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Transferring your project to the 2018 savanna fire management methods

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29 November 2018

Emissions Reduction Fund projects registered under savanna fire management methods may apply to transfer to the savanna fire management emissions avoidance 2018 or savanna fire management sequestration and emissions avoidance 2018 methods (2018 savanna fire management methods). Projects cannot transfer to or between revoked methods.

Contents

Key considerations for transferring projects

Proponents transferring projects to the new methods should consider the following:

  • Project Baseline periods for transferring projects under an existing method remain the same under the new method (see section 26 of both methods)
  • the first year reported on under the new method must immediately follow the last year reported on under the previous method
  • vegetation fuel type maps created and validated under an existing method can be used under the new methods, but may need to be updated (see section 27 of both methods, and the Savanna Technical Guidance Document), and
  • gamba grass must be excluded from project areas under the 2018 savanna fire management methods. If existing project areas contain gamba grass, there are two ways it can be removed. Please see the 2018 savanna fire management method pages for more information (emissions avoidance, sequestration and emissions avoidance).

Projects applying to transfer to the sequestration and emissions avoidance method will:

  • need to obtain consents from eligible interest-holders before applying to transfer, and
  • be subject to 25 or 100 year permanence obligations.

How to transfer

The following sections explain the processes that project proponents must follow if choosing to transfer savanna fire management projects or project areas to the 2018 savanna fire management methods. This guidance does not supersede the legislative requirements for projects under these methods.

Emissions avoidance to the sequestration and emissions avoidance method

Proponents may apply to transfer projects or project areas from any emissions avoidance savanna fire management method (including the revoked methods and the 2018 emissions avoidance method) to the savanna fire management sequestration and emissions avoidance method. This must be done through one of two processes under the Carbon Credits (Carbon Farming Initiative) Rule 2015 (the Rule). Projects who transfer to the sequestration and emissions avoidance method within five years of it being made (by April 2023) will have a new 25 year crediting period for their project. If transferring after this period, the crediting period will be 25 years minus the number of years reported on while under previous methods.

Transferring an entire project

If proponents wish to transfer an entire project to the sequestration and emissions avoidance method, they must follow the process detailed under section 30A of the Rule. The original project registered under an emissions avoidance method will be revoked and a new project registered and declared eligible under the sequestration and emissions avoidance method. The project area/areas in the original project must be identical to those included in the new project.

To initiate this process, proponents must submit a request for a transfer under section 30A, along with:

  • a revocation application for the original project,
  • a registration application for the new project,
  • a statement that they only want the original project to be revoked if the new project is registered and will be declared eligible, and
  • evidence that all eligible interest holders have consented to the application for the new project.

The following requirements apply to transfers under section 30A:

  • the application for revocation of the original project and declaration of the new project must be received in the manner detailed immediately above
  • the first year reported on under the new project must immediately follow the last year reported on under the original project
  • for the Clean Energy Regulator to register and declare the new project eligible, the following must have been completed in relation to the original project:
    • an offsets report covering for the most recent full calendar year must have been submitted,
    • certificate of entitlement relating to that offsets report must have been submitted,
    • all Australian carbon credit units relating to that certificate of entitlement for that offsets report must have been issued, and
    • there must be sufficient time remaining in the calendar year in order to declare the project before 1 December.

In order to satisfy these requirements, we recommend that proponents begin their transfer process as early as practicable in the relevant calendar year, and be aware of the Clean Energy Regulator's average and legislative processing times for applications.

For more information, please see the Rule.

Transferring part of a project

If proponents wish to transfer part of a project to the sequestration and emissions avoidance method, they must follow a process detailed under section 30B of the Rule.

If or once a project is registered under the 2018 emissions avoidance method, proponents may apply to subdivide their project area/areas into areas which they wish to move to the sequestration and emissions avoidance method, and those they wish to keep under the 2018 emissions avoidance method (section 15 of the method). Once the project area(s) have been appropriately subdivided, proponents may submit a request to transfer the project area(s) to the 2018 sequestration and emissions avoidance method under section 30B of the Rule, including:

  • a variation application for the original project
  • a registration application for the new project
  • a statement that they only want the original project to be varied if the new project is registered and will be declared eligible, and
  • evidence that all eligible interest holders in the project area of the new project have consented to the application for the new project.

The project area or areas elected for removal from the original project must be identical to those included in the new project.

Additional requirements for declaration under the s30B process include:

  • the application for variation of the original project and declaration of the new project must be received in the manner detailed above
  • the first year reported on under the new project must immediately follow the last year the relevant areas were reported on under the original project
  • for the Clean Energy Regulator to register and declare the new project eligible, the following must have been completed in relation to the relevant areas in the original project:
    • an offsets report covering for the most recent full calendar year must have been submitted
    • certificate of entitlement relating to that offsets report must have been submitted,
    • all Australian carbon credit units relating to that certificate of entitlement must have been issued, and
    • there must be sufficient time remaining in the calendar year in order to declare the project before 1 December.

In order to satisfy these requirements, we recommend that proponents begin their transfer process as early as practicable in the relevant calendar year, and be aware of the Clean Energy Regulator's average and legislative processing times for applications.

For more information, please see the Rule.

Revoked emissions avoidance methods to the 2018 emissions avoidance method

A project may apply to transfer from revoked methods i.e. any method prior to the 2018 methods to the 2018 savanna fire management emissions avoidance method under section 128 of the Carbon Credits (Carbon Farming Initiative) Act 2011 (the Act).

Projects transferring under section 128 of the Act must submit a method variation application. The change will apply from the start of the current reporting period. If transferring from a cancelled or revoked method, projects will not be able to return to their original method after transferring to the 2018 emissions avoidance method.

Once transferred to the 2018 emissions avoidance method, the project's crediting period will be 25 years minus the number of years reported on while under previous methods.

Sequestration and emissions avoidance to the 2018 emissions avoidance method

A project or project areas registered under the savanna fire management sequestration and emissions avoidance method (2018) can transfer to the savanna fire management emissions avoidance method (2018). For this to occur the original project will need to be revoked or varied (if only transferring part of a project), and all relevant Australian carbon credit units relinquished. A new project may then be registered and able to be declared eligible under the 2018 emissions avoidance method if the last calendar year reported on under the previous project and the first reported on under the new project are consecutive. The new project's crediting period will be 25 years minus the number of years reported on while under previous methods.

Clean Energy Regulator requirements

Proponents wishing to transfer from the sequestration and emissions avoidance method to the 2018 emissions avoidance method must submit both their revocation/variation application and the registration application (including relevant information required by section 13 of the 2018 emissions avoidance method) simultaneously.

The Clean Energy Regulator will not proceed with either application unless:

  • the proponent has submitted an offsets report for the original project including all relevant project areas that covers the most recent full calendar year, and
  • there is time to declare the new project eligible before 1 December.

These requirements limit the possibility of land becoming ineligible for inclusion in projects under both 2018 savanna fire management methods.

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