The Australian Forest Products Association (AFPA) welcomes the opportunity to provide comment on the Carbon Credits (Carbon Farming Initiative — Designated Verified Carbon Standard Projects) Methodology Determination 2015. Please find the AFPA submission attached.

In summary, AFPA has serious concerns regarding the Verified Carbon Standard (VCS) Projects methodology determination being proposed under the Carbon Farming Initiative (CFI).

Presently, there is considerable international debate as to whether ‘avoided harvest’ projects such as those outlined in the VCS Projects actually produce a net carbon reduction benefit over the longer term compared to sustainably managed forests that are subject to periodic harvest for forest products. A lot of this debate centres on the methodology applied and inclusion of appropriate time periods, carbon pools and abatement pathways.

 

Submission: Determination — Designation of VCS projects to CFI