Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....

Design of the Carbon Farming Initiative




This submission template should be used to provide comments on the consultation paper outlining the proposed design of the Carbon Farming Initiative.

Contact Details

Name of Organisation: Friends of Grasslands

Name of Author: Geoff Robertson

Phone Number:






All submissions will be treated as public documents, unless the author of the submission clearly indicates the contrary by marking all or part of the submission as 'confidential'. Public submissions may be published in full on the Department of Climate Change and Energy Efficiency website, including any personal information of authors and/or other third parties contained in the submission. If any part of the submission should be treated as confidential then please provide two versions of the submission, one with the confidential information removed for publication.


A request made under the Freedom of Information Act 1982 for access to a submission marked confidential will be determined in accordance with that Act.


Do you want this submission to be treated as confidential?           Yes                X  No


Submission Instructions

Submissions should be made by close of business 21 January 2011. The Department reserves the right not to consider late submissions.


Where possible, submissions should be lodged electronically, preferably in Microsoft Word or other text based formats, via the email address –


Submissions may alternatively be sent to the postal address below to arrive by the due date.


Emerging Policy Section, Land Division
Department of Climate Change and Energy Efficiency
GPO Box 854



Regional Communities, Water and Biodiversity


FOG is a community group dedicated to the conservation of natural grassy ecosystems in south-eastern Australia. FOG is concerned that there may be indirect negative impacts on grassy ecosystems from carbon farming if there is a financial incentive to plant trees to gain incentives for the sequestration of carbon in natural grasslands, which would be at the expense of the natural biodiversity. While it could be argued that these issues are covered by other regulatory measures, such as environmental impact assessment and native vegetation conservation laws, in fact the application of these on the ground is at times less than ideal. Native dominated grasslands that are somewhat degraded and therefore do not contain the threatened communities also have biodiversity values, often providing habitat for a range of native species. These would have no protection against tree planting under current legislation. To the best of FOG’s knowledge, we do not know how much carbon is sequestered in different Australian ecosystems, and in ecosystems in different states of health, including native grasslands. Overseas research suggests that native grasslands are good for sequestration. FOG is also concerned that biochar and other interventions in solid management could impact negatively on native grasslands, both by direct disturbance and by changes in soil chemistry and hydrology.


Our view is that the Commonwealth should institute a national regulatory regime alongside the proposed carbon farming system.  In particular, FOG asks that the government scheme and legislation:


a) Provides credits for restoration of natural grassy ecosystems; 


b) Refuses credits that involve modification or conversion of natural grasslands or grassy woodlands (or any other 'natural' ecosystem) through alterations to soils or biologically negative changes in species composition;


c) Emphasises that projects that may impact on Matters of National Environmental Significance require environmental impact assessment under the Federal EPBC Act (in this context, the Commonwealth has direct responsibility to protect grassy ecosystems and species as they are listed under the EPBC Act); and


d) Refuses credits that involve planting species not indigenous to the site and not in common agricultural or forestry use in Australia so as to avoid widespread planting of known and emerging weed species (e.g. species such as Desert Ash or Chinese Pistachio have the potential to become weeds around the Southern Tablelands).


e) Instigate research in Australia to clarify the sequestration levels across a diverse range of ecosystems so that we know the implications of proposed carbon farming schemes, and in particular the impact of different ecosystems (including native grasslands) on carbon sequestration.





The initiative provides carbon credits to those who come up with new schemes to sequester carbon but fails to provide such credits to those already doing this on a voluntary basis. In the longer term all non government entities who sequester carbon should be paid for this service. In particular, those who have already acquired land and are managing it for conservation (with or without a voluntary conservation agreement), or who have been preventing from developing land through native vegetation legislation already managing land for biodiversity and carbon sequestration. However, this initiative would not apply to them (and therefore they cannot benefit from it). In particular, take the case of two neighbours, one who has been ploughing, burning stubble and grazing his/her land, and the other who has currently foregone such practices. The first decides to adopts his neighbour's behaviour and is rewarded through carbon credits, but the second model neighbour isn't. We suggest that private conservation properties could be included in such an initiative where it is obvious that there is an alternative agricultural or forestry use for the land. This could even include lands protected by the native vegetation legislation where conservation management is taking place to protect threatened communities, or threatened species habitat, or native vegetation generally.


Any additional comments


FOG is concerned about the relationship between carbon sequestration and burning undertaken for conservation purposes. While ecological burning is not ruled out by the document, we are concerned that such burning may, over time, be seen as a less desirable action in conservation areas. In many ecosystems burning can assist in the maintenance of habitat and species diversity. In relation to grasslands and grassy woodlands, biomass control is required, but we currently do not understand the benefits of burning compared to, say, mowing and removal of grass and capture of gases. Burning may stimulate some ecological benefits in grasslands as well as other ecosystems. Allowance for the use of appropriate ecological burns in conservation areas (including areas identified for carbon sequestration) needs to be clearly stated and kept as a principle into the future.