Design of the Carbon Farming Initiative. Submission by David Mason-Jones

2011-01-16T22:17:00.000-08:00

On the 25th November, 2011, the Australian Government's Department of Climate Change and Energy Efficiency released a Discussion Paper titled, 'Design of the Carbon Farming Initiative - Consultation Paper. The paper invited submissions to be made by 21st January 2011. For those interested, this is the final draft of my submission which I will be placing on rhe Departments website before the closing date.

I'd be happy to receive comments and feedback from anyone wishing to comment on this blog.

Contact Details
Name of Organisation: David Mason-Jones, Journalist ABN 84 316 149 806
Name of Author: David Mason-Jones
Phone Number: 0411 172 328
Email: david@journalist.com.au
Website: www.journalist.com.au
Date: 17 Jan 2011

Scheme design principles
In their broad scope the scheme design principles are good. However, when it comes to the requirement for the emissions to be ‘additional’, I foresee some potential adverse and perverse results if the clause is to operate, as specified, in the Consultation Paper.

No one could argue with the proposition that landholders should only earn carbon credits that are additional to what existed before. However the actual operation of this requirement – as described in the Design of the Carbon Farming initiative Consultation Paper – mean that landholders could be deprived of earning credits for carbon they have genuinely sequestered. The adverse result of this could be that landholders who are genuinely doing a good job in drawing down atmospheric carbon dioxide, and storing it as soil carbon, could just give up on the project when their entitlement to earn carbon credits is terminated. The perverse result would be that the commercial incentive would be withdrawn from the very people who are doing the most to sequester carbon

My comments about the devil in the detail will be developed later in this document.

Scheme coverage
The first paragraph is excellent. A very good and positive recognition of the shortcomings of the Kyoto arrangements and a welcome practical way of recognising various, non Kyoto, abatement methods.

My comments about the eligible abatement methods:

Reforestation and revegetation
There should not be a presumption in the legislation that all tree planting is automatically an environmentally or ecologically sound management practice in Australia. This is most urgently the case where trees are to be planted in areas which were natural grasslands before Europeans arrived in Australia. Planting forests in former grasslands is not a case of “Re-forestation” but rather a case of creating new forests in place of natural grasslands. The logs of the early explorers continually describe a terrain where, in many places, there were few trees. Even the navigator, James Cook, in April 1770, describes the density of trees at Botany Bay as being so sparse that, “… the whole country, or at least great part of it, might be Cultivated without being obliged to cut down a single tree.”

A presumption that all tree planting is good for carbon sequestration, and that all new forests established on ground where natural grasslands once predominated is also good, will lead to adverse, unintended and perverse consequence. The perverse consequences are that, by planting these forests in previous grasslands, the planters will have increased the fire risk in an already fire prone continent. This will lift the danger of widespread catastrophic fire in Australia and this means that huge percentages of the carbon stored in those unnatural forests will be oxidized to carbon dioxide – the very result we are trying to avoid.

My suggestion is that any landholder who proposes a tree planting campaign should not automatically be regarded as engaging in Reforestation, but rather, forestation. Where a landholder wishes to establish a forest, there should be an onus of proof on that landholder that the proposed forest is not inconsistent with a natural grassland existing prior to European settlement. Where this proof cannot be established, and a new forest is developed in any case, the developer should face legal responsibility in torts for fire damage to adjacent landholders. The landholder should not be entitled to the benefit of the risk reversal buffer because the carbon loss in a fire in a newly created forest (in place of a natural grassland) is not a pure accident. The carbon loss in this situation has been contributed to by the action of the landholder creating a standing fuel load, above the ground, in a fire prone terrain. Acting in this way is an act of contributory negligence on the part of the landholder to any subsequent damage that may occur as a result of the fire that will, at some stage, inevitably occur.

Reduced methane emissions from livestock
Given the current widespread community belief that livestock are almost solely responsible for the production of methane in a landscape, and that methane production in the organic atmospheric carbon cycle is something unnatural or unusual, this sounds like a laudable idea. My problem with this, however, is that it is a classic case of a saving which may be made in one area only to be taken up in another area. This is the problem identified later in the Consultation Paper under the heading “Avoidance of Leakage” as part of the Integrity Standards. The production of methane in a landscape should be recognised as an inevitable consequence of plant growth because, when plants grow, they inevitably get eaten by something. Even hard wood trees are eventually eaten by insects and bacteria. Methane is one of the biological consequences of this and will occur whether there are farm animals in the landscape or not.

All of the carbon atoms in methane come from the atmosphere in the first place and, when the methane is belched by the farm animal, the methane returns to the atmosphere. In the atmosphere the methane is oxidised to carbon dioxide and water. The carbon atom in the methane molecule reverts to exactly the form that it was in before – an atom within a carbon dioxide molecule. Methane production in the plant and atmospheric carbon cycle is inevitable and, if you stop cattle producing it, then it will be produced by something else – an insect of a bacteria.

By way of example, kangaroos are often cited as producing little or no methane. But kangaroos avoid eating the cellulous rich parts of plants because they cannot digest them. Where kangaroos avoid eating the stems of plants, insects and others eat the cellulous rich stems and create methane in the process. If the biology of sheep and cattle is tampered with so they produce less methane, this methane will still be produced by something else in the landscape. Apparent methane reductions in livestock is a classic case of cost-shifting or, as it is referred to in the Consultation Paper – Leakage.

For various reasons related to the biology of the breakdown of cellulous, there is little or no value in attempting to reduce methane in ruminant animals. The CFI legislation should reflect this broad view of methane production in the landscape, not the narrow view that livestock methane is somehow unusual, excessive or in some way anthropogenic.

Where a landholder wants to claim recognition under this part of the coverage, the landholder should be required to prove that the methane supposedly ‘reduced’ is not ‘cost shifted’ to some other agency of production in the landscape.

Reduced fertiliser emissions
Yes.

Manure management
No comment.

Reduced emissions or increased sequestration in agricultural soils (soil carbon)
The CFI legislation should have a presumption in favour of this in preference to planting trees on agricultural land. This is because the carbon sequestered in agricultural land is sequestered in a much more fire proof condition than carbon sequestered above the ground in burnable form in trees. Not only is the carbon in the form of soil carbon less accessible by fire, its presence in the soil, including its ability to retain more water, actually helps to make the whole landscape less fire prone and more fire resilient.

A presumption in favour of soil carbon sequestration over forestation of agricultural lands also has the benefit of improving to food security of Australia and the world.

Savanna Fire management
No comment.

Burning of stubble/crop residue
No comment.

Reduced emissions from rice cultivation
I assume this is referring to reduced methane emissions. My comments are essentially the same as the ones I made above under the heading ‘Reduced methane emissions from livestock’.

Reduced emissions from landfill waste deposited before 1 July 2011
No Comment.

General comments
Carbon sequestered in animal biomass.
A proportion of the standing biomass of any animal is carbon. This actually represents a sequestration of carbon in the body of an animal in the same way that carbon stored in vegetation represents a storage of carbon. An entire herd or flock of animals is therefore a carbon sequester in the same way as a grove of trees or shrubs is a carbon sequester.

Even though a farmer may sell animals from the flock or herd, the farmer is usually likely to replace these. The consequence of this is that the carbon sequestered in a herd or flock remains relatively constant over time as animals are sold and as new ones arrive. The CFI should recognise the carbon in the standing biomass of the landholder’s flock or herd.

Wool
About 50% of the weight of a fleece shorn from a merino sheep is carbon. The source of that carbon is from carbon dioxide in the atmosphere. Where that wool is converted into long lasting products such as carpets, bedding or insulation, it is sequestered for a long time. The CFI should recognise the carbon a farmer sequesters in the wool exported from his/her property.

NCOS and part of CFI
The proposal to administer NCOS eligible domestic offsets under the Carbon Farming Initiative is good.

Sale of units
A large part of the design of the Carbon Farming Initiative Consultation Paper is taken up with the problem of how to deal with the situation where a landholder has been paid a lump sum for carbon credits and then something causes the carbon levels to fall.

I think that many of the problems about this issue can be solved by changing the way the carbon credits are sole. Many of the problems could be solved if, instead of getting an up-front lump sum payment, the landholder receives payment of an annuity style income flow rather than the lump sum. The buyer of the units should pay up front in full but a proportion of the sale price could be held back in a trust arrangement to be returned to the landholder increments of capital and interest over a period of years. This ‘annuity’ arrangement could be varied so that the landholder could receive some up front incentive – say 15% or 20% of the sale price, with the remainder to follow over a period of many years as the carbon levels are maintained. Under this proposal there is no need for the clawback arrangements specified in the Consultation Paper because, except for the reduced up-front payment, the landholder is only paid annually for the actual carbon that has been held in the soil for the interval of time between the ‘annuity’ payments.

If trust arrangements are to be set up like this, it would be necessary that the landholder have the facility to conduct a DIY Trust in the same way that can be done with the funds in a Superannuation Trust.
Regional Communities, Water and Biodiversity

Marginal land
The Consultation Paper states, “For economic reasons reforestation is more likely to occur on marginal land than on productive agricultural land …”. I think there is an error of logic here. If the land was marginal in the first place then it is likely that the amount of carbon to be sequestered in a new forest on this marginal land would only be marginal itself.

I believe that the CFI should recognise the role that soil carbon sequestration can play in lifting the resilience of the soil and lifting agricultural production from that soil. A better result in land productivity and a better result in the total amount of carbon sequestered, as well as a better result for food security and reduced fire risk, can be achieved if carbon grazing systems (the interaction between plants and animals) are used to restore the land. Using these systems, marginal land can be turned back again to productive land while, at the same time, addressing the issues of salinity management, shelter for animals and wind breaks against erosion.

The role that soil carbon can play in restoring a natural grassland terrain should be particularly recognised where the terrain can be shown to have been in a grassland condition when Europeans first arrived.
Integrity standards

No one could argue with the need to build consumer confidence. Several provisions of this section, however, produce a result that has nil effect on consumer confidence but an adverse effect on landholders sequestering carbon.

Additional
Note 1. The ‘No reduction if in the normal course of business’ clause. This clause could act in such a way as to stop farmers claiming carbon credits for sequestration in soil if the management practices they use become so widespread that they become regarded as ‘the normal course of business’. Surely the only test is whether or not there is more carbon in the soil at the end of the period than at the start and whether that carbon is held in the soil over time. Surely the aim should be that the management practices to sequester carbon SHOULD become widespread and regarded as a matter of “the normal course of business”.

The entitlement to earn carbon credits for soil carbon comes from the way the landholder manages the land. It is therefore a product of the farm in the same way as other farm commodities. The carbon credits are part of a trading market with buyers – principally from Europe at the moment – wanting to purchase the units. Why should the income from producing the commodity cease if the management techniques to produce these units becomes the normal course of business? Imagine that there was a new alpaca owner in a district who developed an income from the sale of alpaca fleece. If others joined in and it became the normal course of business for the district, would this somehow be a reason why the original alpaca owner should not gain an income from the alpacas anymore? Such a result would be contrary to all commercial standards.

The CFI should be worded so as to remove any possibility of access to the market being closed if the management techniques to sequester carbon become the norm.

Note 2. The normal course of business clause should not be allowed to operate so as to prevent the early movers with to soil carbon to be barred from claiming credits for carbon they have already sequestered or claim credits for new carbon they will sequester in the future. Many of the early starters have been the true pioneers of soil carbon management and their contribution has been invaluable because they have, without significant government or industry support, provided us with proof of concept that soil carbon sequestration is a valid option.

Note 3. With the normal course of business clause as it is currently proposed, there is actually an incentive for farmers to delay acting now to improve their land and sequester carbon. It may also be a possibility that there is an incentive for some farmers to run down their farms, and their carbon stocks, until the CFI is in place. Neither of these negative incentives acts toward the real aim of the CFI – to draw down carbon dioxide from the atmosphere and store it as carbon in the soil.

Note 4. The early movers in Australian soil carbon sequestration should not be penalised by the CFI at all. On the contrary, it would be best if the early adopters could be recognised with some sort of capital payment for the work they have already dome proving the concept.

Permanent
The labile (easily oxidised) fraction of the total soil carbon content of a soil should be recognised as permanently sequestered carbon if it is held at a high level through a period of years. It is true that individual atoms of carbon may be cycling in an out of this labile fraction on a seasonal and yearly basis but, if a landholder increases the labile soil organic matter, and holds it there, the landholder should be entitled to carbon credits for this work.

This is no different at all to the way the carbon sequestered in trees is treated. Because it is in a burnable form, and because the Australian landscape burns regularly, and because additional forestation of the landscape is likely to make the terrain more fire prone, carbon stored in trees can only be regarded as labile carbon. It is definitely not sequestered permanently. And yet, the labile carbon sequestered in trees is a well established as a recognised form of carbon storage. Labile carbon stocks held in the soil profile should be treated in the same way – and should definitely earn carbon credits.

Avoidance of leakageA
greed. No further comment.

Measurable and verifiable
I agree wholeheartedly. In fact the requirement for the carbon stocks to be able to be measured is, I believe, the absolute basis of the integrity of the scheme. Everything depends on it. A large part of the Consultation Paper is related to methodologies and the development of methodologies. It is implied that much of the development of these methodologies will be about how the carbon is to be drawn down and put in the soil. I think that the primary development of methodologies must be how to measure, audit, monitor soil carbon levels with quick, cheap, reliable and scientifically accurate methods.

Conservative
No comment.

Internationally consistent
I agree. However there is an important point to be made here. That is that the whole reason why Australia has to have its own CFI legislation and procedures, is that the provisions of the Kyoto agreements are so poor in their practical understanding of soil carbon sequestration. In addition to all that has to happen to make the CFI work as a practical carbon drawdown solution, the Australian Government must go back to the whole Kyoto process and start renegotiating the clauses that relate to soil carbon.

Supported by peer-reviewed science
Note 1. I believe there is a missing word in the second line of the first paragraph under the heading ‘Supported by etc”. The missing word is “not”. The second line should read, “… reviewed, or if not based on peer-reviewed science etc”.
Note 2. This clause should not be allowed to stifle innovation or prevent a landholder from earning carbon credits if he/she builds soil carbon by a way which is not proven on a peer-review basis but can be proven by direct scientific measurement of carbon levels in the soil.
Note 3. Because of the extensive recent criticism of the peer-review process by credible scientists, the peer-review process should not automatically be taken as being infallible. A scientific fact is true before it is “discovered” and proven to be true by science. The world was round (Spherical) before Magellan sailed round it and proved it was round (spherical). I hazard a guess that the fact that the world is round (spherical) has never yet been validated by a peer-reviewed process and published in a scientific journal. The ultimate validation to whether or not there is a certain level of carbon in a soil profile should be scientifically sound measurement. Measurement of an observed fact is the key.

Additionality
Note 1. See comments about permanence under the “Additional” paragraph heading of the Integrity Standards section.
Note 2. The third paragraph of this section contains an assumption that, if the farmer generates additional profit from sequestering carbon and improving the productivity of the land, the farmer will no longer be eligible to earn carbon credits. This is contained in the words, “ … and clearly do not result in material increases in agricultural productivity or business profitability …” . This clause could have an appalling effect. OF COURSE we want the added productivity benefits from the extra soil carbon in the ground! We want this as a collateral benefit to the income derived from the sale of the CFI carbon credits. We want this to make our farming landscapes more resilient to climate variation and to enhance the food security of the world.

If the payment to farmers for carbon credits was actually a government subsidy, there might be some logic in this clause. However, the payment to the landholders is not a subsidy, it is a normal sale of a commodity as part of a normal market where there are buyers and sellers. Organising one’s business in such a way to achieve synergy between two different streams of the business is an entirely normal commercial practice and definitely to be encouraged in this case.

The CFI must be framed so that landholders are not penalised through becoming more agriculturally productive.

Note 3. The final paragraph of this section refers to activities mandated by governments disqualifying landholders from earning carbon credits. Again, if the payment to landholders was a government subsidy, this clause may have some reasonable basis. The payment is not a subsidy, it is a commercial payment by a buyer who wants to buy the commodity. The freedom of the buyer and the seller in this market should not therefore be restricted just because a government mandates that certain land management methods become compulsory.

Note 4. This clause is also open to abuse by a future government which mandates something that landholders have already started to do. This would arbitrarily cut the landholders out of the market. The legislation should be framed so as to exclude this clause.

Note 5. The key factor in establishing additionality is scientifically reliable measurement.

Permanence
Note 1. In paragraph 2 a) in this section – scheme participants withdrawing. I believe this section should be modified to allow for a time factor to be taken into account. Let’s assume that a participant has an obligation to sequester carbon for 100 years. And let’s assume that the participant raises the carbon levels but withdraws after one year. In this case it would be reasonable that the participant should repay the entire amount of the carbon credit.

However, if the participant raises carbon levels and holds them there for 20 years and then decides to withdraw, then the repayment option should be discounted by the fact that the participant has held the extra carbon in place for twenty years. A landholder who withdraws after 30 years would simply forego the remaining 70% of value.

Note 2. Many of the problems of this section about permanence could be resolved if the payments were in the form of a small up-front lump sum and a subsequent annuity style annual payment – returning both a portion of capital and interest – for the entire period of the obligation. In this situation, a participant who withdraws after 30 years, having received 30 years worth of capital and interest, would have no repayment obligation or carbon maintenance obligation at all.
Leakage

Comments – particularly with regard to leakage in methane accounting – made earlier in the submission.
Scheme processes

General comments about scheme process
The scheme processes outlined in the Discussion Paper represent the building of a bureaucratic nightmare where no bureaucratic nightmare needs to exist.

The fundamental problem in the diagrams and procedures outlined under ‘Scheme Processes’ is that it is a case of micro-management where there is no need for a government bureaucracy to become involved with micro-management at all. The only thing the government needs to become involved with is the validity of the measurement mechanisms. The government does not need to become involved with the approval of projects or the approval of the farming method a farmer or other landholder uses to lift the carbon level in soils.

If the farmer or other landholder can prove that the benchmark level of carbon was ‘X’ at the start of a period, and prove that it is ‘X + Y’ at the end of a period, then the land holder should be entitled to earn the carbon credits. The actual method by which the farmer or landholder does this is not relevant to the question of whether there are, or whether there are not, extra tonnes of carbon stored in the soil under question. There is a requirement, of course, that the farmer should comply with various other pieces of state and federal legislation that determine how he/she farms the land – such as environmental rules about erosion control and the like – but the method of sequestering the carbon is a matter for the farmer or other landholder to work out.

The penalty to the landholder of not successfully at sequestering the carbon, as planned, is that the landholder fails to earn carbon credits. This is a commercial incentive more likely to focus the landholder’s attention on results than a system which focuses the landholder’s attention on the process.

We should bear in mind that the Chicago Climate Exchange failed because it focussed the attention of landholders on process rather than on measurable results. If the CFI micro-manages the process – rather than focussing on the robust and scientifically sound method of measuring, auditing and verifying the landholder’s claims – then we will probably only see a re-run of the failed Chicago Climate Exchange.

This brings me back to what should be the Holy Grail of the whole system – the need for sound scientific measurement – before and after – to be the basis of the payment for carbon credits. To those who say that the cost of scientific measurement of each and every soil carbon claim is hugely expensive, I would say that it would be nothing compared with the expense of setting up and maintaining a huge government bureaucracy to oversee the micro-management of all the processes. The other problem with a new bureaucracy is that it would be an expense against the public purse. A commercially based system of scientific measurement and auditing would be an expense against the person wishing to earn carbon credits.

The legislation should, so far as possible, refrain from setting up new bureaucracies and new overly-bureaucratic processes. In so far as possible, the legislation should encourage existing commercial enterprises to do the scientific measuring, to carry out an independent auditing process, to run Trustee services, to insure against loss of carbon credits by fire, etc, and to otherwise provide services to the CFI.

Becoming a recognised entity
No specific comment.

Project approval
No specific comment.

Register of offset projects
No specific comment.

Crediting periods
No specific comment.

Reporting
No specific comment.

Crediting
No specific comment.

Transfer or termination of projects
No specific comment.

Methodology approval
See my general comments, above, in the section headed ‘Scheme Processes’.

Specifically with regard to methodology approval, there should be a stringent set of approved methodologies for measuring soil carbon with a high degree of accuracy. There should be no separate methodology approval process covering the way that land is farmed or managed to achieve the aim of increased soil carbon levels.

The legal series of events for a claimant to claim payment for carbon credits should be clearly specified and require independent, third party, measurement and verification at all stages. The final sign off of this legal process may be a valid role for a small bureaucracy to perform.

To state it again; a methodology that focuses on MEASUREMENT focuses on RESULTS, a methodology that focuses on PROCESS only focuses on PROCESS.
Taxation treatment of credits

No comment. However, if an annuity style arrangement is entered by the landholder, the tax treatment of the investments should be similar to the tax treatment of other trusts such as life insurance trusts, mutual funds, or superannuation trusts. The income should not be taxable at the time of being credited.

Any additional comments
Solar energy basis of farming
The legislation must include a clear statement recognising that the use of solar energy is the basis of all farming and grazing. It is the basis of the conversion of atmospheric carbon dioxide into carbo hydrates which is the fundamental process in food production. It is also the fundamental process whereby nutrients are incorporated into our food. While fossil fuel energy may be used in parts of the farming and grazing process, it is not the fundamental energy source of farming. Plants and animals are solar powered devices which interact naturally and organically with each other in the solar powered carbon and water cycles. Once this point is clearly recognised in drafting the legislation, and in the legislation’s final format, then many of the other issues involving carbon, soil carbon sequestration and farming become simpler and clearer.

Replace an ‘emissions’ mentality with a with a ‘closed cycle’ mentality
At a number of places in the Consultation Paper the word ‘emissions’ is used to describe the gases produced by farm animals as part of the atmospheric cycle. I believe that to use the word ‘emissions’ in this way creates the danger of a subtle misunderstanding about the relationship between farm livestock and gases in the atmosphere. If the word ‘emissions’ is used to describe the organic gases coming from the digestive process of animals it makes it sound like the gases have been produced in a factory, a power station or a motor vehicle.

Where the fuel source for an industrial process is fossil fuel, then the emissions of global warming gases from factories, power stations and motor vehicles are truly emissions of new global warming gases to the atmosphere.

On the other hand, all of the carbon atoms in the organic gases coming from the digestive process of animals came from the atmosphere in the first place and their passage through the farm animal is not new carbon to the atmosphere. The farm animal only represents a point in a complete cycle. It is a part of a natural and organic, solar powered, atmospheric carbon cycle. It should not be confused with the carbon atoms coming from factories, power stations and motor vehicles.

The use of the word ‘emissions’ when applied to animals in this case can cause a subtle shift of meaning away from the fact that the animal processes are different from fossil fuelled industrial processes.

The principle must be established clearly in the legislation, and maintained at all times, that livestock are part of a closed loop atmospheric carbon cycle that generates no net addition of carbon to the atmosphere.

Carbon grazing and marginal land
There is an assumption in the Consultation Paper that marginal land may not be suitable for soil carbon sequestration using the relationship between plants and animals. This is a poor assumption. It lacks a recognition of the fact that, even on land which may initially be classified as ‘marginal’, carbon farming techniques can be used to dramatically restore the degraded land to productive agricultural land.

The legislation must recognise that carbon grazing is an effective way of restoring marginal land to production.

A further assumption in the Consultation Paper is that the best way to store carbon in marginal land may be to lock the land up and only use it for forestry. This is also a poor assumption because it takes no account of the decades-long research, observation and practical experimentation in this area (the work of Allan Savory) that shows that when land is locked up and left to manage itself, it often degrades in its ecological status when compared with land which is actively managed using carbon grazing methods. This may be counter-intuitoive but it can be shown to be the case.

The legislation must recognise that simply locking up marginal land, and leaving it to manage itself in the hope that a few trees will grow, is a poor assumption. It may be true in some cases but it is definitely not a general assumption that can be made.

Recognition of labile soil carbon fraction
The soil organic matter – or labile soil carbon fraction – of carbon content in soils should be recognised for the purposes of earning CFI carbon credits. While it is true that this fraction can vary somewhat with seasonal conditions such as drought, it is also true that a well managed carbon grazing program which builds up soil carbon, can cause the labile carbon fraction to remain high even where drought and other seasonal conditions might otherwise result in the oxidation of a large part of the labile fraction.

The soil organic matter can be held high even though individual atoms of carbon may be cycling in, and cycling out of, the sink of carbon in the soil. Good land management can therefore mean that the total tonnage of carbon in the soil can remain high even when it is in a labile form and even when there may be external factors – such as drought – which would normally mean that the labile fraction should plunge.

The challenge for the farmer is to maintain the soil organic matter at a high level regardless of the seasonal conditions. This is an achievable managerial aim and is being successfully carried out at the moment on Australian farms.

The recognition of soil organic matter – or labile fraction – in this way is no different from the general recognition elsewhere in the Consultation Paper that carbon stored in trees should be eligible to earn CFI carbon credits. While the wood stored in trees may look permanent enough it is actually highly labile in the Australian context because it is susceptible to regular wild fire.

Source of methane
The source of methane must be recognised clearly as the breakdown of plant cellulous and not as some bizarre and unique process that only happened in the digestive tract of ruminant farm animals. The production of methane in the landscape is a natural organic process that is an inevitable result of plant growth.

The energy source for the production of methane is ultimately the sun and it is a completely normal and natural part of the atmospheric carbon cycle.

The issue of methane is an area where widespread poor analysis of its ultimate sources leads to wrong conclusions about the role ruminant farm animals play in the production of global warming gases.

If the legislation recognises that methane is an inevitable consequence of plant growth, it will help dispel some of the faintly hysterical witch-hunting that has taken place in recent decades over the issue of ruminant animals and methane. If the muddled thinking about methane and livestock can be overturned then it will help create a clearer understanding that farm animals are not part of the problem of the build up of global warming gases, but part of the soil carbon solution.

Peer review process in context
The validity of the peer review process has come under severe – and in many cases, warranted – attack lately. The use of the peer reviewed process must not be allowed to become the method of stifling or inhibiting effective soil carbon sequestration action. Where scientifically valid methods of directly measuring soil carbon can be used to validate the carbon levels at the start of a period of time and at the end of a period of time, then these should be used whether or not a peer reviewed scientific paper can be cited to understand the reasons for the build up in soil carbon.

Some of the existing assumptions underlying various so-called scientific facts about carbon gases need to be re-examined in a peer review process or simply overturned. The most startling of these is the assumption that methane is 23 times more potent as a global warming gas than carbon dioxide. This does not actually come from a rigorous peer reviewed process. As this current ’23 times’ metric is based on a weight-for-weight analysis of CH4 and CO2, it is not truly an apples-with-apples comparison. The more accurate and scientifically sound comparison basis is a molecule-for-molecule analysis where the same number of molecules of each gas are compared with each other in regard to their global warming potential.

In addition to this, other statistics, such as contained in the UNFAO 2006 document ‘Livestock’s Long Shadow’ have been shown to be terribly inaccurate and the result of a deficient understanding of the atmospheric carbon cycle. For example, the document contains statistics about energy use to raise cattle which assume that they will be kept inside in the heated farm barn for months of the year, as they are in Europe. As Australian cattle and sheep husbandry systems do not involve keeping the animals in heated sheds, the conclusions from the UNFAO report have little or no validity in the Australian context.

At all times when peer reviewed papers are used as the basis of some scientific decision about soil carbon in Australia, we must make sure that the peer reviewed paper is actually relevant to, and applicable to, the situation in Australia.

The legislation must allow for a review process to take place, and changes be made to the legislation in future, as some of the poor assumptions of the IPCC, the CSIRO and the UNFAO are recognised and overturned.

Payment of CFI carbon credits
Alternative methods – such as annuity style financial products – need to be developed as an alternative to simple up-front payments of the whole of the carbon credits to the farmer. Such alternative methods will require legal instruments such as specialised Trusts.

Replace the term ‘Climate Change’
The term ‘Climate Change’ is a vague and meaningless term. It is a soft term that can either mean global warming of global cooling. Used by itself without further explanation, it means nothing at all. Worse still, the use of this term by people who apparently believe the global warming models, is actually an act of deep global warming scepticism. People who use the term Climate Change are having an each-way bet on the outcome. If the people framing the legislation genuinely believe that a process involving global warming the is underlying driver for what they term ‘Climate Change’, they should use the term ‘Global Warming’ and cease using the term ‘Climate Change’.

In order to demonstrate the highest level of credibility and integrity, the CFI Legislation should avoid the use of the meaningless spin in the term ‘Climate Change’. Where the document is referring to a climate process which is ultimately driven by a process of global warming, it should use the term ‘Global Warming’.

Renegotiate Kyoto clauses
The Carbon Farming Initiative is a welcome initiative of the Australian government. It is a method of breaking the adverse effect of the poor scientific analysis contained in the Kyoto agreements. The Kyoto agreements spectacularly fail to recognise the natural role of farm animals in a closed atmospheric carbon cycle. The Kyoto agreements also spectacularly fail to recognise the role of soil carbon sequestration as a mitigator of atmospheric carbon dioxide. They fail to recognise the profound role that plants and animals, correctly managed, can play in lifting soil carbon levels.

It is because of these very dramatic shortcomings and errors of the Kyoto agreements that this piece of domestic legislation (The Carbon Farming Initiative) is required. There exists, however, a danger that an international court, or some other international legal process, may one day require Australia to overturn the CFI Legislation because it determines that the CFI Legislation is actually a contravention of Kyoto Treaty. If this was to happen, it would be a complete disaster for the whole process of creating and passing the CFI Legislation.

The Australian government must not allow the weaknesses of the Kyoto agreements to just go on and on into the future unaddressed on the international scale. It would be an open sore. Concurrently with The CFI Legislation, the Australian government must be prepared to go back to the international arena and renegotiate the very bad clauses of the Kyoto agreements which have led to the need for the CFI in the first place.

Journalist.com.au

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