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���Will the Integrated Farm and Land Management Method (as currently drafted) benefit �Indigenous people���Jarrad Holmes�Independent advisor��

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The Integrated Farm and Land Management (IFLM) Method that is currently under development by the Australian Government is complicated.

The one Method is attempting to:

    • Cover large parts of Australia, across all climatic zones, from the desert to the wet tropics

    • Cover off on a wide variety of very different management activities

    • Use different approaches to carbon accounting (existing (FullCAM) and new (direct measurement & scaled up))

But is this Method even going to be applicable on the Indigenous estate?

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Legally recognised Indigenous rights and interests (carbon and nature repair) (ICIN 2023)

Map available on Seamap Australia website

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Key stats regarding Indigenous rights and interests

  • 28% of the Australian land mass is identified as having indigenous legal right (Class 1). Notably, 76% of these Class 1 lands occur outside of the Savanna, and the majority of this is not pastoral land (important for IFLM discussion).
  • A further 29% of lands are identified as having Indigenous EIH consent requirements (Classes 2 and 3).
  • Therefore, Indigenous people have legally recognised rights in relation to carbon (and nature repair) across 58% of the Australian land mass (Classes 1, 2 and 3)
  • In regards to Blue Carbon, Indigenous people have legally recognised interests (Classes 1, 2 and 3) along 66% of the Australian coastline (land adjoining sea) (39% is Class 1).

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    • Of the >1,500 ACCU Scheme land sector projects that are currently active (not revoked), approx. 39 are Indigenous owned and operated with only 4 of these occurring outside of the savanna.

    • Very few of the >1,500 ACCU Scheme non-Indigenous led projects have received Indigenous EIH Consent (note – not all of these projects require Indigenous EIH consent).

    • Outside the coverage of the SFM Method, the ACCU Scheme has delivered relatively little benefit to Indigenous people to date.

Despite strong Indigenous rights and interests across Australia

Maps above taken from ICIN 2022 Report.

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Why so few Indigenous projects outside of the Savanna:

    • Not all of Australia is well suited to a carbon projects. Therefore there will be some areas of the Indigenous estate where carbon is not going to be a good option.
      • It is important that other markets, such as Nature Repair, are applicable to the entire Indigenous estate. Collectively, we need to ensure that Indigenous groups who are excluded from being able to participate in the carbon market are not also excluded from the Nature Repair market.

    • Lack of suitable Methods - Methods are the ‘doorway to the market’, if there is no method that can be applied to an area, then land managers are effectively excluded from being able to participate.

“Despite having extensive land interests across Australia, there is a concerningly low level of intersection between strong Indigenous land interests, and suitable ERF methods. Most areas where Indigenous people hold a legal right to undertake a carbon project, have no suitable ERF method.” (ICIN 2022 Report)

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ICIN 2022 identified 3 priorities for ACCU Scheme Method development to enhance opportunities for Indigenous participation under the Scheme.

1: Expanding the Blue Carbon Method beyond the Agricultural Zone

“Expanding the Blue Carbon Method to include new and additional eligible activities that are more suited to areas within or immediately adjacent to the Indigenous estate will be important if this activity is to be relevant to most coastal Indigenous land holders”.

Status – Feral ungulates in coastal wetlands research project underway.

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2: Expansion of the Savanna Burning Method

“Extending the Savanna Fire Management Methods to additional carbon pools and vegetation types and lowering the rainfall boundary to include the frequently burnt areas of the northern desert, would increase the total area of Indigenous owned or managed lands (Class 1 lands) covered by the Methods by more than 50%“

Status – 2024 SFM Method in development.

Draft includes Pindan veg type and additional seq pools.

Northern desert extension – IDA/CDU research published, data provided to Commonwealth, some progress with inventory and future incorporation into SFM Methods.

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3: Appropriate development of the Integrated Farm Management Method.

“The proposed method currently under development represents a significant opportunity to increase Indigenous access to the ERF, if developed appropriately. In particular, the new method must be applicable and suited to all environs across Australia…”

Status – Method prioritized for development in Oct 2021, planned for completion in 2024.

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What are the key issues

    • ICIN Dec 2023 submitted document to the Department outlining preliminary positions on a broad range of topics.

    • Currently working on a separate piece specifically around the treatment of fire in the IFLM Method and the ACCU Scheme more broadly (as overlaps with SFM and other Methods). Fire is a key gateway issue, but it’s not straight forward, there are some technical challenges.

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Is the IFLM Method (as currently drafted) going to deliver opportunities for Indigenous people?.... Mixed, and still many unknowns.

Similar to areas that would be suitable under HIR.

1) Indigenous pastoral

    • Pastoral properties (Aust. wide) will likely be eligible (cattle mngt is an eligible activity).
    • Properties within the Savanna (IFLM applicable in the savanna) could potentially choose between SFM or IFLM.
    • Existing Indigenous HIR projects could consider transitioning to IFLM.

2) Potentially some areas (any land use/tenure) if significant damage occurring to vegetation from feral animals (feral animal mngt is listed an eligible activity).

3) Where Indigenous Eligible Interest Holder (EIH) Consent required (Class 2 – often on non-indigenous pastoral leases)

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Savanna region, Indigenous non-pastoral (e.g., Land Trust)

      • Maybe excluded from IFLM, depending on how fire is treated within IFLM Method.
      • For SFM projects wishing to stay on SFM, how the IFLM Method is developed could still be of interest. Neighbouring properties, potentially with similar fire patterns, both using different carbon accounting approaches with the Land Trust registered using SFM and pastoral lease using IFLM (e.g., different approach to baseline, different eligible veg, different models used for calcs with SavCAM peer reviewed and public whilst IFLM hybrid approach not public). Maybe not a problem if the two approaches produce similar sequestration abatement results under similar circumstances.

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Other Indigenous - the 75% of Indigenous owned lands outside of the savanna (majority non-pastoral lands):

    • Large areas of the Indigenous estate could continue to be excluded from being able to participate in the ACCU Scheme if traditional fire management is not recognised as a stand-alone eligible activity within IFLM.

And if so, where to next (working towards IFLM V2, modules under IFLM, separate method altogether?)

Thanks.

Feedback appreciated.