For consultation: Proposed changes to subsidiary documents and sampling guidance for measurement-based soil carbon methodsThese proposed changes are designed to clarify and improve sampling assurance processes and controls for projects using the measurement-based soil carbon methods under the Emissions Reduction Fund.

Purpose of the guidance and subsidiary document changes

The Emissions Reduction Fund has two measurement-based soil carbon methods:

The Carbon Credits (Carbon Farming Initiative – Sequestering Carbon in Soils in Grazing Systems) Methodology Determination 2014 (revoked on 7 February 2019, closed to new entrants); which incorporates the CFI Soil sampling design method and guidelines (a subsidiary document)

The Carbon Credits (Carbon Farming Initiative — Measurement of Soil Carbon Sequestration in Agricultural Systems) Methodology Determination 2018 (open and available from 25 January 2018); which incorporates The Supplement to the Carbon Credits (Carbon Farming Initiative—Measurement of Soil Carbon Sequestration in Agricultural Systems) Methodology Determination 2018 (a subsidiary document).

Both methods rely on random allocation of sampling locations to be undertaken without bias to estimate changes in carbon stocks.

This document outlines new requirements and accompanying guidance designed to clarify and improve sampling assurance processes and controls for participants and the Clean Energy Regulator. It is divided into the following areas of discussion:

A. Random sampling in the Carbon Estimation Areas (CEAs)

B. Preventing re-allocation of sampling points by abandoning sampling rounds

C. Legitimacy of obstacles

Appendix A: Proposed changes to subsidiary documents (that correspond to the new requirements in sections A-C)

Each section in this consultation paper identifies the existing requirements, new (proposed) requirements and guidance on meeting these requirements. The proposed changes to the subsidiary material are provided in Appendix A for consultation purposes.

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OFFICIAL

A. Random sampling in the Carbon Estimation Areas (CEAs)

Existing requirements

Both soil carbon methods require spatial locations of soil sampling points to be allocated randomly for the baseline and subsequent sampling rounds.

Both soil carbon methods require the use of a pseudo-random number generator with a defined or known seed number to allocate these random spatial locations.

In Measurement of soil carbon sequestration in agricultural systems projects, before the start of each sampling round, participants must notify the Clean Energy Regulator of the intended latitude and longitude of each sample to be taken.

New requirements

Processes for generating and using random sampling locations for sampling rounds will need to meet the new requirements for both methods (from 1 May 2020). The proposed drafting to be included in the subsidiary documents is provided below and allows for participants to choose from two options to meet requirements – a default assurance approach (option a) and a pre-approved assurance approach (option b):

A pseudo-random number generator with a defined seed number must be used to assign the sampling locations for each stratum, where either:

a. all of the following apply:

i. the process and plan to link the numbers generated by the pseudo-random number generator to sampling locations, and determine which samples are combined into composites, is prepared and documented;

ii. the prepared process and plan (from i. above) is provided to, and receipt acknowledged by, the Clean Energy Regulator before random numbers are generated and applied;

iii. the pseudo-random number generator to be used is available to the Clean Energy Regulator for verification purposes;

iv. the process and plan uses a defined unpredictable seed number which is not known at the time the process and plan is developed (such as the ASX 200 index reported by asx.com.au at a future specified date/time);

v. evidence the plan (from iv. above) was followed for sampling is recorded and included in offset reports;

vi. the approach is transparent, reproducible and auditable;

vii. the approach achieves a genuinely random allocation of sampling locations; or

b. the process applies an approach pre-approved by the Clean Energy Regulator for generating and using random sampling locations. Such approaches may be approved for individual projects or generally in guidance published by the Clean Energy Regulator for the purposes of this subparagraph.

Guidance on meeting requirements for the default assurance approach (option a)

Sampling processes that follow the default assurance approach do not require prior approval from the Clean Energy Regulator.

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However, if baseline sampling is conducted in a manner inconsistent with the default assurance approach, it may be considered ineligible when reporting years later.

It is therefore recommended that participants still discuss the consistency of their approach with the default assurance approach with the Clean Energy Regulator.

Guidance on meeting requirements for the pre-approval of random sampling approaches (option b)

As new business systems and processes develop, the Clean Energy Regulator may publish new pre-approved approaches that simplify assurance processes for participants.

Participants may propose alternative approaches for generating and using random sampling locations for sampling rounds for either publication or individual application in their project(s).

Participants must demonstrate that they have a robust approach that assures that once spatial locations are allocated using a pseudo-random number generator, they are not able to be re-allocated, including removing opportunities after initial sample allocation to redefine:

» random seed numbers

» CEA or strata boundaries, or

» the means by which random numbers are related to site selection.

Approaches must also be transparent, reproducible and auditable and achieve a genuinely random allocation of sampling locations.

B. Preventing re-allocation of sampling points by abandoning sampling rounds

Existing requirements

The assigned locations of sampling rounds must be set out in the sampling plan for both the Sequestering carbon in soils in grazing systems method and the Measurement of soil carbon sequestration in agricultural systems methods.

New requirement

Unless exceptional circumstances apply, sampling in accordance with a proposed process and plan must not be abandoned and started again.

Guidance on meeting requirements

There is the possibility that unfavourable sampling rounds could be discarded and therefore bias the sampling process. To assure that this does not occur:

Once sampling locations are allocated in sampling plans, the results from the allocated (or offset/reserve) locations must be included in offset reports.

It is not acceptable to re-allocate sampling locations if the sampling round is postponed or ceased part-way through—though exceptional circumstances can be discussed with the Clean Energy Regulator in advance of the sampling window closing.

When following the default assurance process for the Random sampling in the CEA (see option a in section A. above), participants must provide sampling plans to the Clean Energy Regulator prior to sampling. This commits the proponent to undertake and report on sampling rounds for which they allocated sampling locations, assuring that sampling rounds will not be abandoned.

When not using the default approach (option a in section A above), participants will need to provide alternative assurance to the Clean Energy Regulator that show all sample rounds have been reported.

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C. Legitimacy of obstacles

Existing requirements

For the Sequestering carbon in soils in grazing systems method: If the sampling location is obstructed by a tree, a large immovable rock or any other obstruction that prevents soil sampling at the intended sampling location, then the actual sampling location is to be located by moving north (0 degrees) until the obstacle is cleared (an offset location). Further instructions apply if this falls outside the stratum boundaries. The coordinates of the actual sampling location must be recorded (see s3.6 of the method’s CFI Soil sampling design method and guidelines).

For the Measurement of soil carbon sequestration in agricultural systems method: Proponents can either offset the allocated sample location (similar to the above process) or use a reserve list of sample locations allocated at the same time as the sample locations are assigned (Part C (s1.0) of the method’s Supplement).

New requirements

Time-stamped photographic or video evidence of obstacles that changed the intended sampling location of a sample must be provided with each offset report.

Guidance on meeting requirements

If proponents are unable to extract a core to the nominated depth, they are permitted to re-attempt extraction in a proximate location (as allowed under the relevant method).

» This is to ensure the soil depth is not under-estimated due to dispersed rocks etc.

If the core extraction fails to reach the nominated depth after several attempts (noting that multiple attempts will need to be justified and documented)—the final sample should be analysed, and the actual sampling depth reported.

» This prevents soil depth from being over-estimated in the strata (e.g. by not accounting for areas of bedrock) by moving away from areas of bedrock.

Should there be any doubt in the method requirements, hazards are considered obstacles.

» This could include trees with overhanging limbs, powerlines, and other hazards that were unintentionally missed from exclusion areas like pipelines etc.

Appendix A: Proposed changes to the subsidiary documents

Following consultation, additional requirements (outlined below) will be included by the Department of Industry, Science, Energy and Resources in the CFI Soil sampling design method and guidelines and The Supplement to the Carbon Credits (Carbon Farming Initiative—Measurement of Soil Carbon Sequestration in Agricultural Systems) Methodology Determination 2018 and would be mandatory for all sampling and reporting conducted after those amendments are made.

These changes1 specifically:

Provide a default assurance approach for random sampling in the Carbon Estimation Areas;

Enable the Clean Energy Regulator to develop new assurance approaches for Random sampling in the Carbon Estimation Areas;

State that sampling in accordance with a proposed process and plan should not be abandoned and started again; and

1 Changes are identified with the red text.

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Request more documentary evidence when moving sampling points from the initial location due to obstacles.

Proposed changes to CARBON FARMING INITIATIVE SOIL SAMPLING DESIGN METHOD AND GUIDELINES

(Applicable to the Sequestering carbon in soils in grazing systems method)

E.2 Assigning sampling locations in each CEA (pp35)

1) For each composite: a. a sampling location must be randomly assigned within each stratum; b. the precision of the sampling location must be to at least 5 decimal places expressed in

decimal degrees as Eastings and Northings; c. the sampling location must be given a unique identifier; d. the sampling location must be able to be identified as belonging to the composite; e. the sampling location must not be closer to an existing sampling location than the expected

offset distance; and f. the sampling location must not be closer to a previous sampling location than the offset

distance for the previous sampling location.

2) A pseudo-random number generator with a defined seed number must be used to assign the sampling locations for each stratum and reported in accordance with Part H, where either:

a. all of the following apply:i. the process and plan to link the numbers generated by the pseudo-random number

generator to sampling locations, and determine which samples are combined into composites, is prepared and documented;

ii. the prepared process and plan (from i. above) is provided to, and receipt acknowledged by, the Clean Energy Regulator before random numbers are generated and applied;

iii. the pseudo-random number generator to be used is available to the Clean Energy Regulator for verification purposes;

iv. the process and plan uses a defined unpredictable seed number which is not known at the time the process and plan is developed (such as the ASX 200 index reported by asx.com.au at a future specified date/time);

v. evidence the plan (from iv. above) was followed for sampling is recorded and included in offset reports;

vi. the boundaries of CEAs and strata are not varied after the plan is provided to the Clean Energy Regulator;

vii. the approach is transparent, reproducible and auditable; viii. the approach achieves a genuinely random allocation of sampling locations; or

b. the process applies an approach pre-approved by the Clean Energy Regulator for generating and using random sampling locations. Such approaches may be approved for individual projects or generally in guidance published by the Clean Energy Regulator for the purposes of this subparagraph.

Note: It is recommended that proponents take into account guidance from the Clean Energy Regulator as to how best to implement these requirements and provide the necessary evidence to demonstrate they have been complied with.

3) Unless exceptional circumstance apply, sampling in accordance with a proposed process and plan should not be abandoned and started again.

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Note: Resubmission of a process and plan under 2(a)(ii) above would be inconsistent with a genuinely random allocation of sampling locations in all but exceptional circumstances (as the first plan’s random locations are discarded).Records of the selection process for sampling locations must be kept in accordance with Part G.

Transitional

4) Sampling undertaken or commenced by 1 May 2020 need not comply with paragraph (a) or (b) of subsection (2).

H.1 The first offsets report (p38)

The first offsets report for a project must contain the following information:(a) A sampling plan in accordance with Part A.

(b) The GPS unit specifications including the accuracy of each device used in the field for the purposes of establishing the CEA boundaries and sampling locations.

(c) The pseudo-random number generator/s used and the seed value/s used for randomly assigning sampling locations in accordance with Part E.

(d) An explanation of how the strata in each CEA should be large enough to accommodate the sampling rounds expected for the project crediting period(s) in accordance with clause D.2.

(e) Time-stamped photographic or video evidence of obstacles that changed the intended sampling location of a sample

H.2 Subsequent offsets reports

The following information must be included in the subsequent offsets reports for the project. For each subsequent offsets report, this information must be included for each round of sampling that is used to generate estimates of changes in soil carbon stocks from the project:(a) The sampling plan that relates to each sampling round;

(b) The GPS unit specifications including the accuracy of each device used in the field for the purposes of establishing and/or relocating sampling locations; and

(c) The pseudo-random number generator/s used and the seed value/s used for randomly assigning any of the following:

(i) Sampling locations in accordance with Part E.

(ii) Separation vectors in accordance with clause F.1.

(d) Time-stamped photographic or video evidence of obstacles that changed the intended sampling location of a sample

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Proposed Changes to The SUPPLEMENT TO THE CARBON CREDITS (CARBON FARMING INITIATIVE—MEASUREMENT OF SOIL CARBON SEQUESTRATION IN AGRICULTURAL SYSTEMS) METHODOLOGY DETERMINATION 2018.

2.0 Assigning sampling locations (p7)

Requirements: i. It is a requirement that sample locations are determined prior to any core extraction in a given

stratum for a given sampling round. ii. It is a requirement that the geographic point location of assigned sampling points are recorded along

with the units used. iii. It is a requirement that the precision of each sampling location (or alternative sampling location) is:

a. if longitude and latitude are used – a minimum of five decimal places; or b. if eastings and northings are used – a minimum of three decimal places.

iv. It is a requirement that within each stratum, sampling locations are assigned using a pseudo-random number generator with a defined seed number where either:

a. all of the following apply:i. the process and plan to link the numbers generated by the pseudo-random number

generator to sampling locations, and determine which samples are combined into composites, is prepared and documented;

ii. the prepared process and plan (from i. above) is provided to, and receipt acknowledged by, the Clean Energy Regulator before random numbers are generated and applied;

iii. the pseudo-random number generator to be used is available to the Clean Energy Regulator for verification purposes;

iv. the process and plan uses a defined unpredictable seed number which is not known at the time the process and plan is developed (such as the ASX 200 index reported by asx.com.au at a future specified date/time);

v. if a reserve list of locations is used when obstacles are encountered—the process and plan includes the selection of that list;

vi. the boundaries of CEAs and strata are not varied after the plan is provided to the Clean Energy Regulator;

vii. the approach is transparent, reproducible and auditable; viii. the approach achieves a genuinely random allocation of sampling locations; or

b. the process applies an approach pre-approved by the Clean Energy Regulator for generating and using random sampling locations. Such approaches may be approved for individual projects or generally in guidance published by the Clean Energy Regulator for the purposes of this subparagraph.

v. It is a requirement that, unless exceptional circumstances apply, sampling in accordance with a proposed process and plan should not be abandoned and started again.Note:

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Resubmission of a process and plan under the requirement in 2(iv) above would be inconsistent with a genuinely random allocation of sampling locations in all but exceptional circumstances (as the first plan’s random locations are discarded).

vi. It is a requirement that there are at least three sample locations within each stratum. vii. It is a requirement, if compositing and equal area stratification are chosen, that an equal number of

sample locations are assigned to each stratum. viii. It is a requirement that a soil core is taken at each sample location (or alternative sample location)

assigned in this part, and is prepared, analysed and the results reported as per Part D.

Recommendations:

i. It is recommended that proponents take into account guidance from the Clean Energy Regulator as to how best to implement these requirements and provide the necessary evidence to demonstrate they have been complied with.

Transitional

i. Sampling undertaken or commenced by 1 May 2020 need not comply with paragraph (a) or (b) of the requirement in 2.0(iv) or the recommendation.

1.0 Locating Sampling locations (p8)

Requirements:

i. It is a requirement that a GPS device with a minimum accuracy of ± four meters is to be used to locate the sampling location in the field.

ii. It is a requirement that, if a large immovable obstruction (such as a tree or boulder) prevents sampling at the intended sampling location, the actual sampling location is to be determined by one of the following processes:

a. A reserve list1) Determine a reserve list of alternative sample locations at the same time that sample

locations are assigned in Part B section 2.0, for that sampling round.b. Offsetting:

1) move north until the obstacle is cleared; 2) if the stratum boundary is hit before the obstacle is cleared then change the direction

of movement 15 degrees to the east and move away from the intended sampling location until the obstacle is cleared;

3) if the stratum boundary is hit before the obstacle is cleared, continue changing the direction of movement in 15 degree increments in the same direction and away from the intended sampling location until the obstacle is cleared and the actual sampling location is within the stratum boundary (Figure 2).

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Key:

= actual sampling location

= obstacle

= stratum boundary

= intended sampling location

Figure 2: Example of determining an alternative sampling location within a stratum in the presence of an obstacle using the offsetting approach.

iii. It is a requirement that both the intended and the actual sampling locations are reported (even if they are the same).

iv. It is a requirement to include the following information in each offsets report—time -stamped photographic or video evidence of obstacles that changed the intended sampling location of a sample.

Disclaimer

This document does not address all requirements in the legislation and subsidiary materials (guidelines and supplements).

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