination
Carbon Credits (Carbon Farming Initiative) (Avoided Deforestation) Methodology Determination 2013
Climate Friendly Pty 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.
Privacy
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 personal information may be used by the Department for consultation
purposes or to contact you in the future.
For more information about the Department’s privacy practices, see the full privacy notice on the Department’s website. If you have any questions about
privacy issues please contact:
Privacy Contact Officer
Department of Climate Change and Energy Efficiency
GPO Box 854
Canberra ACT 2601
Phone: + 61 2 6159 7000
Website: www.climatechange.gov.au
Intellectual Property
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.
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Copyright in this document vests in Climate Friendly Pty Ltd.
Creative Commons licence
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 ...................................................................................................................... 6
Section 1: Methodology Determination Title and Applicant Details ...................................................... 9
Section 2: Expert consultation .............................................................................................................. 10
Section 3: Revised methodology determination glossary .................................................................... 10
Section 4: Justification for variation ..................................................................................................... 10
Section 5: Explanation for variation ...................................................................................................... 13
Section 6: References............................................................................................................................ 18
Section 7: Appendices ........................................................................................................................... 19
Section 8: Disclosure ............................................................................................................................. 19
Section 9: Declaration ........................................................................................................................... 20
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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.
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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) (Avoided Deforestation) Methodology Determination 2013
methodology
determination that
is the subject of the
application:
Specified date on
which the
methodology
determination was
made:
23 June 2013
Name of applicant:
Josh Harris
Company:
Climate Friendly Pty Ltd
Position:
Carbon Farming Development Manager
Telephone:
02 8115 0007
Email:
Josh.harris@climatefriendly.com
Address:
Level, 2 14 William Street, Woolloomooloo, 2043, Sydney
Postal address (if
different to above):
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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)
Florian Reimer, Forestry Project
Manager
South Pole Carbon Asset
Management Ltd.
Yes
South Pole Carbon Asset
Management Ltd.
Yes
f.reimer@southpolecarbon.com
Pablo Llopis Benito, Forestry
Project Manager
p.llopis@southpolecarbon.com
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
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Outline the reasons why the methodology determination specified in Section 1 should be varied.
The Native Forest Protection methodology determination dated 23 June 2013 is demanding, very broad and requires very costly field inventory work, which is
undertaken at risk before a landowner receives a return on their investment.
The methodology has created a market failure by driving out the majority of project developers from the avoided deforestation project class because of the high
up-front costs and risks. These costs and risk do not improve the accuracy of abatement estimates.
Of note, the sections on destructive sampling for development of allometric equations and biomass surveys front load a large amount of work, which is
undertaken at risk.
The methodology actually disincentives climate change mitigation action by land owners. The environmental integrity of the CFI can be maintained by more
efficient and streamlined monitoring guidelines.
Years of experience in technical development of international forest carbon projects under high-quality carbon standard like the CDM, Verified Carbon Standard
(VCS), the CarbonFix Standard (CFS), the Gold Standard (GS) or the Climate, Community, & Biodiversity Standard (CCBS) give the consulted experts an assurance
that the proposed variation will achieve two main goals:
a) maintain and enhance the environmental integrity of Native Forest Protection Projects under the CFI
b) remove disincentives and tap into a larger reservoir of market-efficient offsetting action by Australian landowners.
Please provide additional information to support the statements above. Include supporting evidence and justifications for any assumptions or estimations relied
upon.
The proponents of the variation have indulged in a complete, hands-on effort to develop a project under the existing Native Forest Protection determination
and their findings are the result of their detailed work in the field using the methodology. The recommendations for this variation application are based on a
profound understanding of forest carbon accounting, statistical sampling, forest ecosystem dynamics, allometric development, prediction of forest biomass and
commercial timber volume, Geographical Information Systems, and project development coordination.
The Native Forest Protection methodology as it stands is not user friendly for multi-species native forest projects, demands overreaching sampling procedures
whose results could be achieved much more efficiently with the same amount of assurance, and is overburdening private landowners with rigid demands equal
to a nationally financed research programme on Greenhouse Gas Accounting. Many of the data demanded to be re-monitored by every project has little
variation (like wood-density per tree species) and could be more efficiently established on a national / regional level and applied by landowners as default
values. This proposed variation does not go so far to propose or demand such default values, but scales back a few unnecessarily rigid requirements to a level
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still within the limits of a feasible monitoring operation financed by private landowners upfront. The proposed variations were designed with the aim of not
changing the character of the methodology, but to improve it on a few technical issues whose consequences for real-world project development can be easily
overlooked, but have tremendous impacts. For example, not a single equation was removed, changed or added. Abatement calculations function exactly the
same way as the prior version of the determination. The proposed variation is limited to demands of on-site monitoring, which is the most costly element of a
Native Forest Protection project development.
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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
Explanation
Subdivision
3.4.2
Allometric
equations
3.13 Allometric
equations to be
validated or
developed
Introduction text original “In relation to each
tree species or group of species in the project
area measured as part of the biomass survey
undertaken in accordance with Subdivision
3.4.3, the project proponent must:”
Demanding private landowners to develop or validate allometric
equations for every species occurring on their property, even if it is not
even included in the clearing consent or they do not plan to include it
into the project mechanism, is by far overreaching reasonable demands.
A carbon project and offset report is not an ecological research
programme. This interpretation has been shared already be the
Regulator and the recommendation given by the Regulator was to only
develop allometric equations to cover the species included in the clearing
consent and set the biomass of non-project trees to zero if a published,
peer reviewed allometric equation is not available for them.
Modified to:
“In relation to each tree species or group of
species mentioned in the clearing consent and
for which abatement shall be calculated in the
project area, the project proponent must:”
Subdivision
3.4.2
Allometric
equations
Step 2—
Determination of
allometric domains
Added requirement:
“(7) For clarity, species groups of allometric
equations must have the same
species-dependent growth form as
defined in section 1.3 Definitions.
In terms of the non-project tree buffer, please see changes and
justification for 3.4.3 Biomass survey 3.41 Step 2.2.
Within the determination it states that “the measurement protocols for
the allometric equation are known and are consistently applied” – if the
practice in the development of the allometric equation is to treat forked
trees as separate trees when the fork is below 1.3m, then this should also
be done when applying the allometric. This is similar to where 1.3m is
measured on leaning trees (vertical height vs along the stem). To improve
clarity, the application of the definition of growth form is applied here
where a growth form is species-dependent.
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Subdivision
3.4.2
Allometric
equations
3.18 Step 4—
Determination of
plot design for tree
selection
(2)
Enough plots must be allocated to
The requirement only makes sense if it is meant to be 100 trees per
capture at least 100 trees per species species or species group. This addition simply clarifies the original.
or species group represented by the
allometric equation across the area
mentioned in subsection 3.19(1).
Subdivision
3.4.2
Allometric
equations
3.19 Step 5—
Allocation of plots
for tree selection
Introduced the concept of allometric survey
sites:
(1) When developing an allometric
equation, plots for tree selection must
be allocated within:
(a) an allometric survey site, and
(b) the spatial extent of the
allometric domain as defined in
section 3.16.
The original methodology does not require plots for allometric tree
selection to be allocated in all carbon estimation areas. The
methodology requires allocation in “one or more” CEA. There is no
reason to introduce requirements of un-biased geographic determination
of the allometric survey sites as long as they are within the CEAs.
Because allometric survey sites do not figure into the final abatement
calculations and are sub-divisions of CEAs, we see no need to mention
them in Division 3.2 Stratification.
(2) The geographic extent of the allometric
survey sites is determined by project
proponents.
(3) When validating an allometric equation,
plots for tree selection must be
allocated across the carbon estimation
area or areas in which the allometric
equation is to be applied.
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(4 ) Plots are allocated for tree selection across
the allometric survey sites and carbon
estimation areas using a pseudo-random
number generator with a known seed number.
Subdivision
3.4.2
Allometric
equations
3.20 Step 6—
Survey and random
selection of trees
for destructive
sampling
Added requirement:
Subdivision
3.4.2
Allometric
equations
3.20 Step 6—
Survey and random
selection of trees
for destructive
sampling
Added requirement:
Subdivision
3.4.2
Allometric
equations
3.22 Step 8—
Destructive
sampling
procedure
Modified requirement (3a i):
Subdivision
3.22
Deleted requirement (5) & (6):
Step 8—
“(6) If for a species or species group the
minimum number of measured trees (100)
is reached, this species no longer needs to
be measured in destructive sampling plots
henceforth. If the proponent opts to not
measure trees after 100 area reached, then
plots allocated following section 3.19 must
be measured in the order of the random
numbers generated and not at
convenience.”
“(7)Trees measured in destructive sampling
plots are not to be included in the biomass
survey.”
“(i)
at least every fourth tree cut down in
accordance with subsection (1) in the
order of cutting; and
Abundant species will appear much more frequently in many destructive
sample plots and their list of 100 individual trees per species or group of
species will be reached much faster than other infrequent species.
Having to continue to measure and record trees of species or species
group that already reached the necessary number for the list of random
tree selection is an unnecessary cost that can be avoided without having
an effect on abatement calculations.
The original methodology did not clearly state if trees measured in
destructive sample plots can be included in the estimation of biomass per
CEA if the plot was established with the same properties. As destructive
sample plots are altered by the destructive sampling process, it is a
cleaner solution to directly prohibit their inclusion.
Cutting into components, sub-sampling and dry-weighing is a very costly
part of the monitoring of the project. Every forth tree per single species
still guarantees dry-weight data of 4 trees, which is sufficient to establish
the dry-to-wet ratio of a single species in a single project area.
This requirement introduces an unnecessary large risk for the project
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3.4.2
Allometric
equations
Destructive
sampling
procedure
“
(5) The trees mentioned in subsection
(3) must have been cut down within
a 30 day period.
(6) Subsection (5) does not apply if each
tree mentioned in subsection (1) has
been analysed in accordance with
section 3.23.
proponent. If during first verification a problem is found by the auditor
with a detail of his destructive sampling procedure, it could be
interpreted in a way that the destructive sampling cannot be adapted
and parts added, but the entire sampling has become invalid and has to
be repeated. This is an unjustifiable risk given the high costs and large
complexities of the methodology. Also the methodology already has a
safeguard against too high variations in wet-to-dry ratio in 3.23 Step 9—
Biomass analysis, clause (4). Seasonal variations in wet-weight are
therefore already hedged.
Subdivision
3.4.2
Allometric
equations
3.22 Step 8—
Destructive
sampling
procedure
Modified requirement (7 in original, now 5 after
variation above):
Subdivision
3.4.2
Allometric
equations
3.25 Step 11—
Validation of
allometric equation
Clarification added to requirement (10):
3.4.3 Biomass
survey
3.41 Step 2.1
For the value NPTi in the variable explanations
of equation 12, added: “If the option (a) is
selected in Step 2.2, NPTi is automatically 0.”
See justification below.
3.4.3 Biomass
3.41 Step 2.2
Changed requirement 2 to:
The non-project tree buffer introduces unnecessary restrictions to
project development and inaccuracies. First, the restrictions concern the
“(5)
If an allometric equation is to be
developed for a group of species, each of the
trees at least every second tree per species cut
down in accordance with subsection (1) must
be cut into component parts in accordance with
subsection (4).”
“…This mandates the sub-sampling of tree
components for establishment of dry-weight of
every second tree used for validation of an
allometric equation.”
Cutting into components, sub-sampling and dry-weighing is a very costly
part of the monitoring of the project. Every second tree per species still
guarantees the inclusion of information of all species in the species group
to contribute to development of the allometric for the species group
sufficiently. Otherwise the grouping of species becomes obsolete as it is
much more destructive sampling work than developing an allometric
equation for each species.
The necessity of sub-sampling tree components of trees used for
validation of an allometric equation was not clear in the methodology
and quite open to interpretation. After having discussed the issue with
the Regulator and received their advice that every tree used to validate
an equation must be cut into component parts and measured to
determine dry weight, this variation streamlines that requirement by
only sub-sampling every second tree destructively sampled for validation.
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survey
3.4.3 Biomass
survey
“(2)
If the deforestation plan provides that a
certain kind of tree in the project area must not
be cleared, the project proponent must select
either or both options:
fact that a project proponent could not choose to exclude a tree species
from allometric development and biomass survey in the first monitoring
period and include it in later reporting periods, as the non-project tree
buffer is only calculated once in the first monitoring period. Second, it
introduces also the confusion that biomass would have to be calculated
(a)
either the biomass for all trees for species not intended to be cleared, thus mandating development of
allometric equations for them. Third, the non-project tree buffer seems
not to be cleared in the deforestation plan is
to be an anomaly in the wider frame of international forest carbon
automatically set to 0 or
accounting methodologies and introduce unnecessary inaccuracy. The
experts drafting this methodology variation have never come across
something comparable in CDM, VCS, CarbonFix or Gold Standard. The
(b)
the following formula must be
non-project tree buffer seems to be contradictory to the section 1.3.3 of
used to compute the constant, non project tree
the CFI Sampling Guidelines where it is explicitly stated “ Errors
buffer for each carbon estimation area using
associated with inappropriate multiplication or division of two or more
data collected in the first reporting period:...
component estimates must be minimised.” The application of an average
(3) If project proponents includes option (a)
deduction to all plots’ biomass in form of the non-project tree buffer
then the kinds of trees for which the biomass
applies a ratio calculated as a mean from non-project biomass to all
has been set to zero must not be included in the plots. From these plots, effectively a new average of biomass per plot is
results of any biomass survey.
calculated as part of equation 12. Thus, a ratio is applied to results later
to be averaged to a ratio again. The fact that the average biomass per
This does not include project trees which have
plots is not an explicit variable but implicit in equation 12 does not
been excluded from the results biomass survey
change this fact. As the project proponent has to record in their biomass
due to a lack of allometric equation according
survey the fact that a tree is a non-project tree, it is actually easier,
to Section 3.25 step 11.1. Such trees can be
leaner and more accurate to directly set the biomass of such trees to
later included if an allometric equation is
zero and not apply a ratio deduction over the board to all plots.
validated in accordance with Section 3.25.
Parameters measured in biomass survey for project trees must also be
measured for non-project trees. This includes trees clearable in the
clearing consent, but have their biomass set to 0 because no allometric
equation had been developed at the time of the previous offset reports.
3.41 Step 2.3
Changed the requirement (5) in original, now
(6=: “If under step 2.2 option (b) is selected the
total biomass of non-project trees in each plot
See justification 3.41 Step 2.2.
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must be calculated using the following formula:
Please provide any additional information to support the explanations provided above. Include supporting evidence and justifications for any assumptions or
estimations relied upon.
In order to increase readability, all explanations and scientific references have been given directly with each item of proposed variation. Therefore statements
made above are not repeated in this field.
Section 6: References
Provide a full citation for all reports, papers and journal articles cited in this application.
[1] CDM (2011): A/R Methodological Tool - Demonstrating appropriateness of allometric equations for estimation of aboveground tree biomass in A/R CDM
project activities” (Version 01.0.0). Online: https://cdm.unfccc.int/methodologies/ARmethodologies/tools/ar-am-tool-17-v1.pdf - ACTIVE MODULE
[2] Pearson, T.; Walker, S. & S. Brown (2005): Sourcebook for Land Use, Land-Use Change and Forestry Projects. BioCarbon Fund & Winrock International.
Online: http://www.forestcarbonportal.com/resource/sourcebook-land-use-land-use-change-and-forestry-projects
[3] Verified Carbon Standard (2013): Methodology for Avoided Deforestation VM0009 v2.1. Online: http://v-c-s.org/methodologies/VM0009 - ACTIVE MODULE
[4] FAO (2006): Appendix 1 - List of wood densities for tree species from tropical America, Africa, and Asia. Online:
http://www.fao.org/docrep/w4095e/w4095e0c.htm
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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.
All cited references are online and given with the connecting link recently accessed.
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
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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
Josh Harris
Position
Carbon Farming Development Manager
Signature
Date
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