Standard 2 – Permanent

Standard 2 – Permanent – Current definition: “For practical, biological carbon stores would be generally considered permanent if they were maintained (on a net basis) for at least 100 years.” “The ‘Risk of Reversal’ is unique to sequestration activities and needs to be addressed.”

“The Government recognises the difficulties involved in making very long-lasting decisions about land use and the value of preserving future land use flexibility.” The Government’s approach to permanence: 1. Farmers can withdraw if they ‘relinquish’ credits received. 2. A risk of reversal buffer of 5% insures the Scheme from re-release. 3. Credits must also be relinquished if carbon stores are destroyed and not re-established. The 5% buffer protects the farmer from losses in bushfire or drought.

Questions arising from the Current Definition of Permanence:

1. Is this approach likely to attract any interest among Growers? What percentage of Growers would sign a soil carbon sequestration contract for

2. Given the perceived risks for farmers in such a Scheme, what price would carbon need to be to tip the ‘Risk/Return’ scales?

3. How short would a contract have to be to attract large numbers of Growers to contribute to ‘stalling’ Global Warming? 50 years? 25 years? 5 years?

4. Is the Prime Carbon approach of building a 100% buffer as a risk management protection, ensuring no Grower would have to relinquish credits meet the Government’s criteria for “a uniform approach… simple to administer and justified because there is limited data to enable project level activity risks to be accurately and easily quantified”?

5. Is the rationale for a short (5 years) period: “Behaviour Change becomes Practice Change becomes Culture Change” feasible?

7. Could there be potential for extending the ‘risk buffer’ concept to cover large numbers of growers trading not as individuals but in aggregates. The Iowa and Illinois Corn Growers Associations have redefined Permanence using the concept of “collective persistence” to ensure duration over time. Soil carbon reserve pools serve as a risk buffer to provide insurance of adequate credits should a Project Owner fail to produce agreed upon quantities. Permanence is “a function of the farm aggregate collectively using credit practices of avoided emissions and carbon sequestration rather than the function of an individual producer.” While individuals might temorarily change their sequestration rate for whatever reason, not all farmers involved are likely to do the same. “As an aggregate there is a collective persistence of carbon credits,.” The Corn Growers claim that when the effects of large groups of producers are measured collectively, credit practices increase each year. Their Draft Agricultural Soil Credit Standard is reported to be in the second phase of evaluation by the USDA.

8. Given the importance placed on peer-reviewed data, is the claim that soil carbon can be significantly reduced by bushfire and drought based on peer-reviewed science or is it the type of fact – like “Australia’s soils are too ancient and degraded to sequester significant amounts of carbon” – that everyone knows but no one knows where it came from – a cultural artefact known as a ‘furphy’? Has the Department questioned the assumptions on which much of the scientific opinion is based?

9. Why 100years? What product or commodity can we name that we sell today and must warrant for 100 years? What transactional settlement period is T+100 years? Why are we asking landowners to go longer than government is willing to regulate the environment and business? The only real reason is that people are looking at matching up atmospheric accounting to the IPCC 100 year GWP. Those same studies have also looked at atmospheric impact over 20 years. Since most of the GHG gases have a more severe impact over the first 20 than the next 80, why not look to the immediate climatic impact.

10. If Soil Carbon is to be ‘a secure bridge to the future’ by drawing down the equivalent of 50ppm for 50 years, can this period be justified as the Permanence Standard by virtue of its critical role?

11. Has Soil Carbon’s reputation for instability – which is based on a misunderstanding of carbon dynamics – turned Permanence into a high risk factor which will require discounted pricing? There are two theories of sequestration: The Fixed Molecule Theory Vs The Cycling Molecule Theory. The Fixed Molecule Theory is popular.“Carbon is sequestered in soil when rendered immobile in the form of stable fractions such as humus. Carbon held temporarily in labile fractions cannot be said to be sequestered because it is oxidised in a short time. Therefore only

carbon stored in soil as humus or char can be counted towards a farmer’s tradable tonneages of stored carbon.” But such a restraint would reduce the incentive for landholders to convert to Carbon Farming and lose the benefits to society of the sequestration. On the other hand, The Cycling Molecule Theory starts from the fact that Carbon by its nature cycles. The Carbon Cycle is fundamental to life on Earth. All forms of Carbon are cycling between sink and source. These cycles vary in length of time, some very short, some very long, depending on the nature of the sink. No sink is permanent. All sinks act like ‘holding bays’ - some hold Carbon Molecules for centuries and some for seconds. Climate Change is caused by imbalance in the cycles: ie. too much carbon is being held in the Atmosphere and the Ocean and not enough in other forms. Carbon sequestration occurs when the Carbon Cycle is adjusted to delay its transition from one form to another. When Carbon is captured by Vegetation and becomes a component of soil it enters a ‘holding bay’. Sequestration takes place when the amount Carbon in the holding bay increases and that increase is maintained. The volume of Carbon in the holding bay is not affected by the rate of C atoms escaping so long as the rate of C atoms arriving remains equivalent or greater. If the rate of arrivals is equal to the rate of departures, Carbon is said to be in a “steady state”. If the rate of arrivals exceeds that of departures, Carbon is said to be sequestered. If the rate of arrivals falls short of the rate of departures, Carbon is said to be emitted. Therefore the key to sequestration in soil is not the individual molecule but the representative value of a molecule. Increases in “Molecular Value” can be created by changing land management practices that encourage carbon to increase act naturally.

Recommendations

Carbon Farmers of Australia recommends the Permanence requirement be decided on the following Principles:

Principle 1. That the Permanence performance of the offset be defined according to the role it plays in the global effort to restrain Global Warming and prevent it from going beyond 2°C.

Principle 2. That the concept of Permanence applied to biosequestration be of such a kind that enables the sinks to perform to their capacity.

Principle 3. That the approach to risk be not ‘what risk if we do’, but ‘what do we risk if we don’t’.

Suggestions for Action on the Permanence Standard

Action 1: Define Biosequestration units by a brand name that explains their function, ie., ‘a bridge to the future.’

Action 2: The imperative to have as many farmers capturing as much carbon as possible as fast as possible as a sort-term emergency stop gap requires that Permanence be made more flexible because it is a barrier to recruitment.