On Tues, @DCCEEW say Chubb made recommendations on how the HIR method should be interpreted *but* didn't say the method had been incorrectly interpreted to date.
@sarahinthesen8 "Why would you have to clarify interpretation if it [HIR] hadn't been misinterpreted?"
On the interpretation of the HIR method, we argue that ACCUs should only be issued to projects where native forest is regrowing in areas that have been cleared - where forest doesn't already exist.
Currently, ACCUs are issued to projects where trees and shrubs *already exist*
Yes, we mean that our analysis shows the HIR method is interpreted by @CERegulator so that ACCUs are issued to projects, to grow trees, apparently on top of existing trees.
That's why we're concerned. Andrew explained this in @AuSenate on Monday
And you know what? GreenCollar - the #ACCU market's largest developer - largely agrees with us. Here's an excerpt of a letter we co-wrote and submitted to the Chubb review.
Despite this evidence, and agreement between arguably the biggest critics of the HIR method (ANU-UNSW team) and its biggest proponent, the Chubb review found:
* HIR meets integrity standards🤔, BUT
* recommended changes to its interpretation🤷
On Tuesday @DCCEEW told @sarahinthesen8 that the Government expects to accept HIR #ACCUs from existing projects "indefinitely".
They say the Chubb recommendations only apply to *new projects* "going forward", and confirm the avoided deforestation method has been revoked.
Another question to @DCCEEW on Tuesday regarding #ACCU integrity
"There isn't any issue about the ACCUs already in circulation, out of that [HIR] method or any other method"
Here is discussion about the avoided deforestation method (now revoked, based on Chubb recommendation).
@dcceew says "the integrity is fine" for existing ACCUs from that method. @CERegulator says Chubb "did not raise broad concerns about [it] as a method"
For completeness, here is @CERegulator saying the Chubb review "did not say it thought the landfill gas method as is had substantial problems", but *going forward* it would be reasonable for baselines to be increased (so ACCUs are issued for real & additional abatement)
Note that the landfill gas method is the one most companies who profit from it say it needs to change abc.net.au/news/2022-09-0…
So ok, both @DCCEEW & @CERegulator said on Tuesday that Chubb rec's apply only to *new projects*. This is what we feared, and outline in another thread linked here.
But, I could have sworn I heard differently earlier👇
Why did @DCCEEW say at the start of February that the Chubb rec's apply to existing and new ACCU projects, and by the end of the month both it and @CERegulator emphasise repeatedly that the Chubb rec's only apply to new projects, going forward?
We've estimated that around 1/4 to 1/3 of the #SafeguardMechanism abatement - 60 to 75 million tonnes of CO2e - conservatively - could be delivered by ACCUs that we consider low integrity from *existing* HIR, avoided def, and landfill gas methods.
A final note - the CEA data is NOT COMPLEX DATA. They are literally basic polygon shapefiles showing where sequestration is meant to occur. You can overlay them on Google Earth to see if trees already exist in them or not. No LIDAR or drones or machines that go ping needed.
A final final note - there is other important information that is not publicly available.
👉The root cause of this scandal is the Clean Energy Regulator, which has allowed HIR projects to include uncleared lands when the projects started in their credited areas
📝 There are multiple lines of evidence that show the HIR method should only be applied in locations...
...that have been previously cleared.
One is the the Explanatory Statement to the method () which says: “The Determination applies to projects in which land has been cleared of native vegetation and where regrowth has been suppressed for at least 10 years.”legislation.gov.au/F2013L00162/as…
The ANU-UNSW research team has analysed the recently released CEA (carbon estimation area) for HIR #carbon projects. The results are unsurprisingly bad. 🧵Full papers and interactive data linked below: 1/
HIR (human-induced regen of permanent even-aged native forest) carbon projects have generated ~30% of ACCUs issued under the #EmissionsReductionFund; 37 million ACCUs. They cover more than 31 million ha, ~ the size of Japan. The world’s largest offset type by project area. 2/
Following the Chubb review & the #SafeguardMechanism deal, CEA (carbon estimation area) data has been made public:
Our team's analyses have repeatedly been criticized as incomplete without CEA data. Now we've analysed it, and the results are clear. 3/ https://t.co/wx5hWg1yMQcleanenergyregulator.gov.au/ERF/project-an…
The Australian Government @DCCEEW last week quietly released draft National Environmental Standards (NES) for Matters of National Environmental Significance (MNES) as part of its #EPBCAct reform.
*2 weeks consultation*, due 22 May 2023
A🧵on key issues👇 consult.dcceew.gov.au/draft-nes-for-…
Note the overarching MNES standard is the first to be released, there are others in development that will be released (hopefully) soon, including for:
- Environmental Offsets
- Regional Planning
- First Nations Engagement and Participation
- Community Engagement
2/
First, what's the overall goal? #NaturePositive! (it's mentioned 19 times in the document)
What does this mean? Apparently - a "collective outcome" where the environment is "repaired, regenerated and protected", requiring action everyone, not just government.
Oh cry me a river. How on earth could their projects be "undermined" by sharing data which could quickly an easily prove their integrity. #ACCU#climate#auspol
Also nice for GreenCollar to put this on "it's landholders" so if we call this out we're being mean to farmers, rather a multi-million dollar corporation.
The data carbon companies could freely release (the Regulator & all others are prohibited to release by law) are Carbon Estimation Areas (CEAs) - green shapes shown below
The project area shapefiles (around CEAs) are *already public* - downloadable here researchdata.edu.au/area-based-emi…
It's no secret that conservation science (and journals, and the media) loves a good global map - and there's a lot of them. We found >150 global priority maps published since 2000 (and that's DEFINITELY an UNDERestimate)
So what? Maps can be super useful, and salient, and have helped (and continue to do so) raise awareness and $ for #conservation
But is there a risk we're overestimating their value?