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Carbon sink forests

CHAIR —Mr Williams and Ms Dibley, do you wish to make a brief opening statement before we go to questions?

Mr Williams —Yes, thank you. Just by way of background, Greening Australia is one of the largest environmental NGOs. We have some 47 offices across Australia and we have been in existence for 26 years. Our focus in southern Australia is on transforming degraded landscapes on a very large scale through the restoration and expansion of biodiverse and native forests, woodlands and other vegetation systems. Greening Australia’s model for landscape-scale transformation is based on strong science, with the express aim of achieving an economically sustainable mix of land uses. Broadly, this equates to a landscape that incorporates approximately one-third traditional agriculture, one-third deep-rooted perennial vegetation based agriculture and one-third permanent biodiverse vegetation systems.

Greening Australia’s interest in carbon sinks is quite straightforward. The creation of a carbon market worth potentially billions of dollars can in theory be leveraged to turbo charge existing efforts to halt and reverse the degradation of Australia’s environmental assets through the establishment of large-scale carbon sinks that reconnect isolated remnants of biodiverse native forests and woodlands. As a result of the carbon market there will be, for the first time, a revenue stream that is capable of addressing environmental threats at the scale of the threat.

To realise the opportunity, Greening Australia have created a biodiverse carbon offset business and we have recently been approved as an abatement provider under the federal government’s Greenhouse Friendly scheme. Greening Australia would urge the committee to recommend that the Tax Act amendments and associated guidelines underpinning carbon sink forests provide a positive incentive to drive the use of biodiverse carbon sinks through mechanisms such as tightening the guidelines or amending the legislation to provide a higher level of tax deduction to biodiverse carbon sinks. As a consequence of establishing the biodiverse carbon business, Greening Australia found it necessary to develop a definition of biodiverse carbon sinks—it is: a planting that restores a self-replacing diversity of regionally native vegetation on land cleared prior to 1990.

The qualities that distinguish biodiverse carbon sinks from other carbon sinks include that the plantings are self-replacing—they self-regenerate after natural disturbances such as fires and storms—they are sourced from native seed to the bioregion in which they are planted; they are situated in local soil, slope and climatic conditions and are suited to those; they are at least 10 hectares in size and more than 100 metres wide to ensure permanency and self-replacement. These are most capable of adaptation to climate change, including hotter temperatures, lower and more variable rainfall, and more frequent fires. They represent the lowest environmental and financial investment risk.

There is no legitimate ecological reason why monocultures of non-native species are needed for carbon sinks. After much research and development, fast-growing, short-rotation and uniform plantation systems have been developed to provide profitable timber products. In contrast, carbon sinks need to be long-lived, low-risk, self-replacing and resilient. Uniformity and fast growth are not the imperatives of carbon sinks.

If the intent of the proposed Tax Act amendments is to ensure that forest sinks deliver real and sustained abatement as part of the national contribution to tackling climate change then it is vitally important, in the face of inevitable climate change, that forest and woodland sinks that are inherently resilient are encouraged through additional incentives. Only biodiverse forest sinks, as articulated above, have the capacity to deliver both mitigation and adaptation, because they are inherently resilient. The reality is that it costs approximately twice as much to plant a 40-odd-species biodiverse planting than a single-species planting. Therefore investors seeking lowest cost abatement will direct their funds towards monoculture plantings. To see the first ecosystem service market fail to maximise environmental benefits would be a perverse outcome. Whilst the environment and natural resource management guidelines in relation to the establishment of trees for the purposes of carbon sequestration do go some way to delivering a balanced mixed land use, they fall short of driving biodiverse plantings as the guidelines rely on ambiguous regional natural resource plans.

We believe the Tax Act guidelines should provide a tax incentive for investment in native biodiverse carbon sinks to clearly favour these over monoculture plantings of native and exotic species. This would lessen the cost differential between the two abatement options and maximise the net environmental effect. I might leave it there. We would like to provide a written submission is due course.

CHAIR —Thank you.

Senator McGAURAN —Could you just go over the very last point you made? Sorry, I missed it.

Mr Williams —If the guidelines and/or the tax act are used to favour—in other words, provide a high level of incentive to—biodiverse native forest, then it will lessen the cost differential and put us on, if you like, a more even cost footing in the choice of monoculture versus biodiverse.

Senator McGAURAN —Now that you have established your business, what is your understanding of the point at which you can take the tax advantage of the plantings and growth and maturity?

Mr Williams —At the point of plantation.

Senator McGAURAN —Is that clear in the act?

Mr Williams —Yes, it is clear to me in my interpretation of it.

Senator HEFFERNAN —So, I am the farmer; you are the bloke with too much money who wants the tax deduction; and Ms Dibley is the carpet bagger who is going to save the trees. I then get too old and tired and cranky. We do all that, and we contract it to Origin Energy, or someone, who want the offset. The CSIRO have told us that they have got no idea of the sequestration rate, history, timing of the lifecycle of the tree—they have not completed that work. How do Origin Energy know, when they contract with you, what bang they are going to get for their buck?

Mr Williams —Origin Energy, like any investor, will have to make a forecast of two things: one is the carbon yield that they will get out of the plantation and the second is their view on the carbon price.

Senator HEFFERNAN —But surely they are looking to buy a direct offset against the government’s program, so they are going to be saying, ‘We are going to offset so many million tonnes.’ How do they actually know what a tree is going to do?

Mr Williams —Firstly, they have got to form a view on their forecast—and there is poor science around that—and then, once the plantation is in and planted and it is at the five-year verification point, we measure.

Senator HEFFERNAN —When will that science be complete?

Mr Williams —That is a very interesting question, Senator. I think we heard from CSIRO earlier that the science in relation to mixed species planting is poor. The science in relation to forest species growth rates is very strong. A number of organisations like ourselves and CO2 Australia have undertaken various measurement of dry weight et cetera to derive statistical growth curves for native species, but they are few and far between. It needs more work. Indeed, we have an R&D program—

Senator HEFFERNAN —But we are about to embark upon this journey without the work being done, aren’t we? There are people lining up with their money now.

Mr Williams —Yes.

Senator HEFFERNAN —So aren’t we putting the cart before the horse? Aren’t we just guessing?

Mr Williams —We are guessing. There is a government system for forecasting, called NCAT, that provides forecasts in different land types and rainfalls to give forecast growth rates. These are highly conservative and investors are using that as their baseline.

Senator HEFFERNAN —All right. So we do all that—we get the guesswork done and the alleged return to Mother Nature with the carbon—and then I get old and tired or run away from home or whatever goes wrong and I sell my farm to Senator Joyce. He pays me an extraordinary amount of money, because he is going to grow googly gums or something, which he thinks he can get a quid out of. My property is freehold. His solicitor searches the title and says, ‘Yes, Bill Heffernan owns that and there are no encumbrances on it.’ He buys it and he says, ‘We will bulldoze those trees because they are not registered on the title.’ How do you protect the trees?

Mr Williams —There are two aspects to this. As I understand it, under the green paper, if a forestry operation opts in to the Carbon Pollution Reduction Scheme then that plantation and the credits applying to it will carry with them a liability if they are felled.

Senator HEFFERNAN —That is right, to the bloke who took the contract.

Mr Williams —Correct.

Senator HEFFERNAN —But he did not take the contract; you did—off me, to him, from Origin.

Mr Williams —Correct, and as a risk mitigation, where Greening Australia acquires land through either freehold purchase or profit upon recontract, we would place a covenant over that land and have that registered in perpetuity to protect.

Senator HEFFERNAN —Der! That is the point that we have been making for weeks.

CHAIR —Who are you saying ‘der’ to, Senator Heffernan? I do not think it is Mr Williams.

Senator MILNE —No, it is not.

Senator HEFFERNAN —The government is not saying, NAFI is not saying, no-one is saying that this will have to be registered—which it will have to be. When Barnaby Joyce buys my farm and his solicitor searches the title and it is a clean title, then no-one has got any legal comeback on him because he has bought a clean block of land with nothing registered on it. If there is a gas pipeline through the thing there will be an easement on the title. So then we go to easement. So then you have to survey the easement. Are we going to do all that?

Mr Williams —We will be doing that in our business and that is so we can go to investors or purchasers and provide certainty that we have our risks managed—

Senator HEFFERNAN —Is that required under the legislation?

Mr Williams —Under this tax legislation? I do not believe it is.

Senator HEFFERNAN —That is just flawed legislation. It is crazy. Wouldn’t you agree? You will not get the sack for telling the truth.

Mr Williams —I do not have a view on whether that should be incorporated in this legislation, but it clearly should be a requirement somewhere through the associated tax act and/or carbon reduction scheme.

Senator HEFFERNAN —And you would agree that it would have to be? We have got the CO2 company—and, God bless them! I hope they all get a quid and die rich—but they are talking about putting strips of trees through, originally, they said, the Western Division of New South Wales and they are going to get a salinity credit as well. But when I pointed out to the person who rang me, who I do not want to embarrass, that there really is not a salinity problem in the Western Division, they said, ‘Well, down around Hay,’ and I said, ‘That is not the Western Division.’ But they are talking about putting strips of trees through people’s farms. I said, ‘What if a bloke wants to move his stock against the grain of the trees; would you have to have registered gateways to go through all these bloody tree lines?’ You would obviously have to survey it, so you could secure the planting on the title. So you would agree that it would have to be tidied up legally, on the title, to be enforceable?

Mr Williams —A reasonable investor would expect that risk to be managed in some way through some legal mechanism, yes.

Senator HEFFERNAN —Do you know what state governments are prepared to do on this? Is the law silent?

Mr Williams —I have no knowledge.

Senator McGAURAN —Mr Williams, congratulations on one point: you are the first one to come before us and attempt to set down a criterion, which is very good, and that is why you are opening up all these questions. If it is on the first year of planting that you obtain the tax deduction for your investors and if, in the second and third years, half or even 30 per cent is wiped out by rabbits or whatever, do you have a replanting program? Or, post the deduction, do you feel you do not have to do anything more?

Mr Williams —If I can answer that in the narrow sense of Greening Australia’s business model, we go to market with a product that says we will guarantee for five years particular survival rates et cetera, irrespective of pestilence, fire, disturbance and so on. Beyond that, the investor is taking some risk. There is a management regime et cetera. But we are now answering this in the very narrow sense of our product. We are really here in a broader policy sense around the tax act amendment.

Senator HEFFERNAN —It is important practical stuff, but if what has happened in the Riverina for the last 10 years happens and it does not rain, and your trees die after five years, it is no skin off your nose; it is skin off the nose of the person who has got the contract. You are not obliged—

Mr Williams —To deal with that risk, we run a pool that plants into five landscapes right across Australia, and we overplant and plant extra hectares to deal with that exact risk. But, again, we are answering the question now in the narrow sense of our business model.

Senator HEFFERNAN —Say there was a fire: would you say, ‘We’ve lost those but those are yours over there’?

Mr Williams —We are planting at scales of hundreds of hectares and, in some cases, entire farms. So scale gives us one protection, and you get diversity—

Senator HEFFERNAN —Could you give me an example of where you have planted an entire farm?

Mr Williams —The property we have just replanted is a property just north of Albany in what is known as the Fitz-Stirling link, an area from the Fitzgerald River National Park to Stirling Range National Park.

Senator HEFFERNAN —So it is a monoculture?

Mr Williams —No. Forty-seven species went back into that landscape.

Senator HEFFERNAN —So did you have to do an environmental plan?

Mr Williams —Are you referring to it being done under any particular regulations?

Senator HEFFERNAN —Just under the environmental act for the state of Western Australia. One of the great fundamental planning flaws in the 2020 Vision forestry strategy was that they gave them an exemption from forestry planning. So we had people in here this morning bragging about the Tumut area but you have got people up there tearing their hair out because all their local streams have been lost because there was no environmental planning associated with the plantation forestry. So have you got an exemption? Is there no requirement to do an environmental plan? Can you plant out an entire farm regardless of where it is?

Mr Williams —There was no requirement to lodge an environmental plan for this property.

Senator HEFFERNAN —Don’t you think it is fraught with danger? If the law is silent on environmental planning for broadscale planting, that means you could actually go into a sensitive part of the catchment and plant and not have to put in an environmental plan.

Mr Williams —I made the comment earlier that the quality of the natural resource management blueprints and plans out there at the moment are patchy. Some are inadequate and that raises the risk that you have just outlined; I agree.

Senator MILNE —That is the question I want to get to. When this legislation was introduced the parliament did not have the benefit of the Environmental and Natural Resource Management Guidelines that now are a disallowable instrument, and that comes to my point. I am unfamiliar with the regimes of various catchment management groups around the country—the NRM groups and so on—but in my home state of Tasmania there is no hydrological assessment for any of the catchments in Tasmania; they are starting to do that measurement. We have heard this morning from the CSIRO that it is going to be 2011 before we are going to get any sort of assessment under the National Water Initiative about catchments that are overallocated and so on. We already have tax deduction for Landcare plantings, but that is nothing compared with what this tax deduction will do in terms of monocultures. You mentioned a minute ago the possibility of giving a larger deduction for a multispecies, biodiverse planting as opposed to a monoculture, therefore trying to even up the cost and therefore the incentives. There are so many issues around this and the possibility of getting it wrong. Do you think it is premature to proceed until we have much better data on a number of these ecological issues about water interception, about biodiversity and about permanence and those issues?

Mr Williams —Two aspects there come to mind. Firstly, we are dealing with significant environmental threats on many fronts. We can wait, if you like, to have all the ducks lined up in terms of perfect science, but it will only exacerbate the situation and the opportunity will be lost, particularly around no-regrets actions. Secondly, in relation to the water allocation issue, the reality is that the greater growth rate, the greater the biomass you are trying to create, the greater will be the requirement for water. It is as simple as that. A natural ecosystem will initially, if you compare that to bare earth, intercept water—there is no doubt of that—but, if you look at it through the lens of the total environmental impact, there is a significant positive. If you look at it through the narrowest of lenses on water quantity, then there is a short-term interception.

Senator MILNE —Okay. It is no secret that I have moved for the tax deductibility to be available for biodiverse plantings and where the plantings are in the ground for 100 years—or longer, obviously. Is that something that you would support?

Mr Williams —I would support a differential incentive to put the cost issue on a more equal footing of biodiverse plantation versus the cheaper monoculture. Whether that is a constriction or a different level of incentive, I think either mechanism could be made to work.

Senator MILNE —What about a mechanism to get some kind of reward for restoration of degraded native vegetation or degraded forest?

Mr Williams —I am unclear as to how that would work through a carbon lens, through trying to issue carbon permits off that.

Senator MILNE —The issue here is that the work the ANU has been doing under Brendan Mackey is to estimate the maximum potential carbon-carrying capacity of an undisturbed native forest or undisturbed native vegetation regime. So you know what the potential of your undisturbed one is, you measure the level of disturbance of your existing vegetation or degraded forest and then you provide incentives to restore that to its maximum potential. There is no ability, under this legislation, to look at restoration issues. Because it is taking the Kyoto view that it has to be cleared at 1990 levels, it seems to me the potential for restoration of degraded natural ecosystems is missing in this.

Mr Williams —I would agree, but I took it as a given that this legislation was to encourage early action in advance of the Carbon Pollution Reduction Scheme as outlined in the green paper. So I agree with you, but we have approached this in the narrower sense, if you like.

Senator MILNE —Where in the legislation does it suggest to you that that is the intention at all?

Mr Williams —That has been our interpretation of this legislation, as it was when it was tabled by the previous government.

Senator MILNE —Can you envisage a situation where a forest industry company could be managing a thousand hectares of plantation for production forestry and 700 of those hectares for carbon at the same time and get both?

Mr Williams —Can I see that? Yes. It is possible. That would mean they were either operating in the voluntary market or, more likely, operating in the mandatory market, which means that, under the proposed scheme, they would have opted in and they would have to account for any harvest emissions. So they would need to balance their timber portfolio as well as their emissions portfolio, if you like.

Senator MILNE —And that is why they would manage 1,000 hectares for timber production and, say, 500 or 700 hectares for carbon. In their plantation rotation, they could make sure that they had a constant level of carbon from the 500 hectares out of their 1,000, so they would get a 100 per cent tax deduction up-front, the fibre cost and the carbon. So actually this would be a windfall gain for people who want to manage their forests for fibre, and therefore you will not get the maximum carbon sequestration because there will be a managed rotation so that those trees are never in the ground for more than 14 or 15 years. It is just that the rotation will mean there is a constant level of carbon. Can you see that that could be a huge windfall here for plantation companies and not for the environment, since there will be no additionality?

Mr Williams —I understand the point you are making. I do not understand the economics of a balanced monoculture plantation, so I cannot answer your question. But I do understand the point you are trying to get to.

Senator MILNE —And isn’t that currently allowed under the government’s rules—under the Greenhouse Office rules?

Mr Williams —If that forestry company had opted in, yes, and they accounted for their net sequestration or emissions—yes, as I understand it, they could do that.

Senator MILNE —Okay. You made the suggestion, which is where I am coming from, about rewarding people for ecological services and for planting for biodiversity and building more resilient ecosystems. Apart from the differential levels of support you have suggested you might get for one over the other, are there any other suggestions you would make about all these loopholes in relation to the various state regimes and NRM capacities and all that sort of stuff?

Mr Williams —We would like to see further strengthening around the perpetuity issue, the longevity issue, but we are not necessarily relying on this tax amendment act and guidelines as the only mechanism for ensuring that. We assume there are other mechanisms around land clearing, around the regional plans, around the design of the carbon reduction scheme et cetera, and the sheer market force of demanding the risks be managed for the long-term supply of carbon, that will satisfy those as well.

Senator MILNE —Except that this is a tax amendment and, if you meet the requirements, the tax office will take a simple straight-out 100 per cent tax deduction. These are the requirements, and it will be up to people to take civil action to disprove requirements having been met in terms of catchment management, hydrological issues and all that kind of stuff. In some places they do not exist. In the Tasmanian case, you would meet the Tasmanian obligations because no obligations exist. It does not mean to say that you meet the ecological obligations in terms of land clearance, hydrological assessment, catchments and stuff. Where legislation does not exist, you would comply with the tax act and the guidelines and you could destroy the place.

Mr Williams —I am not disagreeing with you, but I just take you back to our proposed definition of a biodiverse carbon sink being a planting that restores a self-replacing diversity in regionally native vegetation on land clearing.

Senator MILNE —That is your definition—

Mr Williams —Implicit in that is that perpetuity is required.

Senator MILNE —Thank you. That is your definition, but that is not the government’s definition.

Mr Williams —No.

Senator MILNE —We are dealing here with what the government defines as carbon sink as opposed to the ethical view that your organisation might take. That is the issue here. All you have to do is comply with the legislation, not with what Greening Australia or anyone else might think. The definition, as it stands, does not incorporate any of those governing considerations that you have just put forward.

Ms Dibley —I suppose the course we are taking really is to highlight the potential perverse outcomes that you are referring to and to strongly argue that the model of our work, which is all about landscape restoration—

Senator MILNE —Yes, it could be taken on board.

Ms Dibley —Yes.

Senator MILNE —That definition could be incorporated, which would solve a lot of the problems.

Ms Dibley —Yes.

Senator JOYCE —You are aware of the legislation that surrounds the so-called TLAB, the tax laws amendment bill, that this inquiry is about.

Mr Williams —Yes.

Senator JOYCE —You are aware of the deduction that is stipulated in 40-1005—and I quote from the legislation:

... you incur capital expenditure that is covered under section 40-1010 in relation to particular trees established in the income year ...

Have you had any further discussions or been involved with anybody about what part of that capital expenditure would be?

Mr Williams —We have had no discussions regarding the wording in the tax act.

Senator JOYCE —So you are probably not much use to me on that one then. One of the questions has been the tax deductibility of the actual purchase of land, which in the legislation itself is not excluded. Nowhere does this legislation talk about not being able to get a capital deduction for the purchase of land, which would be a substantial capital deduction and give a substantial tax advantage to any organisation that wished to purchase such land. I note that section 40-1020 of this legislation specifically refers to ‘certain expenditure disregarded’, but nowhere in 40-1020 is there any mention of disregarding the purchase of land. Given that land is definitely capital in nature and the section that talks about areas that are to be disregarded does not include land, would that mean to you that land is included?

Mr Williams —I have not read the detail of the legislation. The information in the memorandum and the information provided on the tax office website currently infer that the land is excluded.

Senator JOYCE —How would they come up with that exclusion of land, given that it is not in the legislation?

Mr Williams —I cannot explain how the tax office prepared their website; I am sorry.

Senator JOYCE —You support the legislation, don’t you?

Mr Williams —Yes.

Senator JOYCE —What are your views on the socioeconomic study in regard to the legislation?

Mr Williams —As an organisation, we have not examined the socioeconomic impacts of that. We do not have the resources to do that.

Senator JOYCE —Do you know whether anybody has examined the socioeconomic impact study?

Mr Williams —I have no knowledge of that, no.

Senator JOYCE —Do you know whether there has been a socioeconomic impact study?

Mr Williams —I have no knowledge of that.

Senator JOYCE —If I were to tell you that there has not been a socioeconomic impact study, would you find that surprising?

Mr Williams —Yes.

Senator JOYCE —Do you think there should be a socioeconomic impact study before this legislation goes through?

Mr Williams —I would have thought so; that would be appropriate.

Senator JOYCE —There has not been, and that is one of the surprising things that we found about this legislation. Is your belief in the environmental benefits of carbon sequestration the reason you support the legislation?

Mr Williams —That is right.

Senator JOYCE —Therefore, you believe that there is a substantial advantage in the carbon that will be captured in the creation of these forests?

Mr Williams —Yes. We see significant investment going into biosequestration and through multi-species plantings.

Senator JOYCE —But, as Senator Milne has already pointed out, this can be a rotational harvesting scheme if we wish to work it that way.

Mr Williams —That is unlikely for the multi-species plantings.

Senator JOYCE —But within the legislation we have the capacity to do it.

Mr Williams —Yes. I think we have already covered this point with Senator Milne.

Senator JOYCE —Do you think that is a flaw and should be ruled out?

Mr Williams —It is our view that these plantations should be there in perpetuity.

Senator JOYCE —That means you cannot harvest them, which means you would have to rule it out. I notice you have a tree on your lapel—can you suggest to me what would be the appropriate tree to get the greatest amount of carbon appropriated within timber? How would you get the heaviest amount of carbon? You are looking for the heaviest amount of carbon per acre, aren’t you?

Mr Williams —That is not what we are looking for, no. We are looking to restore the landscape using local native species, funded through a revenue stream generated by carbon credits. We are not looking to maximise—

Senator JOYCE —What would be the advantage to the local community of that revenue stream of carbon credits? Say there is a forest on the edge of town, it is growing in weight and there is a revenue stream going back to Rio Tinto or BHP. Tell me the advantage for the local town of that.

Mr Williams —This is a revenue stream from a monoculture plantation?

Senator JOYCE —The weight of the carbon is increasing, so you are developing carbon credits. And a carbon credit is a revenue item that certainly has value, so it would have to be accounted for as value. So this is an increase in an asset, and an increase in an asset is a form of attainment of revenue. You also have the capacity, I imagine, to sell it if you wish. But just tell me what the benefit will be to the local surrounding towns of that increase in that asset and that revenue. What are they going to get out of it?

Mr Williams —As I said earlier, we have undertaken no socioeconomic modelling.

Senator JOYCE —Off the top of your head, give me one benefit to the town.

Ms Dibley —We are saying that we are restoring natural systems and that we are interested in the restoration of degraded native forests. We think that there are large carbon stocks in existing degraded forests that should be also valued. We are saying that, for instance, through private sector investment in this way there can actually be an increase in the National Reserve System. These are public goods. The focus of our work is public good.

Senator JOYCE —So that is the argument you would espouse at the local hotel on a Friday night?

Ms Dibley —I think we could also, if we got into the discussion, talk about the fact that the kinds of plantings we are interested in are quite different to the sorts of plantings that might give rise to the perverse outcomes that we were discussing earlier.

Senator JOYCE —In regard to those perverse outcomes, do you believe that there should be more prescription about the type of country that this form of investment can be placed on?

Ms Dibley —You have to understand that our work, which is about landscape restoration, is in degraded areas. We look at areas of connectivity with places that already have high conservation value. We work often in establishing areas of connectivity between existing National Reserve System areas, for instance. So we do not conduct that kind of research.

Senator JOYCE —Let us talk about your restoration of areas and connectivity—and I am not quite certain what that means, but we will run with it. When you talk about degraded areas, can you please be a little more specific as to what you define as a degraded area? Would you define, for instance, a cane growing area on an alluvial floodplain as a degraded area? Would you describe the Breezer plains as a degraded area? What value judgements do you make in defining something as a degraded area? Is it as broad as, ‘Well, it was like that 300 or 400 years ago and it is not like that now; therefore, it is degraded’?

Mr Williams —No. The planning process we use is called conservation action planning. It looks at the landscape scale. It identifies all major threats and then identifies a range of outcomes and actions. We do not start at the paddock scale in terms of planning ecological restoration.

Senator JOYCE —Is that sort of guideline in this TLAB legislation?

Mr Williams —No, it is not in the legislation. It is inferred from the reference in the guidelines to the regional NRM plans; but, as we have said, they are ambiguous and at times not of high quality.

Senator JOYCE —As I have pointed out, quite a few inferences from this legislation are actually not in this legislation; they are not there.

Senator HEFFERNAN —In my view, he has done a bloody good job in some areas. I am familiar with this from my area. Years ago this was part of our education about land care and what was happening on our farms. I think you have a lot of good work behind you and you have a pretty fair history in that work. The difficulty for this committee is that the legislation does not have your background and is silent on a lot of the stuff that you take as a given. Wouldn’t you agree with that?

Mr Williams —Yes.

CHAIR —I thank Greening Australia. Ms Dibley, I commend you on your conduct when Senator Heffernan, to get his point across, referred to you possibly as a carpetbagger.

Ms Dibley —I thought it was quite amusing really because it is so untrue.

Senator HEFFERNAN —Who did I refer to as a carpetbagger—Greening Australia? I withdraw that. They are not carpetbaggers. There are plenty of carpetbaggers lined up, but you are not one of them.

CHAIR —Thank you, Ms Dibley, and thank you very much, Mr Williams.

[11.23 am]