Soil Carbon Practitioners Industry Working Group submission on new Agricultural Systems Method

Tuesday 21 November 2017
The Soil Carbon Practitioners Industry Working Group (SCPIWG) is an informal collaboration of Emissions Reduction Fund (ERF) soil carbon project developers.
The group was formed in response to the many opportunities and challenges presented by soil carbon projects.  The work to date developing methodologies under the Carbon Farming Initiative and Emissions Reduction Fund, in combination with the efforts of pioneering project developers, have put Australia in a global leadership position on soil carbon measurement, reporting and verification (MRV).  Members of the SCPIWG have collectively invested millions in operationalising soil ERF carbon projects, and are positioned to increase this investment to more than A$100 million over the next few years.
"We are very proud to have played a role in convening the working group", said Corporate Carbon Managing Director Matthew Warnken.  "Especially given that SCPIWG members have direct practical experience with the registration, baselining, management strategies for enhanced sequestration and project implementation of soil carbon projects.  However, it is imperative that the early learnings from SCPIWG members are incorporated into the new Method if the potential for Australia to capitalise on the soil carbon opportunity is to be realised."
The following organisations are represented: Australian Soil Management, Australian Organic Recycling Association, Australian Soil Services, Carbon Farmers of Australia, Carbon Link, Carbon X, PundaZoie Company (Greening the Desert), Regenerative Australian Farmers, Ylad Living Soils and Corporate Carbon.
A detailed submission on the Carbon Credits (Carbon Farming Initiative - Measurement of Soil Carbon Sequestration in Agricultural Systems) Methodology Determination 2017 was prepared for the Department of the Environment and Energy and is available here.  In general, the Method represents a significant improvement on previous versions, as a result of the following features:
  • expanded range of permitted management practices (for example cropping)
  • improved flexibility in sampling design (unequal strata areas allowed)
  • allowed new technology approaches for measurement (vis-NIR that CSIRO are developing)
  • no need to notify Regulator every time management practices change
  • greater clarification on definitional and operational matters
  • greater clarity on the management of trees and regrowth
  • general improvement in implementation of the carbon accounting equations.
These improvements are welcome and will have a significant positive impact on development and implementation of soil carbon projects.  Building soil organic carbon levels in agricultural systems is gaining recognition as one of the most important strategic pathways for mitigating the worst impacts of climate change as well as helping the agricultural sector adapt to climate change.  It also improves agricultural sustainability by supporting additional income, improved productivity and resilience.  
Given the strategic importance of soil carbon in delivering a double dividend of improved agricultural performance and increased sequestration, SCPIWG made the following recommendations to improve the operability and take up of the new method:
  • removal of the arbitrary 50 per cent discount at the first sampling round and application of a sliding scale based on the length of time between the first sampling and the baseline sampling round
  • re-structure of equations, address some drafting errors and clarify key eligibility criteria and definitions
  • allow the Grazing method and new Agricultural Systems method to operate concurrently for a period of 24 months to prevent any unintended consequences arising during implementation of the new method
  • replace requirement for a land management strategy with a 'participation declaration' acknowledging key project risks and a landowner commitment to implementation
  • baseline period of 5 (not 10) years, with default options for baseline values for projects without data (such as new property acquisitions)
  • provide SCPIWG with an opportunity to conduct an operability test prior to being finalised as part of the Determination presented to ERAC for final review.
Taking up the SCPIWG recommendations would be a significant step to supporting wide spread participation in soil carbon projects.  Any comments or clarifications in relation to the SCPIWG submission can be directed in the first instance to Matthew Warnken.
Matthew Warnken
Managing Director
+61 418 238 040

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