A Regulatory Mirage: Non-compliance with Regulatory Requirements in Australian Human-induced Regeneration Projects

The boom-and-bust nature of rangeland ecosystems makes them ill-suited to nature-based solution (NbS) carbon offset projects involving sequestration in vegetation and soils. The variability in these systems makes it difficult to determine whether observed stock changes are attributable to the project activities, creating additionality risks. The low and variable rainfall in rangelands also means stock increases will often be impermanent, being susceptible to reversals in droughts, a risk magnified by climate change. The vast areas and small potential for gains per unit area add further complications, making it difficult to accurately measure carbon stock changes at low cost. This creates pressure to trade accuracy for simplicity in measurement approaches, increasing the risk of measurement errors. Despite these risks, rangelands have been advanced as a location for offset projects because of low land costs and low opportunity cost, and a perception they are extensively degraded. The most prominent example globally is human-induced regeneration (HIR) projects under the Australian carbon credit unit (ACCU) scheme, which are purporting to regenerate permanent even-aged native forests (areas with ≥20% canopy cover from trees ≥2 metres high) across millions of hectares of largely uncleared rangelands, predominantly by reducing grazing pressure from livestock and feral animals. Existing research has shown limited forest regeneration in the credited areas of these projects and that most of the observed changes in tree cover are attributable to factors other than the project activities, most likely variable rainfall. Here we extend this research by evaluating compliance of a sample of 117 HIR projects with regulatory requirements. The results suggest most HIR projects are non-compliant with key regulatory requirements that are essential to project integrity. The findings point to major administrative and governance failings in Australia’s carbon credit scheme.