Independent review of gateway checks July 2025

This report adds to the series of independent reviews conducted by Associate Professor (Honorary) Cris Brack of the process and outcomes of human-induced regeneration (HIR) gateway checks that began in 2023. 

Regeneration checks require proponents to demonstrate at 5-yearly intervals that regenerating vegetation within their project’s carbon estimation areas (CEAs) are increasing in canopy cover against relevant thresholds.

Since his last report in December 2024, Assoc Prof Brack has reviewed an additional 16 projects that have completed HIR regeneration gateway checks.

With this new report, Assoc Prof Brack has now independently reviewed 75 projects that have passed HIR regeneration gateway checks. This represents over a quarter of reporting projects under the HIR method.

Summary of findings

Assoc Prof Brack’s analysis of data provided in 2025 confirms these conclusions from his 2024 reports:

• Strong assurance that projects are being managed according to HIR requirements, as provided by:
  • independent audit reports
  • reviews by the Clean Energy Regulator (CER), which continue to appropriately use multiple sources of data to check whether regeneration thresholds at relevant scales are being met
  • new s215 audits.
• Through expanded s215 audits, ecologists/foresters have identified areas that do not show sufficient regeneration. While the overall projects' stratification meets the HIR guidelines for classification accuracy, proponents must review these areas and potentially remove them before the next reporting period.
• Proponents or their agents used appropriate methods to classify CEAs and confirm regeneration canopy cover is meeting threshold levels.
• Proponents or their agents have stratified project areas into CEAs that result in an acceptable accuracy rate and meet good practice requirements.
• National-scale models of tree cover:
  • are unreliable for CEA evaluation in substantial areas, especially in Western Australia
  • tend to significantly underestimate the canopy cover in CEAs
  • present substantive discrepancies from the high-resolution data provided by proponents. This means many proponents need to provide significant additional evidence, such as field surveys and geo-located photographs, in support of the regeneration check.