Public Consultation Summary – March 2019
Thank you to everyone who contributed a written submission or comment and to all those who attended a meeting. All your input is extremely valuable.
Where appropriate, revisions have been made to the draft Reef Credit Standard and Guide which are now available in final version for use during the Beta phase (next 12months):
Compilations of all written submissions received by the Secretariat during the public consultation process for the draft Reef Credit Standard and Guide are available now. These documents include detailed responses to each suggestion, comment or question and are available below:
The Consultation Process
On 12 November 2018, the Reef Credit Secretariat published the draft Reef Credit Standard and Guide on the website (www.reefcredit.org) and invited comment on the draft documents. A series of public consultations were held over the ensuing four weeks in Canberra, Brisbane, Yeppoon, Rockhampton, Mackay, Townsville, and Cairns. Meetings were held with representatives from state, federal and local government, agricultural industry, environmental non-government organisations, and research institutions.
The Secretariat received a total of 22 comments on the draft Reef Credit Guide and 116 comments on the draft Reef Credit Standard, from multiple organisations.
Summary of submissions and responses
Some common questions raised in submissions related to the:
1. Additionality test (content and application);
2. Verification (auditing) process;
3. Process for establishing equivalence between different types of pollutants; and
4. Process for establishing baselines.
These comments were dealt with as follows:
1. Additionality test (content and application). The content of the additionality test is clarified to provide that “All Reef Credit generated pollution reductions and removals must be over and above:
1) a business as usual scenario;
2) legal requirements (e.g. regulatory standards threshold for compliance, or activities required by a conservation covenant); and
3) what is already funded to occur ( i.e. satisfy the financial additionality test).”
The definition of ‘business as usual’ has been revised to refer to “water pollutant reductions that would have occurred in the absence of the Reef Credit Project”. This is to make it clear that the change must be attributable to the incentive provided by the Scheme.
In a situation where there are overlapping programs (such as carbon projects), the financial additionality test will be applied by the independent verifier to determine whether the project is eligible to receive Reef Credits.
Further, Methodologies may adopt any of the following further approaches to the assessment of additionality: a. Implementation barriers (investment barrier, technology barrier or institutional barriers); b. Common practice; or; c. Performance benchmark.
2. Verification (auditing) process. The verifier must meet the eligibility requirements set out in the Standard for accreditation. The verifier attests that the requirements of the Standard and Methodology have been met in relation to the Reef Credit Project.
3. Process for establishing equivalence between different types of pollutants. The DIN amount is used as the base unit of measure or reference to create proportional equivalence or relative value (rather than functional equivalence) between pollutants in relation to the targets.
4. Process for establishing baselines. The process for establishing baselines will be dealt with in the Methodologies. A project must describe the project baseline scenario in accordance with the requirements of the relevant Methodology and must be reasonably assured during validation and verification.
Appointment of Technical Advisory Committee
A Technical Advisory Committee will be appointed in March to provide advice to the interim Steering Committee and Secretariat on technical matters including:
a) selection of independent peer reviewers to review the draft foundation methodologies; and
b) compliance of the methodology development and approval process with the Standard.
Peer Review process for Draft Foundation Methodologies
Peer reviewers will be appointed by the Secretariat as subject matter experts to ensure methodologies are theoretically rigorous, scientifically robust and practically workable. It is anticipated that the peer review process for the draft foundation methodologies will commence in March and will be completed by April. The process for peer review of methodologies is set out in the Reef Credit Standard, Schedule 5.
The peer review process will include broader public consultation on the draft foundation methodologies. The Reef Credit Secretariat will be seeking this public comment on draft foundation methodologies in March. The public consultation period will run for 30 days in parallel with the subject matter expert review.
Establishment of Governing Body
An independent skills based Board of Directors will be established to provide oversight to the Reef Credit Scheme. It is anticipated that the Board will be established by May at which time the first Reef Credit Projects may be submitted for approval.
All components of the Reef Credit Scheme, including the governance arrangements, will be reviewed at the end of 2019 when the beta phase concludes. The revised arrangements will then be formally ratified by the Board.
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