- You may no longer be additional. Whereas the CFI made classes of projects that were okay – like savanna burning – the ERF introduces new project tests: the project must not have started and be unlikely to be carried out under another government program. Now say you have a ranger group which is undertaking burning under an Indigenous Protected Area management plan. Has the project started? Would it happen anyway? The answer may be no and no. But we don’t yet know if these kind of savanna activities could be threatened as projects.
- If you are killing camels, you are out. Under the new ERF rules, non-Kyoto projects such as feral animal management and blue carbon projects in the sea are out (although, curiously, the ERF would extend coverage to Australia’s exclusive economic zone in the sea). Aboriginal lands are chock full of camels, buffalo, pigs and horses – all with emissions profiles. Seagrass meadows also have huge potential to realise carbon savings. But not under the ERF.
- You can only bid once. That’s right, your project might remain additional but you can only get one 5 year contract. So even if you invest to upgrade your land management capacity to take on a land sector project and manage to win a contract, there’s only 5 years of certainty. On top of that, you can only get one crediting period, so you can’t even get credits and sell them in the voluntary market. Something else may follow in 5 years, but what will that be? If savanna burning stops, the emissions savings stop.
- If things go bad, you still have to cough up ('make good'). Your contract will insist on the abatement you must provide over 5 years. So if you have a bad fire season in the last year and abatement is down, you will have to dip into your own pocket to deliver the abatement. This is not so attractive if the carbon credits are just part of your income to carry out these activities. To cover this risk, projects are likely to underbid abatement.
- There’s not too much money to go around. ERF funding has been reduced to $1.1b over the next 4 years because contracts will only be paid on delivery. For example, there’s only $76m allocated for the first year. This smaller pool means that some large industrial projects scoop the pool, there might not be much left for the land sector.