Joint CER/DCCEEW response to ANU papers on Human Induced Regeneration

The Clean Energy Regulator (CER) has released Carbon Estimation Area (CEA) data following recommendations from the Independent Review of Australian Carbon Credit Units (ACCU Review) and a change to the law by Parliament.

The Department of Climate Change Energy Environment and Water and the Clean Energy Regulator provide the following statement in response to the two papers released by Andrew Macintosh et al on Human Induced Regeneration (HIR) the week of 19 June 2023:

The analysis relies on a misinterpretation of requirements in the method:

  • There is no requirement in the HIR method, nor other legislation, for projects to be preceded by land clearing.
  • The HIR method was designed to avoid creating an incentive for broad scale land clearing, which can cause significant environmental harm including land degradation, loss of biodiversity and poor water quality.
  • Scientific literature supports the view that grazing animals can stop trees reaching a forest, such as a study by Eldridge et al. (2016), which found that that overall “ecosystem structure, function, and composition in rangelands are negatively affected by livestock grazing”.
  • Carbon Estimation Area (CEA) satellite images are not sufficient, in and of themselves, to make a judgement about the performance of HIR projects.
  • The CEA data alone does not provide insight into the changed land management practices, nor readily show how much abatement has been achieved, particularly at the early stages of a project.
  • The CER confirms abatement outcomes of HIR project activity with audits, site visits, drone footage and geolocated photographs.
  • On the first paper, the CER and the department reject the claim that CER released false and misleading material. The analysis in the paper is based on flawed assumptions about when projects started and the extent to which forests increased on areas of land in the CEAs.
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