Proposed Improved Avoided Clearing Method

Pahia Cooper   6:36
Good morning, everyone. We'll get started. Just give me a thumbs up if you can see the slides and hear me please, great. My name's Pahia Cooper. I'm part of the Natural Capital programme here at DETSI. Today, we're going to be talking about our new avoided re clearing and native reforestation method.
Before we get started, I would like to say acknowledgement of the traditional owners of the land of which we're hosting this event today, MEANJIN in Brisbane, home to the Turrbul and Jagera people. I pay my respects to their elders, past, present and emerging, and extend my respect to all Aboriginal and Torres State Islander people participating in the webinar today.

Pahia Cooper   7:18
We'll get started. We've got three main things coming up on the agenda. Firstly, you'll hear from Brett Kerr from Detsi on the key changes and developments for the method. Then from our colleagues at ANU on the technical processes.

Pahia Cooper   7:32
And then we'll have questions to finish. So the session is being recorded and it will be posted on detsi's web page. Please put questions into the chat as we go along, we will try to answer all, but anything we don't will be summarised and posted on the DETSI web page.

Pahia Cooper   7:50
Hopefully by the end of this week, do contact with us directly for any questions that we don't answer or you'd like to ask us. I will now pass over to Brett Kerr. Thank you.

Brett Kerr   8:03
Thanks Pahia. Now if you can hear me, I've just had a Yep, excellent quick fix. That technical problem. Welcome, everyone. Thanks for joining us today. We've got a fair bit to get through today, so.
It might be a bit rushed, but we will miss Peter mentioned take on questions and summarise those and answer them and put them up on the web page after the session.
Thanks. So just in terms of the period where we're doing this initial engagement, we had the draught method and supporting documents up from the 28th of November, but we'll be looking for feedback by the 6th of February next year to allow us to make final changes to the method.
Didn't prepare documents to submit to Iraq in March, so that's the the period where involved in there'll be some additional targeted stakeholder meetings and First Nations engagement during that period as well as this information session.
Thanks Pahia. I just wanted to start off with some of the key topics that were canvassed with us during our initial round of engagement earlier in the year and then going to talking about some of the main developments of the method and changes that were made from the proposed.
So initially made through our EOI.
So one of the topics we did hear from stakeholders about was around native timber harvest opportunities in the method. We haven't made any changes to the method scope in response to that.
We do recognise that that those activities could constitute a method, but it was beyond the scope of the EOI we put to Iraq.
We had canvas, three of the first engagement around the sort of multi activity or integrated option of bringing reforestation in alongside avoided clearing to bring.
All stages of of regrowth into scope of the method we are progressing with that more integrated option and hence we've also had a change in from the name of the yeah, why through to what we're proposing for the method now.
We had.
Different views on the eligibility window for avoided clearing, so we the initial proposal was for 25 year window. So you need to have demonstrated comprehensive clearing within the past 25 years. We've heard calls for that to be longer and shorter, but we've maintained that 25 year period as what we think is the.
The best balance forest and forest cover definitions there was some confusion there about changes to standard and accepted definitions, so I would clarify that there are in fact no changes to those except accepted definitions in the method.
We heard a fair bit about property management plans and the usefulness of those there is. We'll go into a bit more detail about those further down, but there is there are provisions for property management plans and one of the key elements.
Way that carbon projects may have been managed in the past around by security and the impacts on neighbours and other things. So we've been a little bit more prescriptive in the property management plan about that aspect.
The current press crediting option that we propose for 100 year projects as as an incentive for the longer permanence periods was pretty broadly had negative feedback. So on a number of fronts, one was the integrity of of upfront crediting.
Another point of view was it's it's probably not really a strong enough incentive to change anyone's decision on whether they like for a 25 or 100 year permanence period project and the other one was around the gap between crediting, ending and permanence periods. And that's a risk to.
To the projects and makes uptake of these projects difficult, excuse me for landholders, our response to that then has been to drop that compressed crediting option and instead propose A50 year crediting period.
For 100 year permanence projects and for avoided clearing projects that include avoided clearing, you would need to demonstrate at the 25 year mark that you had a continued unrestricted right to clear.
At that point in time, we understand this is a fairly new approach. The the ACT allows for the sort of, despite crediting periods to be applied to methods, and this will be one where I think one you know.
There's a potential to take away from the eracs rights to extend crediting periods, so something for us to progress through, and we'll be interested to hear people's views on that, whether that 25 year check for the continued unrestricted right to clear.
Is a fair approach to that.
50 year permanence. So EOI had the minimum 50 year permits periods for all activities. For us, the considerations here around additionality, for avoided clearing methods versus the uptake of the method.
What we have done is allow a 25 year permanence period for reforestation. Only projects that maintain the 50 year minimum permanence period for projects that have involved avoided clearing.
To ensure that there's some clear additionality where we're allowing up to 25 year clearing cycles and in the method.
We had some feedback around assessment scale, so the AI initially proposed either 10 by 10 or 25 by 25 metre scales for evidencing historical clearing and stratifying projects.
What we have done, taking into account feedback we received there is adopt A 30 by 30 metre scale to evidence historical clearing and a 10 by 10 metre scale for stratifying projects. So this just reflects the native resolution of imagery that's publicly available.
Historically, so looking back to where people might be looking to evidence historical clearing at the turn of the century and for current imagery for project stratification.
Stay here.
Slope. So we had a proposal in the EOI to restrict eligibility to land that had a greater than 10% slope. We received pretty broad feedback that that wasn't.
Necessarily useful risk criteria given regional variability and different Grazing regimes. So I guess in different landscapes that that's like didn't make sense everywhere.
So we've removed it. We had asked also for suggestions on other sort of risk mitigation criteria that could be introduced, but we didn't receive any, we do.
Still maintain some confidence in the other eligibility criteria that will strongly sort of address additionality around the evidence of previous comprehensive clearing and the unrestricted right to clear into the future, so we'll just rely on those.
At this stage, Subforestry clearing is a is a new concept that we've introduced into the the draught and this is to capture that regrowth that sits between the 10 and 20% canopy cover level.
Where we're close to forest cover and further away from land that's been cleared and they maintained as cleared land. So the key element here is that we treat this in terms of eligibility as though it was a.
Clearing avoided re clearing CEA where you'll need to demonstrate that unrestricted right to re clear into the future. Given potentially how close these areas are to forest cover already.
Ecological thinning. This is a practise that's been allowed in many previous and existing methods. We've sought to clarify this as to put some sort of boundaries around this to ensure that it's.
Or to make compliance, I guess easier for the regulator and also to just ensure that it's fit for purpose in terms of providing that ecological outcome as well so.
In that respectively it's, it will be allowed once only during the project. The Crown cover must be greater than 30% at the time you do ecological thinning and the Crown cover's not to be reduced below 30% during that thinning process.
And also the crammed cover is not to be reduced below 75% of what you'd expect in the reference ecosystem for that area. And then that clearing event would be modelled into full Cam.
During the process.
The other thing that we've elected to adopt in the draught is a standardised crediting model for avoided re clearing. Tom Butler will talk to this in a little bit more detail during his section of of the information session.
As well, but essentially we're looking to credit avoided clearing projects in a standard way, irrespective of the time between the most recent clearing event and the start of the project. And we use the gateway cheques.
In the method which I'll talk about later, to just ensure the project's tracking along as expected, and this serves several benefits. One is to provide some investment confidence to landholders where you have a.
More clear understanding of the credits that you're going to get through a project if it's managed well enough to meet the gateway requirements, it's simplifies administration. You don't have to worry too much about trying to time the start of your project in relation to the most recent.
Clearing event and it also spreads the delivery of carbon credits out in the more evened way through the life of the project as opposed to the previous avoided clearing method where.
For land, it hadn't been cleared for some time. You'd get a lot of acky's upfront and less through the life of the project. So again, taking into account some of the feedback we heard around the incentives and the way that they play out through the life of a project to allow.
Our landholders to better manage the project.
None.
Some other issues raised. It's really specific to our methodology itself. One was really integrated farmland Management method and the intersection with that. So that's something that we continue to work with. The Jiki method development team on.
Keeping them up to date on how our methods progressing, we see that, well, there's potentially some overlap here as it was with N FM RNHIR methods that it's not.
That great issue that can't be managed through some good communications, and that was some of the recommendations that came from our stakeholders that the differences would need to be explained, but also the integrated farmland punishment method will have a much different scope as it develops over time.
We did had some concerns raising our initial engagement period around scheme rules, specifically Rule 20 a a talking about excluded projects and whether.
Re clearing within seven years prior to the project would rule a project out and for avoided clearing, the regulator provided us some clarity that that rule doesn't apply to avoided clearing. So for this method.
If you've cleared within the, I guess 7 to 25 year period and cleared again within seven years, that will make no difference to your eligibility.
So it was good to get that clarity.
The other issue raised is around stewardship support. Obviously not something we progress through the method, but just a general.
Feedback from a lot of our stakeholders that sort of support and to land holders and farmers is really a key element of the success of the scheme. So we certainly take that on board.
So Don Butler will talk a little bit in a little bit more detail around eligibility when he goes into the technical details and how how these will be applied in assessing your project and developing a project. But these are the essential eligibility requirements for the various CEA types.
In the method. So for avoided re clearing a forest this this activity is about the retention of secondary forests and subforests where they have experienced comprehensive clearing by mechanical chemical means.
And the action that the the provider takes there is to commit to ceasing re clearing during the permanence period. You must have a a recent clearing event within the last 25 years, and you must have an unrestricted right to.
Re clear and the land must be managed to maintain forests and loud forests to mature. So I think so relatively straightforward for the reforestation ceas. This is about the establishment maintenance of native forests on land that's been cleared for Agriculture.
And has remained clear can be done through plantings or natural regeneration, or a mix of both, so we can have mixed ceas plantings. Only natural regeneration only, or mixed ceas, and Don will talk a little bit about how.
We propose to deal with those scenarios in full Cam. The land must have noted for us potential and clearing cannot have occurred within seven years of project application. Just to ensure that we're not incentivizing.
Clearing through the method.
These maps give a a general indication, and it is indicative only of where we think avoided clearing projects may occur. So the map on the left is Queensland category X areas. The map on the right, the blue areas in there show NSW category one exempt land.
And it's.
That's a very broad, broad areas where we think these projects may be eligible depending on this specific site characteristics. Obviously in clearing histories for reforestation activities.
Similar to the nature repair markets and it's native vegetation method proposal and the replanting, native forests and woodland ecosystems methods, we've defined some eligible sub regions around the country where there has been.
A history of clearing for agricultural purposes. This is just one of the sort of measures that we deal with the the counterfactual around these projects that they without the project would be likely to remain clear because of the land use.
That they're under and the map on the left just shows where we think that we're predominantly cleared. Land exists within those eligible sub regions. So it gives an indication of where we think projects may be possible for reforestation.
In terms of First Nations, cultural activities made a lot of questions and the initial around the consultation around cultural burning cultural activities so burning will be accommodated within the methods, including for cultural reasons and that's.
Activities will just need to be modelled in to full Cam and for region ceas we don't. And Donald goes into this in a bit more detail, but for avoid declaring ceas we won't be modelling disturbances.
In the standardised crediting crisis, biomass removals for cultural and native title reasons also accommodated in in the method, including Bush Tucker. So removal of seeds, etcetera.
As occurs in other methods.
We have some newness and lieu provisions as well that are very similar to the environmental planning's 2024 method newness and lieu provisions that just allow for some activities to commence after an application has been made to the regulator for a project.
Project plan. I won't read all of these elements, but the the the main elements there would be what you'd expect out of a project plan dealing with some of the project information I've mentioned already. The specific provisions in there around bio security, risk Management and.
Which will include demonstrating an alignment with Commonwealth and state laws, but also regional and local bio security plans that exist in various formats under various regimes around the country.
For Regency, as obviously some species details as well, we're also have provisions in here that the project plan be published and this is a response to feedback we received.
From really a community perspective, I suppose about.
A lack of understanding of how Land's being managed on the carbon projects, which leads to distrust in the Community or others, I guess perverse outcomes for the scheme, so we'll require these project plans to.
Be adhered to under the method, but also to to be published so that people can understand the sorts of activities that are undertaken, including virus security Management.
So Gateway requirements we're building into the method and they they are really a key part of how we deal with risks under the method as well. There are various types of gateway requirements depending on the ceas involved, so for avoided.
Forestry clearing ceas it's really about forest maintenance. So these gateway cheques at years 5 and 10 in every 10 years thereafter in the permanence period, are really about just maintaining that forest cover so.
More than 5% loss in Crown cover from the initial Crown cover estimates at the commencement of the project for reforestation ceas there's their forest development gateways where we're looking for 5% increase in Crown cover.
At years 4:00 and 8:00, so by year eight, you should have a 10% increase in Crown cover forest attainment. So have 20% crown cover at two metres at year 12, and then forest maintenance.
Gateway is similar to the avoided very clearing ones where that years 22 and every 10 years thereafter you need to demonstrate that you're maintaining that forest cover.
For avoided some forestry clearing, there's forest development check at Year 5, forest attainment check at year 10 and then forest maintenance cheques at year 15 every 10 years thereafter.
If failure to meet Gateway requirements will lead to some options to to re stratify as a new CEA or an exclusion area, they need to modify your project plan to include corrective actions for reforestation, CEA's carbon stock.
Modelling will be paused until the gateway requirements are met, and if there's a long term failure to rectify and meet the gateways, the land is then deemed to have never been eligible.
Editing.
As I mentioned already crediting periods, so for 25 year permits projects the crediting period will be 25 years for 100 year reforestation projects. Crediting period is proposed to be 50 years.
And for 100 year avoided clearing projects, we're proposing that 50 year crediting period subject to demonstrating that continuing unrestricted right to clear at the 25 year point of the project.
No, no. Once again, Don will go into this in a bit more detail, but we do have provisions in the method for direct measurement to in those scenarios where people feel that full Cam is substantially underestimating.
The abatement in the project area since this this will be for void re clearing ceas only where there's actually gonna be some relevant growth data available on the site.
It requires an initial survey prior to the first offsets report. Then two subsequent surveys thereafter. The method contains the details and so say done. We'll go through this and how those surveys should be undertaken.
And the maximum increase of the in layer in full Cam that can occur as a result of this direct measurement would be 25%.
So I'll hand over to Don now to talk through eligibility and stratification biomass survey elements, the standard crediting for avoided clearing and also the way that we'll deal with mixed planting and regeneration, ceas and full.
OK. Thanks Tom.

Don Butler   33:05
Thanks for all that in town. 15 minutes it would be fairly much. I'd see there are some questions in the chat. I don't know if you want to deal with them first at all. We'll just move on.

Brett Kerr   33:18
Yeah, we'll move on. We'll deal. We'll try and deal with as many questions as we can at the end and after your your presentation here and then anything we don't get to, we'll commit to addressing and posting it on the web page after.

Brett Kerr   33:34
This session.

Don Butler   33:35
Sure.
Screen.
So I'm, as Brett said, going to talk through some specific issues around eligibility and stratification primarily and then talk a bit about the gateways and how they interact with these stratification concepts.
And abatement calculations, as Brett's pointed out, there are three broad types of activity areas, reforestation, avoided, forest, re clearing and avoided subforest re clearing.
And within the reforestation category, there are three subtypes, which range from a pure planting CEA, much like an environmental planting, a natural regeneration, CEA, where there's sufficient regeneration there to go ahead without any.
Auxiliary planting and then the idea about a mixed CEO for each of those types, we're expecting proponents would map their CE as commencement no CE, as must aggregate to .2 hectares.
The concepts for eligibility and gateway assessment hinge very much on the stratification requirements around the 10 by 10 metre grid scale, which is also each cell within that 10 by 10 metre grid will be aggregated into.
Fixed .2 hectare larger structures aggregates for assessment of forest potential forest cover and and other requirements for the gateways. Now that's.
Pretty tricky to wrap your head around if, especially if you're reading the draught method. I direct anyone who has struggled there to have a look at the workflow document and that's where I'll spend a fair bit of the short time I've got here today.
The other thing to note at the start here really is around this idea that comprehensive clearing can be deemed based on the type of native vegetation for that land. It typically being forest.
And the lack of the lack of natural disturbance events that might have rendered at non forest in the absence of Agriculture clearing.
So to jump right in, we'll start with the concept for stratification of reforestation ceas because there's in some ways the simplest. And as Brett's mentioned, there are some basic eligibility requirements, including that you need to be in Australia in a place where full Cam works.
Has to have had comprehensive clearing for Agriculture, noting that that can be deemed based on reference ecosystem and then each piece of land needs to form part of a 10 by 10 metre cell which is illustrated in these pictures at the bottom here which I've taken from the workflow document.
Where crown cover from native trees is less than 10% at the eligibility date, so this is effectively limiting reforestation ceas to those areas where there's very little tree cover and commencement. And we also have the provision for.
A lack of clearing within seven years and a need to assess forest potential, which is a fairly familiar concept for people that have been working in this space, except that forest potential here needs to be considered.
For each 10 by 10 as well as these concepts of aggregates that add up to at least .2 hectares and sort of the cells within the CEA, either with each other or with surrounding cells, so that we can align.
These ten by ten kind of concepts, with the scale for native forests, which is .2 hectares. So that's illustrated here in the picture, where the blue boundary would be the CEA boundary with exclusions.
Delineated in red on the left image and then the cells that are included within that CA are then aggregated into these .2 hectare aggregates, dealing out in different colours.
To give you the broad idea, you'll note that many of these have cells that are outside the CDA included. Doing that would basically be sensible for a proponent who had confidence in the.
The forest cover in those external cells being retained because that will be an important part of the assessment of gateways and the the presence of forest cover as the project goes forward.
For the cells inside the CEA, you can also see that the aggregates are able to overlap and the kind of fundamental requirement is that each aggregate contains at least five cells that are unique to it from within each CEA.
Which we think is a kind of flexible balance to enable people to identify .2 hectare areas that can be used for forest assessment but limits the scope to which they can all overlap.
Now importantly.
But cells that are outside of the proposed CEA can only be included within an aggregation if they're contiguous with A10 by 10 metre cell inside the CEA. So they can't run for miles. You can share.
Either inside or outside cells as I've mentioned, and that fourth point there is the key one where there must be at least five unique 10 by 10s for each aggregate within the CEO.
These aggregations and the cells. The idea is that they are fixed so that you can't sort of recast the structure every time you're doing an assessment to the scope for gaming.
When we get to talk about gateways, the the gateways are assessed for each 10 by 10 as well As for the point to hectare aggregation. But the point to hectare aggregation is considered in a couple of ways again.
Primarily to limit gaming, so there's the whole aggregation which is illustrated here for this turquoise outlined aggregate with the red hashing. So that shows all of the cells that are included in aggregate A5. That's one.
Unit that needs to be assessed. You also need to consider all of the cells within the CEA for each aggregate as well as those that are not shared with another aggregate from within the CEA.

Don Butler   41:12
So with that concept in mind, our 10 by 10s as well as a .2 hectare aggregates the idea for reforestation. Ceas is that there are, as I said before, 3 subtypes, plantings, natural regeneration and mixture.
The cut off between them is determined basically on how many plants you intend to add, noting that for any planting or mixture you need to be planting in each 10 by 10.
If you can't do that, you should consider excluding cell or including it in a different type of CEA so the the minimum density of plantings for a planting only CEA is 400 and that needs to be assessed.
Across hectares. And as I said, there needs to be a planting undertaking the next 10 by 10 and that for regeneration can't have more than 100 plantings planted stems per hectare added to it.
And then it would be modelled as natural regeneration and the mixture is for those areas that fall within those two thresholds of more than 100 planted trees and less than 300 and less than 400 planted trees per hectare.
And for all of those reforestation types, we're talking here just about species that are native to the local area, and the plantings must be permanent, noting the option for one thinning during a project's life.
I'm moving on now to the concept of stratification for avoided Forest Re clearing, so all the land that's included in an avoided forest Re clearing CEO must again form part of a 10 by 10 metre cell.
That has canopy cover above 2 metres, that's greater than 20%, noting that that cover must be assessed for trees that have regenerated since the last comprehensive clearing, and they must also form part of a .2.
Detected aggregation of land.
With forest cover.
So the other things, as Brett's already noted, are that these areas must have been comprehensively cleared within the last 25 years. We've also included the concept of excluding trees, survived that last comprehensive clearing, which it illustrated here in the figures on the bottom right.
So saying there that trees that will likely be more than 35 years old at the application date required to have exclusion areas defined around them, and you cannot have undertaken clearing since the 1st of January 2025.
And importantly, noting some of the comments in the chat about the EPBC Act changes, this concept of unrestricted right to Cliff Agriculture is still in play and.
Applies to this avoided forest re clearing concept as well as the avoided sub forest re clearing concept, but essentially the aggregation requirements are very similar to what I set out for the the reforestation.
CE as and then the third type of CEA, the sub forest re clearing CDA. So here we're talking about land that's not eligible for avoided forestry clearing because it doesn't have forest cover the 10 by 10 scale is not eligible for planting because you've got more than 10% crown cover.
At that scale, therefore, we haven't avoided Subforest re clearing CDA. Again, the requirement is for assessment at the 10 by 10 as well as a .2 hectare scale. The requirement at the .2 hectare scale is that we don't have forest cover.
And again, like the other re clearing class, we require comprehensive clearing in the past, noting that that can be assessed, as Brett said earlier at 30 by 30 minutes as well as a requirement to exclude all trees that survived that last re clearing.
And no clearing since 2025 as well as forest potential, which can be ascertained by considering the native ecosystem type for the land as well as its typical cover and height.
So the way that the gateways that Brett described interact with those stratification concepts can be initially kind of complicated to wrap your head around, but essentially the gateways need to be assessed for cells at that 10 by 10 metre scale as well as the point.
To hectare scale at those fixed aggregations, and if land fails at either of those scales, it fails the gateway, so that includes the areas that were defined to.
Within the aggregations of point to pick the aggregations that are outside of the ceas and that's goes back to that comment I made about proponents being wise to include them only if they're confident that the forest cover in those outside cells will.
Remain and also back to that concept that within the .2 hectare areas you need to be thinking about passing the gateways for individual cells that are isolated within the .2 as well as the.
Cells that are unique to that CEA not overlapping any other. Sorry unique to that aggregation and don't overlap any other aggregations.
So with that laid out, the three broad types, I'll briefly sort of update on where we got to for this draught with the abatement calculation concepts. The key thing is that for the avoided re clearing.
CEA types abatement is effectively modelled in the absence of adjustments for FBI or disturbance, and the other key thing is that you can there's a proposal for A50 year crediting period.
For projects that opt for 100 year permanence, which also affects the number of credits, you're going to get, and is contingent on the right to clear that unrestricted right to clear for Agriculture, being present in the 25th year of the project. So it's a.
Contingent effectively sensitive to potential future law changes, abatement is modelled basically by adding up the individual calculations for each CEA.
And then subtracting Emissions from fossil fuel combustion and for the project for reforestation, ceas that modelling effort includes planned and unplanned fires.
And for the avoided re clearing CAS of the sub forest or forest avoided re clearing it includes a deduction for an expectation of the baseline carbon stock and the continued cyclic RE clearing.
For each CEA, we're asking proponents to develop a full Cam model, plot the parameters of that plot will depend on the type of CEA it is, and you can see the proposed G values that we've got for the different types of CEA.
In the table on the bottom right and the M parameter for the plot will be drawn from the will will be the average of the values in the maximum biomass layout across the included cells in the CEA.
So on the area weighted average M will be used for each plot. And as Brett mentioned, there's the opportunity for people to undertake biomass sampling to adjust the value for M within limits up to 25% up.
And and include that value for M in in the model in the plots.
In pictures, the difference is really between reforestation, ceas that have a planting event or a regeneration event modelled at project commencement. And then, as I said, the option of A50 year crediting period dependent on the retention of the right to.
Comprehensively clear of Agriculture without restriction at 25 years, if you choose hundred year permanence. So that's that is subject to the vagaries of of weather and climate as well as incorporating adjustments for disturbance in the form of fire.
Whereas for the avoided re clearing CEA types versus forest and sub forest, the concept is that at the start of the project, each CEA will be deemed to be at the point where.
The modelled stock in biomass and debris above bloke and will be just above the long term average biomass models using an assumption of ongoing RE clearing and then a project would receive credits effectively.
Of the curve, either for 25 year accrediting period or 5050 year accrediting period, depending again on the option for permanence that's selected as well as the retention of the right to clear for Agriculture unrestrictedly after 25 years.
Umm.
I think that's probably a good spot to leave it in the interest of time and I'll stop sharing. Go back to Brett.

Brett Kerr   51:39
Alright. Thanks very much. Don. There's couple of questions in the chat that I might get you to answer. It's the first one from.
Jeff Roberts around the gateway cheques and where we've said you know, things like the five 5% increase each each five years and the reforestation CEA have we?
Determined those levels against, I guess the reference ecosystems. So I think, Jeff, that's what you're getting out there has been reasonable achievable.

Don Butler   52:20
OK.
Yeah, I think that would be. I mean, obviously we've done our level best to set numbers that we think are sensible, but if there's feedback on those, we'd be very interested in hearing it. We haven't at this stage suggested changing it for different environments.
So yeah, they they are up for discussion, but they're they're based on our understanding of what's what's commonly delivered.

Brett Kerr   52:53
In general, since we tried to set the gateways at at pretty reasonable levels, that's the intention. They're not meant to be difficult to achieve, they're just meant to mitigate risks. I guess that projects aren't progressing somewhat towards.
The necessary outcomes question from sky around. I guess the aggregating of the point to hectare groupings and so that these are really just to avoid.

Don Butler   53:21
Yeah.

Brett Kerr   53:27
What we what we heard through our technical sort of working group sessions earlier about a Swiss cheese effect where you have little little pieces left out because they don't quite make their own standalone .2 hectare forest, so.
They really used to determine that you've got forests at the point to hectare level meeting those definition standard definitions rather than being used to calculate abatement. And the purpose there is to say that whether they're inside or outside of a project area or shared with another.
Different CEA doesn't change the fact that they are either forest or capable of being forests at the point to hectare scale, and I don't know if there's anything else you want to add to that, Don.

Don Butler   54:15
Yeah, the I think the key point for Scott's question is that the the aggregates don't define the CEA, it's kind of the other way around. Every cell in ACEA needs to be part of an aggregate and that can like go beyond the boundaries of the CEA. So the CEA is a is a concept in itself and they don't.
But the aggregates which you use to assess forest potential and and gateways can overlap to a certain extent.

Brett Kerr   54:47
Thanks Christophe. Had a question here which I cannot answer so I ain't gonna hit this. MTA Don around how fixed the cells are to landmarks, the geographic coordinates.
And so maybe this. Yeah, you go.

Don Butler   55:04
Yeah, yeah. The idea is that they're geographically fixed.
Noting that there there can be a bit of a little bit of dither, but essentially I'm viewing this as a kind of raster. Rest of you of the world where the grids are aligned with coordinates, so you would need to do a good job with rectification. You may need to do some.

Brett Kerr   55:28
No.

Don Butler   55:29
Small adjustments here and there.

Brett Kerr   55:35
Thanks Dunn. I might just go to Scott's follow up here. We're still not quite following, if you can have non CEA in the aggregates, aren't you potentially counting re pre-existing forest and CEA gateways?
None.

Don Butler   55:54
Effectively we're. Yeah, we're allowing the presence of a forest beside an area that you're adding forest cover to the count, to the attainment of a point, to hectare minimum to be a forest, if you like. But that's why I was talking about the need for each 10 by 10.

Brett Kerr   55:55
Thank you.

Don Butler   56:13
As well as the unique cells within an aggregate. So there's there's many levels of assessment, so you're not entirely allowing for the pre-existing forest account. You're also expecting to see change within the CDA cells.

Brett Kerr   56:36
Sam, you saw has a question here Don, the use of 10 by 10 metre cells seems unnecessary. It makes mapping requirements confusing and difficult. Appears to be based on the idea that mapping is based on Sentinel 2 satellite imagery without explicitly saying that.
Mapping of CEA should just use vector based polygons like other methods. Requirements such as each 10 by 10 metre cell must have at least one tree are just not practical from a monitoring perspective.

Don Butler   57:05
I think that's a comment.

Brett Kerr   57:09
Yeah. And so we do have a question in the discussion paper as well. It's if sits aside this around, it's come from discussions with the regulator around the sorts of products that can be used to.
Show eligibility for instance, or or in mapping. So things like persistent green and whether we should have a defined list that can be used that the regulator would maintain.
And what they if So what those products should be? So that's that's something for that would be keen to get feedback on as well through through this process there are a few other questions at the bottom of the discussion paper which is on our web page that just some some things have occurred to us that we'd.
Really like to see people's see people's views on as well. That's just one of them.
Emily here is 400 stems, a hectare for planning quite high. My understanding is the current EP required density is 250 stems per hectare.
Yeah, you have comments about that being too high, would be keen to get them through in the feedback.
Yeah. Any views on that welcome.
And from Phil, what science supports the long term sustainability of 400 stems per hectare, see a lot of trees not surviving. So I think that's a similar comment to Emily's that 400 maybe too dense. So yeah, happy to get.

Andrew Macintosh   59:04
I don't just to jump in, Brett. The 400 don't have to all survive. You have to plant in in all 10 by 10s and it has to be 4 hundreds, 4 hundreds, pretty low if you actually strictly read the planting. The the guidelines under the C5 which are part of the form part of the instrument, it actually should be 400 stamps per hectare as a minimum.

Brett Kerr   59:07
Yep.

Andrew Macintosh   59:24
But then they seemingly have overridden that and taken the interpretation of the instrument has been superior to the other incorporated document. So I think 400 is kind of reasonably standard as a as a lower bound a lot of times plantings will be significantly higher than that.

Brett Kerr   59:41
Entry, Christophe, question about whether the method will be considered for alternative assurance, we would like to see it considered for that. That's obviously a decision of the CR board to make has been raised in our discussions with.
With the stuff from the regulator. So yeah, we'd, we'd like to say I don't like personally. Don't say why not, but yeah, not our decision to make.
James, can we have a 50 year permits and 50 year crediting period for the AC part in forest and Subforests would remove long term risk for land holders.
Yeah, something worth considering, James. I don't think the way we've would have to have a look at the specific drafting unless someone can help me with that off the top of my head, I think we've restricted that 50 year crediting to 100 year permanence.
The way we've dealt with 50 year permanence periods for avoided clearing to, I think Scott asked a question earlier, it was rather than pursuing an act change at the moment to allow that, we've just set a minimum 50 year permanence period for that.
Those types of projects in the in the method, and if a 50 year permanence period comes into being through an amendment to the ACT that will sort of enliven that possibility in the method. So we're not seeking a sort of contemporaneous or prior.
Yeah.
Act amendment to to bring that into effect.
So Christophe, could you elaborate on what sort of bio security requirements it will be, a shame to ensure some weight free CAS. Is that correct? No. So what we're really pointing to Christophe is.
It's it's in different different states in Queensland where you're from. Local governments have local government, local bio security plans for instance, and we'd be looking for you as a landholder to demonstrate how you will manage.
The site to be consistent with those local plans as as well as state and Commonwealth laws in other states, their regional bodies that prepare bio security plans as well. So we'd be looking for people to align to those regional bio security plans.
And also just so there's obviously various impacts of weeds and one of one of them will be on the carbon potential of the site or the potential for it to regrow native forests. So obviously it would be expected to manage weeds.
In such a way that that forest outcome is not impeded, wheat freeze sounds super optimistic. Christopher, any any piece of land? So we're not really requiring anyone to be wheat free.
And we're we've come to time. Yeah. If you can get an area of land. Wait, free. Chris off. Tell me how to do it. Love to know. We'll coming to time. He's just gonna. So just to to wrap up. We will.
Post up the recording of this information session for people to to look back on or to for people that couldn't make it. We'll summarise the the queue and the questions and answers that we've had today and and post that up as well.
If you have additional questions, please just email us at the email address that's on your screen. There. Natural Capital at Tipsy and we'll try and incorporate that if you get them to us soon enough. Otherwise, any feedback we could of course we'll we'll take on board.
And we'll try and have the recording and the Q&A is up before the end of the week onto the website as well. Just a reminder that we we want to close feedback on the 6th of February to give us time to to make, to submit our documents to Eric in March.
To hopefully be able to brief erac on the final proposal from us in the April settings. So that's our anticipated timeline, our web address for the method is there. That has a discussion paper, the workflow document around the technical elements.
Method as well as the draught method itself. If you just Google improve the voided clearing you'll you'll get to that Web page as well. So thank you all, I really appreciate you taking the time particularly.
Close to Christmas and apologise for this running over the Christmas period. What seems to happen and better what our best intentions are. But Yep, thank you again and we look forward to receiving your feedback.