Associate Professor (Honorary) Cris Brack from the Australian National University conducts regular independent reviews of human-induced regeneration (HIR) gateway checks. This is the December 2024 review report.
Summary
Associate Professor (Honorary) Cris Brack has completed his second report for 2024. This is his third report, overall.
The report analysed 33 human-induced regeneration projects, including 18 projects reported on in August 2024.
It confirms the Clean Energy Regulator’s (CER) assessment of the HIR project gateway checks, using multiple lines of evidence, remains robust. Key findings include:
- The CER continues to use multiple data sources and requires proponents to provide more evidence to show regeneration when there are discrepancies between the CER’s checks and the proponent’s data before a regeneration check is accepted.
- The independent audit reports and the CER’s assessments of project data continue to provide strong assurance that HIR projects are being managed appropriately.
- Appropriate procedures have been used by the proponents and their agents in classifying the carbon estimation areas (CEAs) and identifying changes in regenerating cover.
The report also finds that re-stratification of CEAs is key to the integrity of the HIR portfolio and to ensure only regenerating CEAs are issued ACCUs.
- Project proponents generally re-stratify CEAs as part of the regeneration check and remove parts of CEAs that have not achieved the minimum canopy cover.
- Independent checks by qualified auditors confirm good practice techniques were used, and strata boundaries were reliable.
- Gateway audits confirm that project proponent’s strata boundaries are more reliable than when using national-scale models. However, minor issues about potential regeneration areas identified during site visits will be reviewed by CER and will potentially be removed by the next reporting period.
The report further supports Assoc Prof Brack’s earlier findings that only using national-scale models of tree cover is unreliable for many projects, particularly in Western Australia.
- Field measurement observations conducted by independent auditors and ecologists under the expanded s215 audits confirm that proponents’ stratifications are significantly more accurate than the national-scale models.
- The CER used hundreds of georeferenced photographs and in-situ measurements to confirm regeneration thresholds were being met when national-scale models suggested unsuccessful regeneration.
- An increased focus on objectively located, field-based measurements and georeferenced photographs is required until national-scale models of tree cover become more reliable for large HIR projects.
This independent review provides further confidence in the ACCU Scheme and the integrity of the HIR project portfolio.