Report of the Senate Environment, Communications, Information Technology and the Arts References Committee
The Heat Is On: Australia's Greenhouse Future
Table of Contents

Chapter 7

Carbon and the Land         (Part a)

Pilot land use, land use change and forestry projects that are designed to avoid emissions by reducing deforestation and forest degradation have produced marked environmental and socioeconomic co-benefits, including biodiversity conservation, protection of watershed and water resources, improved forest management and local capacity building, and employment in local enterprises. [1]

Introduction

7.1 The contribution of the land-based sectors to emissions and the potential of elements of the sectors to play a significant role in greenhouse gas abatement is one of the most complex, controversial and uncertain elements of the climate change debate. The objective of this chapter is to examine and provide recommendations on:

• the contribution of the land use change and forestry, and agricultural sectors to Australia's greenhouse gas emissions;
• the impact of current land management practices and policies on current and projected greenhouse emissions;
• action that is currently being undertaken to reduce emissions in these sectors and the potential for these sectors to contribute to greenhouse gas abatement; and
• the use of carbon sequestration through land-based sinks as a greenhouse response measure and the issues and uncertainties associated with accounting for their use.

The Global Carbon Cycle

7.2 Carbon is released into the atmosphere through natural means via plant respiration, soil respiration and diffusion from oceans, as well as by human activity such as burning fossil fuels for electricity production and transport, and deforestation. Human activity has disturbed the natural cycle resulting in an increase in the release of carbon annually bringing about an increase in atmospheric concentrations of greenhouse gases. [2]

7.3 Plants and soils are important components of the carbon cycle. Carbon is taken from the atmosphere by plants through photosynthesis, and is released again to the atmosphere through respiration, as part of life support processes. However, not all carbon is released as part of this process. Some carbon dioxide is converted with water into carbohydrate (which contains carbon) and oxygen. Plants utilise carbohydrate in cell tissues as they grow, and consequently some of the carbon from the atmosphere is transformed to the living system. Where photosynthesis exceeds respiration, the net carbon is stored (sequestered [3]) in the plant biomass (roots and above ground matter such as stems, tree crowns etc), thus creating a carbon sink [4] or store. Soils store carbon as organic matter - as a result of plant litter decomposition, and root material. [5]

7.4 The contribution of the land use, land use change, and forestry sector to the global carbon cycle is important. Globally existing terrestrial ecosystems are currently estimated to be acting as a small net sink for carbon dioxide. This carbon uptake occurs through vegetation and soils in terrestrial ecosystems and is much larger in soils than in vegetation. [6]

7.5 In Australia, the removal of vegetation for agricultural or other purposes has resulted in significant emissions. Other activities in the land use change and forestry sectors such as the growth and regrowth of native forests, establishment of plantations and environmental plantings provide an opportunity to offset these emissions and sequester additional carbon from the atmosphere. There are, however, considerable uncertainties about the long term potential of carbon sinks as an abatement measure and accounting for the carbon sequestered.

Greenhouse gas emissions from land use change and forestry, and agriculture

7.6 The land use change and forestry sector and the agricultural sector are both significant contributors to Australia's National Greenhouse Gas Inventory (NGGI). Each of these sectors is reported separately in the Inventory according to the international guidelines established under the UNFCCC. In addition, due to the uncertainty of current estimates from land clearing, these are not included in the national Inventory total but reported as a separate item.

7.7 According to the most recent estimates contained in the 1998 NGGI, the land use change and forestry sector (excluding estimates of land clearing) is estimated to have provided a net sink of -24.5 Mt CO2-e or -5.4 per cent of net national emissions. [7] Factors considered in arriving at this estimate include:

• growth, harvesting and regrowth in managed native forests and plantations;
• wood products including production of fuelwood, paper, particle board, furniture and building frames that decay at varying rates; and
• prescribed burning, wildfires, and changes in land management practices such as pasture improvement and minimum tillage. [8]

7.8 Emissions in the forestry subsector as a result of commercial harvesting and fuelwood production equated to 38.9 Mt and 12.8 Mt, respectively. This is offset by the removal of greenhouse gases through carbon sequestration resulting from tree growth in managed forests of -73.4 Mt, resulting in a net sink of -21.6 Mt. A small amount of emissions were generated as result of prescribed burning and wildfires (1.4 Mt) and a small sink resulting from minimum tillage and pasture improvement practices (-4.2 Mt). The contribution of these areas to the Inventory provides an additional net sink of -2.8 Mt, bringing the total net sink for the subsector to -24.5 Mt. [9]

7.9 Emissions from harvesting have increased by 10.4 per cent over the period 1990 to 1998, and whilst the sink associated with forest growth has also increased over this period, it has not had the same rate of growth (2.9 per cent) thereby resulting in a reduction in the net forestry sink in this period. [10]

7.10 Projections undertaken in 1997 identified a potential increase in net sink capacity from forests to 32 Mt in 2010 with existing measures. [11] Dependent on the final treatment of sinks under the Kyoto Protocol this potential could increase significantly.

7.11 The interim estimate of emissions from land clearing in 1998 is 64 Mt. This is comprised of emissions of 81.5 Mt associated with land clearing and the removal of 17.5 Mt through sinks associated with the regrowth of grass and woody vegetation. Factors considered in arriving at this estimate are the burning and decay of aboveground biomass, regrowth on cleared lands, and changes in soil carbon from current and past events. Land clearing can cause emissions of carbon dioxide from the disturbed soil for 10 years or more after the event. [12]

7.12 The estimates for land clearing are highly uncertain and considered the most uncertain part of the Inventory. The uncertainty results from a lack of accurate statistics on:

• the rate of land clearing;
• biomass of vegetation cleared;
• regrowth of vegetation on cleared areas; and
• level and change of carbon through soil disturbance. [13]

7.13 To improve confidence in land clearing estimates and to meet future requirements of the Kyoto Protocol, a National Carbon Accounting System (NCAS) is under development. A key objective of this system is to provide by 2002 an estimate of the 1990 emissions from land clearing for inclusion in Australia's 1990 Kyoto Protocol baseline. It is also intended to provide substantially improved estimates of areas of clearing, areas of forest plantings, rates of growth in commercial and environmental plantings and emissions from soils, to increase confidence in post-1990 estimates and to meet future Kyoto Protocol accounting requirements for sources and sinks. [14]

7.14 Using the interim estimates available, it appears that land clearing activities were a net source of greenhouse gas emissions from 1990 to 1998 but there has been a considerable decline in emissions from this subsector in this period. [15] More recent reports of land clearing rates, particularly in Queensland, suggest an increase in emissions could be expected for 1999 and 2000.

7.15 When land clearing figures are included in the total for the land use change and forestry sector, total emissions for 1998 are estimated at 134.7 Mt with the removal of -95.2 Mt through sinks. This leaves a net emissions result of 39.5 Mt compared to the currently reported net sink of -24.5 Mt. [16]

7.16 The 1998 NGGI notes that:

The uncertainty associated with estimates of emissions and removals from Forest and Grassland Conversion [land clearing] remains high. This is largely due to the use of incomplete data, preliminary rates of land clearing for some states and some years, inadequate methodology for calculation of regrowth sequestration, use of averaged pre-clearing biomass and soil carbon estimates not spatially linked to where clearing is occurring, and the use of default conversion factors for soil carbon change following clearing. [17]

7.17 The agricultural sector contributed 20.2 per cent or 92.2 Mt of total national net emissions in 1998 (excluding land clearing estimates). It is the most significant source of greenhouse gas emissions following the stationary energy sector, and the largest source of methane and nitrous oxide emissions. However, it also one of the more stable sectors with little change in emissions overall in the period 1990 to 1998. Sources of emissions in the agricultural sector are livestock (enteric fermentation and manure management), rice cultivation, agricultural soils, prescribed burning of savannas (for pasture management, fuel reduction, prevention of wildfires and traditional Aboriginal burning practices), and field burning of agricultural residues. [18]

7.18 There have been increases and decreases within this sector, most significantly in the agricultural soil subsector, which has seen an increase of 10.4 per cent overall in the period 1990 to 1998. The increase is due primarily to increase in nitrous oxide emissions from fertilised crops and pastures (representing an increase in the rate of artificial nitrogen fertiliser application). There has also been an increase in emissions resulting from the field burning of agricultural residues such as cereal stubble burning, and an increase in methane emissions due to increases in rice cultivation. Changes in livestock emissions over the period 1990 to 1998 can largely be attributed to increases and decreases in livestock numbers driven by economic factors such as wool prices, however, there has been an increase in nitrous oxide emissions due to increasing intensification of the livestock industries. [19]

7.19 Emissions projections undertaken in 1997 for the agricultural sector indicate growth of 7 per cent on 1990 levels by 2010 with current measures. [20] As noted above, there has been limited overall growth in the agricultural sector with current trends showing an overall 1.8 per cent increase in the period 1990 to 1998. [21]

7.20 There are also considerable uncertainties about emissions estimates from the agricultural sector. The level of uncertainty is thought to be between 20 per cent and 80 per cent and is due to the diffuse sources of emissions in the sector, lack of understanding of some of the processes leading to emissions in the sector, lack of robust data, and the methods by which data has been compiled. [22]

Requirements under the United Nations Framework Convention on Climate Change (UNFCCC) and the Kyoto Protocol

7.21 As a party to the UNFCCC, Australia is committed to the promotion of sustainable development and promotion and cooperation in the conservation and enhancement of sinks and reservoirs of all greenhouse gases, including biomass, forests and oceans. [23] Australia is also required to produce and regularly update a NGGI that presents emissions on a gas by gas and sector by sector basis as determined by the reporting guidelines established by the IPCC. [24] This includes the land use change and forestry, and agricultural sectors.

7.22 Following the negotiation of the Kyoto Protocol, carbon sequestration through forestry sinks and other means has taken a more prominent role. Under Article 3 of the Kyoto Protocol, countries must count both sequestration and emissions from a limited set of land use change and forestry activities towards meeting their Kyoto Protocol target commitments. Sinks may also play a strong role in the implementation of the flexibility arrangements (Emissions Trading, Joint Implementation (JI), Clean Development Mechanism (CDM)) under the Kyoto Protocol. There are outstanding definitional, operational and measurement issues awaiting decision before the potential impact of these articles is fully known. A number of these are expected to be considered and resolved in the international negotiations at CoP 6 later this year. [25] The inclusion of, and parameters of, the Articles pertaining to sinks in the Protocol has been the source of much international and domestic debate, and a key focus of submissions to this inquiry. These issues are explored in greater detail in the sections on accounting for carbon, and the role of sinks, below.

Overview of current greenhouse action in the land use change and forestry, and agricultural sectors

7.23 Governments and industry have placed significant emphasis on the potential role of sinks in achieving Australia's Kyoto target. Governments view sinks as highly cost effective means of meeting the abatement task and point to a range of ancillary benefits that can also be achieved with sink related programs, such as addressing issues of land degradation and enhancing biodiversity.

7.24 Under the National Greenhouse Strategy (NGS), efforts are being made to reduce land-based emissions and enhance greenhouse sinks through existing national forestry and revegetation programs such as Bushcare - the National Vegetation Initiative; and new programs such as Bush for Greenhouse, which aims to promote investment in the establishment of greenhouse sinks. Bush for Greenhouse was only declared `open for business' [26] by the Government in April 2000, more than 2 years after its inception, and is not without its critics. For example, Southern Pacific Petroleum and Central Pacific Minerals reported:

Our experience with the Bush for Greenhouse program has been disappointing mostly because there appears to be confusion within Government about this program's scope and objectives. [27]

7.25 Effort has also been expended in investigating the potential role of carbon sinks in a national emissions trading scheme; improving understanding of how relevant carbon pools are affected by management practices; and expanding capacity to measure and monitor changes in carbon stocks through the establishment of a NCAS.

7.26 Primary responsibility for the management of natural resources such as native vegetation rests with the states and territories, and has been the source of much tension in Commonwealth and state relations. A number of national strategies/ frameworks/policies have been agreed with the states and territories to encourage sustainable land management practices and greater protection for native vegetation. For example, the 1992 National Forest Policy Statement and more recently, the Australian and New Zealand Environment and Conservation Council (ANZECC) National Framework for the Management and Monitoring of Australia's Native Vegetation. The success of these strategies is reliant on action taken by the states and territories, with the Commonwealth often expected to facilitate action through the provision of funding or other support.

7.27 In addition, considerable focus has been given to the ongoing international negotiations related to sinks and the Kyoto Protocol. This point was reinforced by Mr Ralph Hillman, Australia's Ambassador for the Environment, who told the Committee:

Sinks are of critical importance to Australia. The definition and rules to be adopted will impact on the size of our abatement task, as well as the cost. This will be a key issue for us at CoP 6. [28]

7.28 State governments (most notably Western Australia and New South Wales) have embarked on a range of sink enhancement and investment projects. The potential for sinks has also been recognised in most state greenhouse strategies/action plans developed under the auspices of the NGS.

7.29 Industry is also increasingly seeking to offset emissions through the use of sinks. The Australian Greenhouse Office Greenhouse Challenge Program recognises the use of sinks as an offset in industry agreements and several state governments have entered into agreements with industry. Recent examples are the agreement between State Forests NSW and the Tokyo Electric Power Company to establish 10,000 to 40,000 ha of plantations in NSW to offset a portion of their emissions; and investment by BP AMOCO in reforestation projects in partnership with the Western Australian Department of Conservation and Land Management.

7.30 A commensurate amount of effort does not appear to have been taken by governments in reducing emissions from agricultural production. Module 6 of the NGS identifies a number of sustainable agricultural management practices to deliver reductions in greenhouse gas emissions, however, little evidence of the promotion of these practices at any level of government has been presented to this inquiry. Significant hopes appear to be pinned on the outcomes of rumen modifier research being conducted by CSIRO as the key measure for achieving emissions reductions in this area.

The future for the land use change and forestry, and agricultural sectors

7.31 The Committee canvassed a broad range of views when considering issues associated with the land use change and forestry, and agricultural sectors. These included: Federal and state government agencies, community advocacy groups, industry representatives, environmental groups, and farming interests. A wide range of views was presented and very few areas of concurrence amongst witnesses emerged. A key area of divergence was the potential role and contribution of sinks in meeting Australia's Kyoto Protocol commitments. The agricultural sector attracted few comments, although land clearing for agricultural and other purposes was perceived by most witnesses as a significant problem that needed to be addressed.

7.32 Common views and issues which emerged from evidence presented to the inquiry were:

• Sinks present a cost-effective means of abatement and have a number of positive ancillary environmental benefits. However, there is considerable concern over the permanence of sequestered carbon and the longer term impact of choosing this method over reduction of emissions at source.
• There were fears that a perverse outcome may result from the over-reliance on sinks as an abatement measure. The use of sinks as a primary response measure could lead to an increase in actual emissions at source and potential reduction in investment in areas such as renewable energy, fuel switching and energy efficiency.
• There was criticism by a number of groups of the negotiating position the Government took to Kyoto, in particular the inclusion of Article 3.7 which enables Australia to include land clearing in its 1990 baseline and claim as a credit any reductions from the subsequent decrease in emissions as a result. Significant focus is now being given to the negotiating position the Government is taking to the CoP 6 negotiations.
• The allocation of carbon credits associated with sinks has a number of inherent risks and uncertainties that are yet to be overcome, including measuring and monitoring the carbon sequestered and establishing carbon property rights. These uncertainties have been viewed as stifling potential investment in sinks and concern was expressed that the longer the delay in their resolution, the less benefit such investment will be to meeting Australia's Kyoto target in the first commitment period. Other concerns relate to the potential for the misuse and false accounting of carbon sequestered.
• It was widely agreed that the need for credible and transparent accounting mechanisms for the land use change and forestry sector, to reduce current levels of uncertainty and meet future reporting requirements under the Kyoto Protocol, is an imperative.
• The negative impact of current land management practices, in particular land clearing, on Australia's emissions is high. There are many ancillary environmental and other benefits such as enhancement of biodiversity, soil conservation and water management, and low cost abatement to be achieved by reducing emissions in this sector. There is a common view that insufficient action is being undertaken in parts of Australia to reduce or halt land clearing and that further research and development in sustainable agricultural systems is required if emissions reductions in this sector are to be achieved.

7.33 To a large degree the future role and potential contribution of sinks to Australia's greenhouse abatement task will be determined by the outcome of the
CoP 6 negotiations. Regardless of this uncertainty, a number of policy options have been put forward by witnesses (including suggestions for Australia's negotiating position on sinks), although there are divergent views on the best options. Suggestions included:

• A greater emphasis should be placed on reducing emissions at source in the land-based sectors by halting land clearing and ensuring more sustainable management practices in agricultural production. Sinks should only be viewed as part of a portfolio of responses in the land-based sectors not as the key response measure.
• Rather than focus on creating new sinks, greater efforts should be made to protect existing sinks, in particular old growth forest, by ceasing logging activities in native forests. Government policy should favour the protection of ecologically diverse natural forest landscapes over the creation of plantations.
• As a greenhouse response measure, sinks should only be viewed as a short term or transitional option to buy additional time to identify and implement long term abatement solutions that reduce emissions at source.
• Priority should be given to a more precise definition of forest and forest related activities under the Kyoto Protocol, to ensure that priority is given to maintaining existing carbon sinks rather than creating new ones.
• Sequestration is a useful transitional strategy to employ until we have the solutions to go to more sustainable forms of energy usage.
• Australia should be actively promoting its sequestration opportunities beyond forests and should ensure that recognition in the form of carbon credits is also given in the Kyoto Protocol to revegetation activities.
• Investment in plantations and revegetation activities on already cleared land offers a low cost solution not only for greenhouse but also salinity and the delivery of regional ecologically sustainable development. To effectively achieve these outcomes property rights to carbon must be recognised at a Federal level and a uniform national framework put in place to enable trading of carbon credits between growers and industry to generate further investment. Such a trading system needs to be supported by a transparent and credible accounting framework.
• To best meet Australia's interests, the objective of the international negotiating position on sinks under the Kyoto Protocol should pursue as broad an interpretation as possible to enable all revegetation activities to be recognised and accepted as a sink.
• Government should provide leadership, funding and regulation to provide sufficient incentive for the development of appropriate biomass plantations to provide carbon sequestration and the added objective of addressing issues such as dryland salinity, wildlife habitat, soil erosion, liquid fuel production, wood products, and biomass for energy production.
• The management of land clearance and the pursuit of forestry and land rehabilitation programs that have economic and/or environmental benefits, as well as greenhouse abatement, should be a key priority for ongoing national greenhouse policy development.
• Government greenhouse policy in the land-based sector should also aim to benefit the long term viability and sustainability of rural communities and help to achieve broader natural resource management outcomes.
• Government should also be willing to develop and commit to cost sharing approaches for the management and retention of native vegetation, including equitable compensation for landholders adversely affected by imposition of government controls on vegetation use and management.
• Government should be providing a greater level of support for research and development in reforestation and revegetation opportunities.

Greenhouse Sinks and the Kyoto Protocol

7.34 As noted earlier, the Kyoto Protocol makes allowances for the inclusion of sink activities as follows:

Article 3.3. The net changes in greenhouse gas emissions by sources and removals from sinks resulting from direct human-induced land use change and forestry activities, limited to afforestation, reforestation and deforestation since 1990, measured as verifiable changes in carbon stocks in each commitment period, shall be used to meet the commitments under this article of each party included in Annex I. The greenhouse gas emissions by sources and removals by sinks associated with those activities shall be reported in a transparent and verifiable manner and reviewed in accordance with Articles 7 and 8.

Article 3.4. Prior to the first session of the Conference of the Parties serving as the meeting of the Parties to this Protocol, each Party included in Annex I shall provide, for consideration by the Subsidiary Body for Scientific and Technological Advice, data to establish its level of carbon stocks in 1990 and to enable an estimate to be made of its changes in carbon stocks in subsequent years. The Conference of the Parties servings as the meeting of the Parties to this Protocol shall, at its first session or as soon as practicable thereafter, decide upon modalities, rules and guidelines as to how, and which, additional human-induced activities related to changes in greenhouse gas emissions by sources and removals by sinks in the agricultural soils and the land use change and forestry categories shall be added to, or subtracted from, the assigned amounts for Parties included in Annex I, taking into account uncertainties, transparency in reporting, verifiability, the methodological work of the Intergovernmental Panel on Climate Change, the advice provided by the Subsidiary Body for Scientific and Technological Advice in accordance with Article 5 and the decisions of the Conference of the Parties. Such a decision shall apply in the second and subsequent commitment periods. A party may choose to apply such a decision on these additional human-induced activities for its first commitment period, provided that these activities have taken place since 1990. [29]

7.35 In addition, there is scope for sink activities to be included in the Protocol's flexibility mechanisms (JI, CDM and Emissions Trading).

7.36 The Kyoto Protocol did not provide definitions of land use change, forests, forestry activities including afforestation, deforestation, and reforestation, carbon stocks, human-induced and direct human-induced. Nor does the Protocol set out the rules for accounting for carbon stock changes, and for emissions and removals of greenhouse gases from land use and land use change and forestry activities, or how sinks may be incorporated in the flexibility mechanisms.

Articles 3.3 and 3.4

7.37 Internationally a significant effort has been put into clarifying and reaching agreement on issues associated with Articles 3.3 and 3.4. The Intergovernmental Panel on Climate Change (IPCC) was charged with the preparation of a special report concerning current understanding of land use, land use change, and forestry activities and their relationship to the Kyoto Protocol. The IPCC's Summary for Policymakers provides scientific and technical information to provide guidance to the Parties to the Protocol in their ongoing deliberations on these matters. The report notes that:

There are many possible definitions of a `forest' and approaches to the meaning of the terms `afforestation', `reforestation', and `deforestation' (ARD). The choice of definitions will determine how much and which land in Annex I countries are included under the provisions of Article 3.3… . The amount of land included will have implications for the changes in carbon stocks accounted for under Article 3.3. [30]

Countries have defined forests and other wooded lands for a number of national and international purposes, in terms of: (i) legal, administrative, or cultural requirements; (ii) land use; (iii) canopy cover; or (iv) carbon density (essentially biomass density). Such definitions were not designed with the Kyoto Protocol in mind and, thus, they may not necessarily suffice for the particular needs of Articles 3.3 and 3.4. [31]

7.38 The difficulties of defining terms such as forests was illustrated to the Committee by Professor Graham Farquhar of the Cooperative Research Centre for Greenhouse Accounting:

If, for example, something that had 40 per cent [canopy] cover was called forest you could convert from 100 per cent cover down to 40 per cent cover and still have a forest. In taking that very strict definition the fear is that the Parties might not report the loss of carbon from forests. I am sure it was not the intent, but that is what people are debating about in terms of the usage of canopy covers and how it might play out if the people follow the letter rather than the spirit of the thing. [32]

7.39 The Special Report developed seven definitional scenarios, for lands that can be counted under Article 3.3, which combine different definitions of forests, and afforestation, deforestation, and reforestation. Each scenario reflecting the range of approaches that can be taken with them and an assessment of the implications. An example of some of the issues encountered include:

Definitions of a forest, which are often based on a single threshold of canopy cover or carbon density may allow increases or decreases in carbon to remain unaccounted due to aggradation or degradation. To minimise this possibility multiple or sequential thresholds, or national, regional or biome-specific thresholds could be used, or the issues of aggradation and degradation could be covered under Article 3.4… .

Some definitions of reforestation include the activity of regeneration after disturbance or harvesting, while disturbance or harvesting are not defined as deforestation. In these circumstances credits could be accounted for the regeneration without debits for disturbance or harvesting, this would lead to an accounting system where the changes in terrestrial carbon do not reflect the real changes in the atmosphere. [33]

7.40 Professor Farquhar advised the Committee that for Article 3.3 a key issue has been how to develop accurate and verifiable measures of changes in carbon stocks, particularly when some aspects such as soil carbon are difficult to measure:

… the accounting system has to be cost effective as well as accurate, consistent, comparable, verifiable and efficient to record and report changes in carbon stocks and changes in emissions from land us, land use change and forestry activities. There is a variety of research methods to help here - statistical analyses, forestry inventories, remote sensing techniques, flux measurements, soil sampling and ecological surveys. We note that those terms `afforestation' and `reforestation' will probably not be terribly important in accounting terms in the sense that they would get treated the same way. The difference would refer to the time before the actual act of planting trees since trees were there before. [34]

7.41 Article 3.3 refers only to those activities (afforestation, reforestation and deforestation) which have taken place since 1990. The actual measurement does not occur until the first commitment period (2008-2012). Professor Farquhar advised the Committee the way this would work is:

Under Article 3.3 one compares how much carbon is in an area affected directly by humans if there is a comparison between 2008 and 2012. In an area where there is deforestation, one looks at the carbon stock in 2008 and determines how much less there is in 2012, and there is a debit. In areas where there has been an activity since 1990 in terms of growing a new forest, one looks once again at the change in carbon stock between 2008 and 2012. So the change in stock is measured over the first movement period, 2008-2012, only for those activities that relate to the period since 1990.

Scientists would hope that there would be contiguous accounting periods because if you have a gap after 2012 before a second commitment period then all sorts of fun and games could go on if people were not following the spirit of the framework convention. I think most people agree that the second commitment period should be starting immediately in 2012. [35]

7.42 The interpretation of `activities' that may be included as additional activities under Article 3.4 have posed similar problems for the method of carbon accounting and separating human-induced changes from naturally induced changes.

7.43 The Climate Action Network Australia (CANA) [36] has referred to the Kyoto Protocol as an `accounting game' and expressed concern about when activities are reported under the Protocol and for how long. In reference to Article 3.4, Ms Anna Reynolds noted:

If it was an entire system where you counted what was happening in 1990 with crop land management, pasture management and forest management, and you actually accounted for it also in the end year, there would not be as much of a loophole. It is used as a way for your accounts to show all these debits while your emissions actually increase. And 3.4 was rushed through in the last few hours of the Kyoto Protocol negotiations. It was not really discussed. There was not much transparency about what it could do to country targets. So no-one's targets have really accounted for the potential growth in emissions they can gain if they include pasture management and soil tillage improvement. [37]

7.44 In their Report, the IPCC has stated that:

A well designed carbon accounting system would provide transparent, consistent, comparable, complete, accurate, verifiable, and efficient recording and reporting of changes in carbon stocks and/or changes in greenhouse gas emissions by sources and removals by sinks from applicable land use, land use change, and forestry activities and projects under relevant Articles of the Kyoto Protocol. [38]

7.45 The IPCC has identified two possible accounting approaches towards meeting these requirements, a land-based approach and an activity-based approach, either of which or a combination of the two could be adopted. There are further uncertainties that need to be taken into account at this point including: measurement uncertainty; uncertainties in identifying lands under Article 3.3 and 3.4; and defining and quantifying baselines if any. It has been suggested that the best way to deal with these uncertainties is by using good-practice guidelines or by adjusting the carbon stock changes to understate the increases and overstate the decreases. [39]

7.46 The potential management of wood products and the permanence of carbon sinks are further issues to be considered in carbon accounting. For example, if the management of wood products is treated as an additional activity under Article 3.4, then it may be necessary to exclude wood products from accounting under other Article 3.3 and 3.4 activities to avoid double counting.

7.47 The permanence of carbon sinks has been a key issue internationally, and in submissions and evidence put to this inquiry, in the debate on their use as a greenhouse response measure. The enhancement of carbon sinks is potentially reversible as a result of human activities, disturbances or environmental changes including climate change. The solution that has been put forward by the IPCC to deal with this possibility is to ensure that any credit for enhanced carbon stocks is balanced by accounting for any subsequent reductions in carbon stocks. [40] On the issue of permanence, Professor Farquhar noted that:

… the question has to be answered in two senses. It seems to me that from an accounting point of view it is not a problem, that is, you get debited if the sink is removed. From a national perspective, in terms of planning how a country meets its requirements, that is an issue that the countries will have to take note of. The underlying fear from some people might be that this might lead to inaction in other areas and that it all could come to a head if suddenly there were a climate change and all the forests were to burn down. I personally do not think that that is very likely. In the foreseeable future I see our ecosystems, as a whole, continuing to take up carbon dioxide. As the temperature rises we are likely to have impacts on those areas. I can see that there will be a threat to alpine ecosystems and so on, but I do not think that large scale impermanence is an issue. [41]

7.48 The Committee recognises the concerns raised by CANA regarding the permanence of sinks, and how they are accounted for under the Kyoto Protocol. The Committee also recognises that solutions have been put forward by Professor Farquhar and the IPCC that may address these concerns.

Greenhouse sinks and the Kyoto Protocol flexibility mechanisms

7.49 The potential inclusion of sink activities in the Kyoto Protocol flexibility mechanisms is also an area requiring resolution. Only the JI mechanism specifically allows for sinks, although it has been argued that Articles 3.1, 3.3 and 3.4 imply that credits from sink activities can also form part of Emissions Trading. Article 12 of the Kyoto Protocol, the CDM, does not explicitly refer to sinks and there is a strong push by a number of countries, including Australia, for their inclusion.

7.50 The Australian Government argues that the inclusion of sink activities in all three flexibility mechanisms is important to ensure that `the flexibility mechanisms are used to their full potential including delivery of maximum economic and environmental benefits and participation by a wide range of Parties'. [42]

7.51 Others such as CANA, have argued that the inclusion of sink activities in the flexibility mechanisms, in particular their inclusion in CDM, should be limited, citing issues of permanence, potential carbon `leakage', negative socioeconomic impacts, monitoring and verification and the potential impact their inclusion might have on action to reduce emissions at source. For example, Ms Carrie Sonneborn of the Australian Cooperative Research Centre for Renewable Energy, expressed the view that:

The flexibility mechanisms… can promote sinks to the detriment of investment in renewable energy, and it can also fail to deter extensive new fossil fuel developments such as natural gas. If it had to be a carbon - a fossil fuel - you would want it to be natural gas, that is for sure. … if the widespread establishment of renewables is delayed as a result of flexibility mechanisms, it could result, at a domestic level, in Australia losing out on market share because it does not invest in this new growth industry sufficiently. At an international level it could delay a shifting to sustainable energy and therefore the addressing of the global warming issue at its source. [43]

7.52 With the exception of the issue of delaying the shift to more renewable forms of energy, the IPCC Special Report has gone to some lengths to examine and provide options for dealing with the issues associated with the flexibility mechanisms and sinks. The Report notes that with the exception of permanence, these issues are not unique to land use change and forestry activities.

7.53 With regard to potential socioeconomic impacts, the Special Report examined current projects occurring under the auspices of activities implemented jointly. The Special Report notes that:

Pilot LULUCF [Land Use, Land Use Change and Forestry] projects that are designed to avoid emissions by reducing deforestation and forest degradation have produced marked environmental and socioeconomic co-benefits, including biodiversity conservation, protection of watershed and water resources, improved forest management and local capacity building, and employment in local enterprises. [44]

7.54 However, the Report also notes that:

Projects that are designed to protect natural forests from land conversion or degradation could pose significant costs to some stakeholders if they restrict options for alternative land uses such as crop production. Such costs might be mitigated, however, by siting projects in regions where conservation measures are consistent with regional land use policies and by promoting sustainable agricultural intensification on associated lands. [45]

7.55 The potential impact of projects that encourage afforestation through plantations are just as variable. For example, plantations can help maintain and improve soil properties and provide a source for biomass fuels and other wood products, but may also have negative impacts on biodiversity if replacing native grassland or woodland, and negative socioeconomic impacts if projects displace valuable agricultural land. [46]

7.56 The IPCC Special Report suggests that a `screening' test be applied to activities to ensure that projects do not have adverse socioeconomic or environmental effects and limiting the crediting of activities to those that pass such a test. The IPCC suggests that one option would be to adopt internationally recognised Environmental Impact Assessment standards and guidelines for carbon-offset projects. [47]

7.57 The Committee supports of the inclusion of sinks in the Kyoto Protocol flexibility mechanisms and is of the view that ultimately such activities will benefit developing nations to achieve sustainable development. However, the Committee also recognises the concerns of groups such as CANA, that sink activities may delay the shift to more sustainable forms of energy use, and may have negative socioeconomic and environmental impacts.

Australia's international negotiating position on greenhouse sinks and the Kyoto Protocol

7.58 The Australian Government undertook a consultation process earlier this year to inform people about the land use change and forestry issues currently under consideration in the international climate change negotiations; and to inform the development of Australia's international negotiating position on greenhouse sinks and the Kyoto Protocol. Through this process written submissions were sought on an Australian Greenhouse Office (AGO) issues paper titled Greenhouse Sinks and the Kyoto Protocol - An Issues Paper.

7.59 At the same time, the Federal and Western Australian Governments hosted a closed international forum on greenhouse sinks with representatives from 30 countries. There were no public reports arising from the forum which has led to criticism about its restrictive nature and perceptions amongst the conservation movement `that Australia is very clearly pushing an agenda of maximising the use of sinks under the Kyoto Protocol' [48] at the expense of real abatement action at source.

7.60 The conservation movement has expressed considerable concern about the provisions for sinks under the Kyoto Protocol due to their potential to be used as `loopholes'. As noted above, an area of particular concern to the conservation movement is the inclusion of additional sink activities under Article 3.4, arguing that it is `against the spirit of the Kyoto Protocol'. [49] In presenting evidence to the Committee the Australian Conservation Foundation (ACF) noted that:

The second issue in terms of continuing negotiations is 3.4 of the Kyoto Protocol which is on additional activities, which include a range of activities potentially involving agricultural practices and so on. The definitions of those have not yet been finalised. To give an example of the potential impact of those definitions, the University of Colorado prepared a report for the World Wildlife Fund. They found that, with a particular definition of additional activities, emissions in the United States could increase by 10 per cent and the US would still meet its Kyoto target. Basically, a minus seven target could be met, on paper, with no extra activities, just by including sinks. [50]

7.61 The World Wildlife Fund (WWF) put forward a similar view stating that land use change and forestry activities would create `loopholes' in national commitments:

The reason I used the somewhat pejorative term `loopholes' is that, because the detail of how this section could be used was left hanging, there is scope for the misuse of the land use change and forestry section to actually avoid actions to achieve the United Nations Framework Convention on Climate Change goal which is, of course, to reduce atmospheric concentrations of greenhouse gases. We have coined the phrase `carbon pardons' to describe these loopholes, because, essentially, many people are operating - and certainly many businesses are operating - very similarly to the Pardoner of Geoffrey Chaucer's time of selling pieces of paper giving absolution from climate sin with no real change to the actual activities going on. [51]

7.62 Following the release of the IPCC Special Report, and the conclusion of the Government's consultation process on sinks and the Kyoto Protocol, Australia recently (1 August 2000) put forward its submission to the UNFCCC on land use, land use change and forestry. The submission sets out Australia's views on how the sinks provisions (which includes afforestation, reforestation and deforestation in Article 3.3 and additional sinks activities under Article 3.4) should be implemented through decisions agreed at CoP 6.

7.63 In its 1 August submission, the Australian Government suggests that the key to implementing the land use, land use change and forestry provisions is the development of an overarching carbon accounting framework known as the `Article 3.3/3.4 lands accounting approach'. The Article 3.3/3.4 lands accounting approach refers to land-based accounting which is directly linked to specific, eligible land use, land use change and forestry activities. Australia argues that the benefits of this approach are that it:

• provides a coherent framework for reporting eligible Article 3 activities;
• facilitates consistent and robust estimates of all relevant carbon pools;
• simplifies measurement and carbon accounting by removing the need to separate out emissions associated with human-induced processes (harvesting and replanting cycles) from natural processes (fire, CO2 fertilisation); and
• ensures that measurement of changes in carbon stock and/or greenhouse gas emissions are in line with key requirements of the Protocol.

7.64 Key requirements for land use, land use change and forestry activities in the first commitment period include that:

• the activity is directly human-induced, or human-induced;
• the activity took place since 1990;
• measurement of changes in carbon stock or greenhouse gas emissions as a result of the activity is verifiable and transparent; and
• measurement uncertainties are taken into account.

7.65 The Government's submission supports a set of definitions and rules for eligible Article 3.3 sink activities (afforestation, reforestation and deforestation) that they argue:

• reflect Australia's diverse national forest estate;
• winds elements of a definition of a forest into the definitions for afforestation, reforestation and deforestation;
• requires a change in land use for afforestation and reforestation activities, for example establishment of a plantation on land cleared for agricultural purposes, but does not apply a strict land use change test for deforestation, although harvesting is explicitly excluded (this is because the harvesting cycle is assumed to be in balance); and
• are consistent with the 1996 IPCC Revised Inventory Guidelines which govern monitoring and reporting for the first commitment period (Article 5.2). [52]

7.66 The Australian submission supports a narrow approach to the selection of additional activities under Article 3.4 in conjunction with land-based accounting and argues strongly for the inclusion of revegetation activities including:

• the establishment of woody vegetation to address sustainable land management;
• windbreaks and shelterbelts;
• environmental plantings or fencing off areas of native vegetation;
• agroforestry planting of trees or the development of new tree crops, such as tea tree oil, to encourage a more diversified and sustainable production system that leads to social, economic and environmental benefit for land users; and
• changes in stock management practices to encourage regeneration of vegetation. [53]

7.67 The submission does, however, leave open the question of further additional activities being put forward for inclusion, noting that Australia is working on methodologies to account for additional activities in the agricultural soils and forest management categories (including wood products). [54]

7.68 The Committee accepts that many of the issues surrounding the practical implementation and resolution of the inclusion of sinks in the Kyoto Protocol are highly technical in nature. However, in the Committee's view the Government can take greater steps to clarify and explain its position. A step in this direction would be public reporting of the outcomes of the Perth Sinks Forum. The Committee is concerned at continued perceptions of Australia attempting to maximise potential loopholes in these aspects of the Kyoto Protocol. While it is unclear that this is the case, the strength of these perceptions cannot be overlooked.

7.69 The Committee acknowledges that it is in the best interests of all Parties to the Kyoto Protocol to reach resolution on the inclusion of sinks in the Protocol, as soon as possible, to provide for greater certainty and facilitate ratification of the Protocol. However, the Committee is concerned that aspects of the science are still highly uncertain and the potential for loopholes to be exploited through the accounting system remain.

Recommendation 66

The Committee recommends that the approach taken by the Government to international negotiations on the inclusion of sinks should be based on the following principles:

• that sinks activity in the Clean Development Mechanism should be consistent with the principles of ecological sustainability and that appropriate project guidelines be included to minimise potential adverse socioeconomic and environmental impacts;
• the sinks activity in the Clean Development Mechanism should complement other activities to reduce emissions at source;
• that the credibility of the use of sinks relies on the credible, verifiable, and transparent recording and reporting of changes in carbon stocks and/or changes in greenhouse gas emissions by sources and removals by sinks;
• that sink activities undertaken for climate change mitigation purposes should not result in native forests being cleared to establish plantations; and
• that it is desirable for the second commitment period to start immediately after the first commitment so that reporting on sink activities is contiguous.

Accounting for the Carbon Domestically

7.70 The need for a credible, transparent and verifiable process for accounting in the land use change and forestry sector internationally and domestically has been acknowledged and called for by governments and interest groups alike. As part of the Prime Minister's 1997 Statement: Safeguarding the Future: Australia's Response to Climate Change, the establishment of a NCAS for Land Based Sources and Sinks was announced at a projected cost of $12.5 million. The Commonwealth submission to the inquiry notes that:

Australia's greenhouse gas performance can only be measured through careful monitoring of sources and sinks. Reduction in uncertainty of current emissions estimations particularly the Land Use Change and Forestry sector, is essential as it is likely to form the basis for assessing emissions trends, abatement performance and compliance to commitments under the Kyoto Protocol.

The National Carbon Accounting System (NCAS), announced by the Commonwealth in 1997 with funding of $12.5 million, aims to provide a complete accounting and forecasting capability for human-induced sources and sinks of greenhouse gas emissions from Australian land-based systems. The CRC for Greenhouse Accounting, supported by the AGO will assist in developing the fundamental science that underpins NCAS. [55]

7.71 In presenting evidence to the inquiry, the AGO noted that:

We certainly would agree we need an internationally credible and transparent process of accounting in land use change and forestry. I think you will find that the approach that was commenced with our National Greenhouse Gas Inventory and is now flowing through to the National Carbon Accounting System does do that. There is a very strong focus on scientific excellence in terms of developing the approach through essentially workshopping and involving, through other devices, a whole range of expert input and review. For example, the draft implementation plan for the 1990 emissions baseline underwent an international scientific review amongst a good number of the world's leading scientists late last year. We have published that international review report and it is going on to our web site. We will basically continue that process and I think we have in place the arrangements to do that.

We do expect that the international review provisions that will go with the compliance regime for the Kyoto Protocol will involve international scrutiny of all countries' national systems accounting for emissions and sinks, including land use change in forestry. Australia is taking a very active part in beginning to develop the international guidelines and codes for that. For example, Australia hosted the final expert workshop for IPCC good practice guidance provisions in Sydney last week. We have been actively supporting that and we will be actively supporting the good practice guidance work that will follow specifically on land use change and forestry. [56]

7.72 It is the Government's intent that the National Carbon Accounting System (NCAS) will:

• reduce scientific uncertainties surrounding land-based estimates of emissions and sinks in the Australian context;
• provide the scientific and technical basis for international reporting under the UNFCCC and the Kyoto Protocol;
• provide a basis for emissions projections to assess progress towards meeting international emissions reduction targets;
• support emissions trading discussions; and
• underpin international negotiations on greenhouse sink activities. [57]

7.73 Clarifying the 1990 baseline is a critical issue for Australia as, at present, there is considerable uncertainty over what Australia's target of 108 per cent means in terms of actual megatonnes of emissions. This uncertainty is largely due to the uncertainty of emissions from the land use change and forestry sector, in particular land clearing. The first priority of NCAS is to provide the information to refine estimates of Australia's 1990 baseline. The work that is currently being undertaken to support this is focused on:

• area and location of land cover change;
• biomass of the vegetation and carbon content of plant components - such as leaves, roots and stems;
• effects of different land use and agricultural practices;
• the decay rate of wood products - such as furniture, woodframes and paper; and
• refinement of data and models to track these changes. [58]

7.74 Ms Gwen Andrews, Chief Executive of the AGO notified the inquiry that this work should be completed around the middle of 2001.

7.75 CANA put the view that `further independent (non-government) research is needed to quantify and monitor land use and forestry roles in carbon sequestration and climate change strategies'. [59] The Wilderness Society submission states that `the controversy surrounding the use of biospheric carbon stores and sinks would be substantially mitigated by the establishment of an independent (from government and industry), resourced, scientific body whose tasks would be to refine the science and develop the reporting, monitoring and compliance rules to allow any role of land use change and forestry to be creditable'. [60]

7.76 This in part stems from a view that:

Current government policy is to allow substantial increases in domestic industrial emissions and meet the Kyoto target `on paper' with off-setting mechanisms. This will require creative accounting that gives the impression of reductions while in reality the planet's atmosphere is left with more greenhouse gases not less. The main tools to achieve this at a domestic level will be land use change, emissions trading, and sinks (tree planting) schemes. [61]

7.77 Given the work of the NCAS and the CRC for Greenhouse Accounting, Australia is well placed to meet the reporting requirements of the Kyoto Protocol and provide greater certainty on the emissions from land use, land use change and forestry. In the interest of transparency, greater steps could be taken by the Government to remove the `black box' of accounting by involving a broader range of non-government stakeholders in discussions on the work taking place and ensuring the results of peer review are publicly reported.

Recommendation 67

The Committee recommends that regular briefings for all stakeholders are held on the progress of the National Carbon Accounting System and the outcomes of work as it is finalised.

(Chapter 7 - Part b)

(Chapter 7 - Part c)

 

Footnotes

[1] Watson et al (Eds), Land Use, Land-Use Change and Forestry: A Special report of the IPCC, Cambridge University Press, 2000, p 327.

[2] Australian Greenhouse Office, National Emissions Trading: Crediting the carbon, Discussion Paper No. 3, 1999, p 12.

[3] Sequestration is the process of removing carbon dioxide from the atmosphere and retaining it in a carbon sink such as a forest.

[4] A sink is defined as a process, activity or mechanism, which removes a greenhouse gas, an aerosol, or a precursor of a greenhouse gas from the atmosphere.

[5] Australian Greenhouse Office, National Emissions Trading: Crediting the carbon, Discussion Paper No. 3, 1999, p 13.

[6] Intergovernmental Panel on Climate Change, Summary for Policy Makers: Land Use, Land-Use Change, and Forestry, Canada, 2000, p 5.

[7] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, 2000, p A-28.

[8] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 7, Forestry and Land Clearing, 2000.

[9] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 7, Forestry and Land Clearing, 2000.

[10] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, 2000, p A-28.

[11] Australia's Second National Report under the United Nations Framework Convention on Climate Change, November 1997, p 6.

[12] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 7, Forestry and Land Clearing, 2000.

[13] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 7, Forestry and Land Clearing, 2000.

[14] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 7, Forestry and Land Clearing, 2000.

[15] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 7, Forestry and Land Clearing, 2000.

[16] Australian Greenhouse Office, National Greenhouse Gas Inventory Land Use Change and Forestry Sector 1990 to 1998, 2000, p A-3.

[17] Australian Greenhouse Office, National Greenhouse Gas Inventory Land Use Change and Forestry Sector 1990 to 1998, 2000, p A-5.

[18] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 4, Agriculture, 2000.

[19] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 4, Agriculture, 2000; and Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, 2000, p A-26.

[20] Australia's Second National Report under the United Nations Framework Convention on Climate Change, November 1997, p 6.

[21] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, 2000, p A-23.

[22] Australian Greenhouse Office, National Greenhouse Gas Inventory 1998, Fact Sheet 4, Agriculture, 2000.

[23] Australian Greenhouse Office, The National Greenhouse Strategy: Strategic Framework for Advancing Australia's Greenhouse Response, 1998, p 101.

[24] Australian Greenhouse Office, The National Greenhouse Strategy: Strategic Framework for Advancing Australia's Greenhouse Response, 1998, p 101.

[25] Australian Greenhouse Office, Greenhouse Sinks and the Kyoto Protocol: An Issues Paper, 2000, pp 2-3.

[26] Senator, the Hon Robert Hill, Bush for Greenhouse Open for Business, Australian Greenhouse Office, Media Release, April 13 2000, p 1.

[27] Southern Pacific Petroleum and Central Pacific Minerals, Submission 172, p 1749.

[28] Official Committee Hansard, Canberra, 9 March 2000, p 3.

[29] The Kyoto Protocol to the Convention on Climate Change.

[30] Intergovernmental Panel on Climate Change, Summary for Policy Makers: Land Use, Land-Use Change, and Forestry, Canada, 2000, p 5.

[31] Intergovernmental Panel on Climate Change, Summary for Policy Makers: Land Use, Land-Use Change, and Forestry, 2000, p 5.

[32] Proof Committee Hansard, Canberra, 6 September 2000, p 919.

[33] Robert T Watson, Chair of the IPCC, A Report on the Key Findings from the IPCC Special Report on Land Use, Land-Use Change and Forestry, 12th session of SBSTA, Bonn, Germany, 13 June 2000.

[34] Proof Committee Hansard, Canberra, 6 September 2000, p 921.

[35] Proof Committee Hansard, Canberra, 6 September 2000, p 921.

[36] The Climate Action Network Australia is comprised of the following organisations: Australian Conservation Foundation; Community Information Project on Sustainable Energy; Conservation Council of South East Region and Canberra; Environment Victoria; Friends of the Earth; Greenpeace Australia; Queensland Conservation Council; Sunshine Coast Environment Council; Total Environment Centre; World Wide Fund for Nature (Australia); Conservation Council of Western Australia; Urban Ecology, South Australia; New South Wales Nature Conservation Council; AidWatch; Pacific Bioweb; North Queensland Conservation Council; Institute for Sustainability and technology Policy; Tasmanian Conservation Trust; Institute for Sustainable Futures; Northern Territory Environment Centre; and Centre for Education Research in Environmental Strategies (CERES).

[37] Official Committee Hansard, Canberra, 10 March 2000, p 48.

[38] Intergovernmental Panel on Climate Change, Summary for Policy Makers: Land Use, Land-Use Change, and Forestry, Canada, 2000, p 8.

[39] Intergovernmental Panel on Climate Change, Summary for Policy Makers: Land Use, Land-Use Change, and Forestry, Canada, 2000, p 9.

[40] Intergovernmental Panel on Climate Change, Summary for Policy Makers: Land Use, Land-Use Change, and Forestry, Canada, 2000, p 9.

[41] Proof Committee Hansard, Canberra, 6 September 2000, p 928.

[42] Australian Greenhouse Office, Greenhouse Sinks and the Kyoto Protocol: An Issues Paper, 2000, p 90.

[43] Proof Committee Hansard, Perth, 17 April 2000, p 537.

[44] Watson et al (Eds), Land Use, Land-Use Change and Forestry: A Special Report of the IPCC, Cambridge University Press, 2000, p 327.

[45] Watson et al (Eds), Land Use, Land-Use Change and Forestry: A Special Report of the IPCC, Cambridge University Press, 2000, p 327.

[46] Watson et al (Eds) Land Use, Land-Use Change and Forestry: A Special Report of the IPCC, Cambridge University Press, 2000, pp 327-28.

[47] Watson et al (Eds), Land Use, Land-Use Change and Forestry: A Special Report of the IPCC, Cambridge University Press, 2000, pp 115-18.

[48] Mr Shane Rattenbury, Proof Committee Hansard, 23 June 2000, Canberra, p 757.

[49] Climate Action Network Australia, Submission 193, p 2035.

[50] Mr Van Rood, Official Committee Hansard, Melbourne, 21 March 2000, p 195.

[51] Mr Michael Rae, Official Committee Hansard, Sydney, 23 March 2000, p 440.

[52] Australian submission to the UNFCCC on Land Use, Land-Use Change and Forestry - 1 August 2000: Implementation of Articles 3.3 and 3.4 of the Kyoto Protocol, pp 1-3.

[53] Australian submission to the UNFCCC on Land Use, Land-Use Change and Forestry - 1 August 2000: Implementation of Articles 3.3 and 3.4 of the Kyoto Protocol, pp 1-3.

[54] Australian submission to the UNFCCC on Land Use, Land-Use Change and Forestry - 1 August 2000: Implementation of Articles 3.3 and 3.4 of the Kyoto Protocol, p 13.

[55] Australian Greenhouse Office on behalf of the Commonwealth Government, Submission 169, p 1700.

[56] Official Committee Hansard, Canberra, 9 March 2000, p 23.

[57] Greenhouse notes: Information from the Australian Greenhouse Office, No 16: National Carbon Accounting System, December 1999.

[58] Greenhouse notes: Information from the Australian Greenhouse Office, No 16: National Carbon Accounting System, December 1999.

[59] Climate Action Network Australia, Submission 193, p 2036.

[60] The Wilderness Society, Submission 178, pp 1844-45.

[61] Climate Action Network Australia, Submission 193, p 2037-38.