Analysis of the Integrity Risk and Performance of Human-induced Regeneration (HIR) Projects using CEA data

The ANU-UNSW research team has analysed the recently released CEA (carbon estimation area) for HIR #carbon projects. The results are unsurprisingly bad.

Full paper here

Interactive data and map here: https://www.carbonintegrity.au

Our key findings are:

1. Most HIR CEA areas have never been comprehensively cleared. This means projects are being credited ACCUs as if forest is regenerating on top of existing remnant vege. Remember that under the HIR method, ACCUs are issued according to *modeled* forest regeneration.

1. Woody/tree cover (sparse woody & forest) increased in CEAs of only 19% of 192 projects. Woody cover decreased in 42% projects. Important to remember ACCUs should only be issued once FOREST cover is achieved (min 2m high, 20% canopy cover), not just any increase in woody cover.

Here's what the overall picture looks like. Projects are supposed to be regenerating permanent even-age native forests across the **entire area** included in the CEAs (3.4 million ha). Currently, only about 12% of this area is forest (note it was 10% in 1988, see trend)

Our analysis of CEA data confirms what we've argued for 2+ years: HIR projects are likely to have been significantly over-credited with #ACCUs.

Yet, critics of our analyses argue that publicly available satellite imagery, plus the CEA data, is insufficient to judge the integrity of #carbon #offsets.

Yet the Clean Energy Regulator has repeatedly used the EXACT SAME DATA to *defend* the integrity of HIR projects:

First time, early 2022: Beare and Chambers report

Second time, June 2022: ERAC report

Third time, May 2023, Carbon Farming Industry Forum, Cairns:

Our team has reproduced these graphs to explain why they are misleading - full paper available here:

First, there's no defensible reason for plotting the y-axis as "%vege growth since 2010". Most projects didn't start on the ground until 2016.

You know what did happen in 2010?

It rained.

Once you plot the NFSW data using a % forest cover y-axis, rather than a *change* since 2010, you can see a more honest picture. The first graph below shows % forest cover inside HIR projects, vs the broader Bourke LGA.

The second graph's y axis is adjusted as per the Clean Energy Regulator graph. This just shows that during the Millenium Drought, forest cover fell more sharply in the HIR project areas than in the surrounding LGA, then it recovered more rapidly following the 2010-12 La Lina event. Same trend since approx 2014.

Putting aside the y-axes for a moment, the Regulator's own graphs - using the same data we have analysed - show that:

Almost all of the increase in woody cover in the CEAs occurred *before* HIR projects were registered, & woody cover has *barely changed since* (~2% increase).

Why does any of this matter?

In January 2023, ACCU issuance on HIR projects was paused post-Chubb. Minister Chris Bowen directed the Clean Energy Regulator to administer the HIR method according to the Chubb Review recommendations in May 2023.

As of June 2023, HIR ACCU issuance has restarted.

This is exactly what we feared - a short pause, then back to business as usual.

This is the same Regulator that Minister Tanya Plibersek wants to administer the #NatureRepairMarket.

I agree with Zoe Daniel MP & others that the EPA, not the Clean Energy Regulator should perform this role (if the NRM Bill passes the Senate).

Finally, if you want to see the additional, contextual data the Clean Energy Regulator & others say is needed to evaluate ACCU scheme performance, go to:

• Project Register cleanenergyregulator.gov.au/ERF/project-an…
• Column N of spreadsheet, click URL
• You'll find a PDF with information such as the registration date, crediting commencement date, modelling commencement date, data sources used, very brief information on the baseline scenario (e.g "livestock, feral animals") and the management practices implemented in the CEAs (e.g "Management of the timing, and the extent, of grazing; Management, in a humane manner, of feral animals")

Perhaps the "Voluntary CEA Data Release" would be better described as a metadata release, seeing as you can't actually access any of the data described in the PDF.

But you can view all public CEA & NFSW data here:

carbonintegrity.au