Chapter 7
Carbon and the Land (Part c)
A National Policy Framework for Sinks?
7.147 Considerable concern has been expressed throughout the inquiry
that sinks are viewed by governments and industry as a long term solution
rather than a transitional strategy, and a strong perception exists that
it is the Government's intent that a large proportion of Australia's Kyoto
target be met through sink activity.
7.148 Sinks can be viewed in a number of ways:
- as a long term measure/response;
- as an interim or transitional measure (short term/buying time); or
- as an entirely additional activity with greenhouse benefits but no
tradeable credit for action as not reducing emissions at source.
7.149 Most witnesses to the inquiry accept that sinks are not a long
term solution. The CANA submission notes that:
The notion that carbon sequestration represents a solution is based
on a dangerous delusion - the delusion that forests, plantations and
other sinks represent intrinsically permanent stocks of carbon and that
there is almost infinite scope to increase these stocks. In reality,
carbon sequestration offers, at best, the potential for taking a small
proportion of the current anthropogenic CO2 emissions from the atmosphere
and providing a short term store for that carbon. Under the Kyoto Protocol,
however, even this small benefit is ambiguous, since for every emission
unit claimed as sequestered unit of carbon, a corresponding additional
unit of gross industrial emissions is permitted. In other words, the
use of sequestration activities, within the Kyoto Protocol framework,
results in more greenhouse gases being added to the atmosphere than
would otherwise have been the case. [1]
7.150 The Committee does not favour consideration of sinks as a long
term measure. It is the Committee's view that the science on the longer
term future of sinks remains uncertain. Contributing to this uncertainty
is the scope of the sink activities contained in the Kyoto Protocol, the
potential lack of permanence, and the risk of sink removal post the first
commitment period if there is not contiguous reporting into a second commitment
period. As noted by the WWF in evidence to the Committee:
The focus should be reducing greenhouse emissions at source. Land use
change and forestry is a peripheral activity which cannot address some
of the issues that the previous speakers today have mentioned, that
is, what is the long term goal for greenhouse gas reductions far and
beyond Kyoto? [2]
7.151 The Committee takes the view, that as a transitional measure, sinks
can make a valuable contribution to both meeting the Kyoto target and
putting in place longer term strategies for reducing greenhouse gas emissions
at source. This was a view put forward by CSIRO and many others to the
Committee:
The other response is sequestration - that is, if you do not want carbon
dioxide in the atmosphere. It is important for committee members to
realise that you have a choice of only three places to put that carbon.
It does not disappear from the system. It does not leak out into space.
It is a mass and that mass remains constant. If we do not want carbon
dioxide in the atmosphere, we could leave it where it is, which implies
not burning fossil fuels, not wreaking massive land use changes. If
we are going to continue to burn fossil fuels and we do not want the
carbon in the atmosphere, then it needs to be either put back into the
lithosphere via geological sequestration, or it gets put into the marine
environment or the terrestrial environment via tree planting programs,
vegetation, et cetera. Sequestration may be a transitional strategy
until we go to more sustainable forms of energy usage. [3]
7.152 The Committee emphasises that sinks should only be viewed as one
part of the solution, and that the primary focus of greenhouse response
measures should be on reducing emissions at source and encouraging fundamental
changes in the energy and transport sectors.
7.153 It is the Committee's view, that without the benefits of tradeable
carbon credits, much of the valuable ancillary benefits to be gained from
carbon sequestration may not arise, because the financial incentive for
investment would no longer exist. The Committee agrees that carbon credits
should not be the driver for necessary revegetation activities to reduce
and repair salinity, but acknowledges the potential for carbon credits
to stimulate action in this regard.
7.154 The Western Australian Government has argued that for sinks to
make an effective contribution to Australia's Kyoto target, significant
changes in policy are required. Dr Cox informed the Committee that:
… governments by themselves cannot possibly achieve that outcome.
It has to be achieved through private sector participation. The three
elements we think are important to achieve those outcomes are, firstly,
the recognition of the Commonwealth Parliament that revegetation will
provide cost-effective greenhouse gas abatement and will also deliver
regional development, ecologically sustainable development and environmental
management on a large scale; secondly, understanding that commercial
action is necessary to achieve the required scale of revegetation and
that government action in the early stages is required to demonstrate
the potential and to develop markets for commercial products and biomass
energy; and, finally, early resolutions of uncertainties about accounting
rules and the adoption of national regulations for controlling greenhouse
gas emissions.
7.155 Dr Cox suggested that a national policy framework for sinks is
required to facilitate and encourage action and adds that the key policy
elements required are:
- … [r]ecognition of property rights. In other words, if people
grow vegetation for the purposes of carbon accretion, that property
right must be recognised and we have suggested the framework that should
be established for that.
- … [a] framework needs to be put in place for a trading environment
so that people can trade carbon credits between farmers and industry
and so that the money generated from that can be utilised by farmers
for revegetation purposes.
- … [t]o enable trading to take place, there must be an accounting
framework and a measurement system in place. It is currently being worked
on but, again, we would encourage a policy framework at the Federal
level, supported by the states, to ensure we have the ability to account
for what is being accredited. [4]
7.156 The NGS sets out a number of measures by which greenhouse sinks
may be expanded, enhanced and managed, but does not address the issues
outlined by the Western Australian Government, link activities and measures,
or establish a goal for the contribution of sinks to meeting Australia's
target. A number of the principles developed and agreed by governments
to guide the further development and implementation of the NGS do go some
way towards providing the basis of a national policy framework and should
be considered in the development of a national policy framework for sinks.
7.157 The Committee supports the development of a national policy framework
for sinks that:
- integrates with natural resource management and ecologically sustainable
development;
- provides the basis for broadscale activity to address significant
environmental issues such as dryland salinity; and
- facilitates opportunities for new industries under a greenhouse banner.
Recommendation 74
The Committee recommends that the Australian Greenhouse Office coordinate
the development of a National Policy Framework for Greenhouse Sinks, which:
- is developed in partnership with state and territory governments
and relevant stakeholders; and
- is informed by the outcomes of the international negotiations on
the scope of sink activities to be included in the Kyoto Protocol.
The policy framework should identify principles to guide the establishment
of sink activities and consider, but not be limited to:
- the protection and enhancement of the native forest estate and
native vegetation;
- the impact on the environment of plantations versus environmental
plantings or revegetation;
- socioeconomic impacts on regional and rural communities;
- opportunities for the facilitation and development of new industries
particularly in regional communities;
- the opportunities for broadscale activity to address significant
environmental issues such as dryland salinity, land clearing and sustainable
land management;
- how sink activities may best be integrated with existing land uses
such as grazing;
- legislative mechanisms for the recognition of carbon rights;
- cost effectiveness of the range of sink activities; and
- the role of partnerships in achieving outcomes.
Recommendation 75
The Committee recommends that a National Policy Framework for Greenhouse
Sinks do the following:
- give priority to actions that will protect and enhance the native
forest estate and native vegetation;
- provide for research and development into native species reforestation
and revegetation activities which enhance carbon sequestration;
- provide funds for rural strategies that will facilitate greenhouse
abatement and broader environmental outcomes such as the establishment
of fuel plantations in salinity affected areas, and biomass based cogeneration
plants for agro-industrial plants in rural regions;
- set out the accounting framework to be used and establish an independent
verification process; and
- establish the framework for the trading of carbon credits domestically
and define the range and scope of sink activities that will be recognised
in a national emissions trading system.
Alternative Methods of Carbon Sequestration
7.158 The inquiry also heard of various projects currently underway to
test the long term viability of sequestering carbon in underground cavities
and in the ocean. CSIRO told the Committee that research into such methods
was the focus of considerable international activity. [5]
7.159 Geological sequestration appears to have enormous potential, with
estimates in Australia of up to 60 gigatonnes of CO2. However, no detailed
analysis has yet been conducted to determine the capacity of Australian
sedimentary basins to sequester CO2 and it appears to be a very high cost
method of greenhouse gas abatement. Technologies to perform this currently
exist in oil extraction industries, although challenges exist in concentrating
CO2 and separating it from other industrial pollutants.
7.160 Research efforts are also being directed into the marine sequestration
of carbon dioxide, either through direct injection of CO2 into the ocean
depths, or the stimulation of phytoplankton growth in surface ocean layers
through the addition of nutrients such as nitrogen and iron. There are
currently significant technical difficulties with such methods and uncertainty
about their broader ecological impacts.
7.161 Dr Thomas Trull, from the Antarctic Cooperative Research Centre
at the University of Tasmania, told the Committee about experiments they
had conducted with ocean fertilisation. In February 1999 they fertilised
an area of the Southern Ocean `about the size of the entire Derwent estuary
and the greater Hobart region', using iron in the form of ferrous sulphate
heptahydrate, a salt:
That bloom did not exceed what you can see there in November when natural
processes produce activity anyway when there is iron available. By adding
iron we are able to essentially extend the phytoplankton production
season… . This algal bloom transferred approximately 2,000 tonnes
of carbon from the atmosphere to the ocean. That is roughly one part
per million of the present natural global uptake by the ocean. It was
a very small experiment and a very small increase in the uptake, but
it demonstrated the feasibility and how that can occur. Even if we were
to carry this activity out over the entire Southern Ocean we could achieve
levels of enhanced uptake very similar to the terrestrial reforestation
process, but both of those are small compared to the emissions from
fossil fuels. [6]
7.162 The Antarctic CRC felt that this method was promising but cautioned
that further research was needed:
There are still possibilities for deleterious effects. We do not know
exactly which algae will respond when and where. We could get nuisance
algae. We could get changes in food and the ecosystem structure which
would not be desirable. We could produce toxic algal blooms. But probably
all those things can be avoided. [7]
7.163 The CRC argued that the possibilities for oceanic sequestration
were similar to those for sequestration on land and, while worth pursuing,
would not substitute for the reduction of fossil fuel use in the global
greenhouse abatement task:
Both these enhancements of the terrestrial and oceanic sink produce
only relatively small decreases in the atmospheric carbon dioxide level.
They both produce decreases of about 50 parts per million. That is to
be compared with our present levels of about 360 and our expectation
that that will double. Ocean enhancement should be given the same attention
that terrestrial enhancements are given. Both should be viewed as small
in their impact compared to the necessary reduction of emissions if
we want to maintain atmospheric CO2 levels close to present levels or
even keep them below doubling. [8]
Recommendation 76
The Committee recommends that Australian government, industry and
scientific community should continue to monitor research into alternative
methods of carbon sequestration, and to support it where such methods
seem promising and prudent.
Agricultural Production: Reducing Greenhouse Gas Emissions
7.164 The agricultural sector is responsible for 20 per cent of Australia's
greenhouse gas emissions (excluding land use change). The agricultural
industry has been receiving a great deal of focus in terms of the potential
for carbon sequestration through the creation of carbon sinks on cleared
agricultural land, but little attention appears to have been focused on
ways to reduce emissions at source. While the Committee notes that emissions
from this sector have been relatively stable for some time, the Committee
takes a longer term view of the need to address greenhouse gas emissions
and believes that all sectors must play their part in achieving emissions
reductions.
7.165 Module 6 of the NGS seeks to ensure incorporation of greenhouse
issues into agricultural management practices through the promotion of
sustainable agricultural practices and development of packages of information
for each key industry type. Much of the emphasis of the measures is on
capacity building, provision of extension services to the agricultural
community and communication and education programs.
7.166 The NFF submission to the inquiry states:
NFF believes there is a need for greater identification, dissemination
and extension of on-ground changes to land management practices which
enhance sustainability but also reduce emissions from the agricultural
sector.
Land managers need access to such tools, if they are to play a role
in emissions reduction. Greenhouse alone as an issue will not in the
present situation be sufficiently compelling to the individual farmer
to make changes to their land management. However, production orientated
solutions, which enhance sustainability but also reduce emissions are
more likely to be embraced.
There is also a clear need for provision of information to land managers
about greenhouse issues, how they relate to natural resource management
and how they may impact on their management decisions and costs of production.
[9]
7.167 Primary responsibility for the delivery of these programs lies
with the state and territory governments and intergovernmental mechanisms
such as the Agriculture and Resource Management Council of Australia and
New Zealand (ARMCANZ). The submission from the NFF suggests that not much
progress has been made on this front to date.
7.168 As part of the Commonwealth submission to the inquiry a work program
for the ARMCANZ Standing Committee on Agriculture and Resource Management
(SCARM) was provided. This program outlines the work the Council is intending
to undertake to assist in implementation of the NGS. The activities outlined
in the work program are intended to address the policy and institutional
issues to enable agriculture and natural resource management to contribute
to reducing greenhouse gas emissions and establishing carbon sinks.
7.169 The work program has three broad themes as follows:
- Sustainable agricultural management practices:
- identify activities with the greatest greenhouse benefit;
- identify incentives to encourage uptake of sustainable agricultural
practices; and
- use this information to inform policy development.
- Sinks:
- review the potential contribution of different primary industries
to sink establishment and maintenance;
- investigate potential incentives to encourage uptake of carbon
offset activities;
- review current regulations and institutional frameworks impeding
the establishment of carbon sinks; and
- consider auditing processes and procedures for assessing carbon
sequestration in vegetation.
- Emissions Projections:
- development of scenarios of future emissions levels; and
- opportunities emanating from the establishment of an emissions
trading regime.
- Emissions Trading:
- analysis of the issues for the agricultural sector and provision
of advice on how a framework may best be devised for the sector.
- Industry Awareness:
- ensuring industry and government stakeholders are aware of the
role of agriculture and natural resource management will need to
play in meeting greenhouse commitments.
- Adaptation strategies for climate change.
7.170 SCARM has sought $2 million from the Commonwealth and state agencies
to support implementation of the work program over the next two years.
The Committee is concerned that the broad scope of the SCARM work program
will result in limited on ground abatement activity. The work program
distributes minimal resources across a very broad range of activities
that will result primarily in research reports and may risk duplicating
work that is being undertaken by Commonwealth agencies such as the AGO,
for example, emissions projections, emissions trading and sinks. It is
the Committee's view that a number of the issues that the program is seeking
to address, such as emissions trading and sinks, are beyond the scope
of the Council and need to be considered as part of a higher level policy
framework specifically addressing these issues.
7.171 The work program appears to offer little practical application
of measures to reduce emissions, and the focus is on further research
and policy development, rather than communication and education about
action that can be taken now. In the view of the Committee, a more strategic
approach to action than presented in the SCARM work program is required.
This is discussed further in the section on sustainable land management
below.
7.172 The Committee is also concerned at the overall scarce level of
funding being provided to support measures in the agricultural sector.
The Committee is not aware if the SCARM work program is fully funded and
notes that in the Prime Minister's 1997 Statement only $1 million out
of $180 million was specifically allocated to a measure in the agricultural
sector.
7.173 The Committee was presented with very little evidence in both hearings
and submissions on the agricultural sector and the progress of measures
to reduce emissions in the sector. With the potential for the agricultural
sector to be incorporated into a future national emissions trading system,
the Committee is highly concerned at the paucity of measures, beyond sink
creation, receiving attention by governments. The Committee is aware that
a significant level of attention is currently being given by the Federal
Government to the development of a natural resource management strategy.
The Committee believes that a central focus of this strategy should be
the reduction of greenhouse gas emissions from agricultural production.
Recommendation 77
The Committee recommends that the reduction of greenhouse gas emissions
from agricultural production be a focus of the Natural Resource Management
Strategy currently under development.
Reducing methane emissions from livestock
7.174 Emissions from livestock in 1998 represented 13.8 per cent of total
national emissions and 68.2 per cent of emissions from agriculture. These
emissions are principally methane produced by sheep and cattle generated
through the natural process of enteric fermentation. Methane-producing
organisms (methanogens) exist in the digestive tract of cattle, sheep
and goats as a normal product of fermentation of the fodder that livestock
consume. The level of methane produced varies depending on feed quality
and intensity of management. For example, sheep fed on low quality pasture
produce less emissions per head but more over a lifetime due to the time
taken to reach target live weights, while sheep fed on grain produce more
emissions per head but less over a lifetime as they reach target live
weight gain more quickly. [10]
7.175 Research to control methane production in livestock is not new
and has been a focus for nutritionists for some time as its production
represents a loss of energy resulting in lower productivity (growth, and
production of milk and wool) of the animal concerned. CSIRO advises that
`methane has no nutritional value for livestock and it is breathed out
by them. The methane produced by methanogens accounts for between 2 per
cent and 12 per cent of the energy in the fodder that livestock consume'.
[11]
7.176 Manure management in the intensive livestock industries also produces
methane and nitrous oxide emissions.
7.177 Options for reducing greenhouse gas emissions from livestock appear
to be limited and focus on either inhibiting or suppressing the production
of methane in the enteric fermentation process; and/or reducing stocking
rates, adopting grazing management strategies that result in less methane
being produced and less carbon being lost from pastures; and modification
or improvement in effluent disposal techniques.
7.178 Options for inhibiting or suppressing methane and reducing greenhouse
gas emissions through changing the composition of feed or introduction
of additives which inhibit the production of methane have limited application
in Australia. The method of delivery is only suitable to intensively managed
stock, such as dairy or feedlot cattle, as daily or frequent doses are
required and would also require reduction in actual stocking rates to
reduce overall greenhouse gas emissions. [12]
7.179 The most promising option appears to be a vaccine currently under
development by CSIRO. Under the Prime Minister's 1997 Statement, Safeguarding
the Future, $1 million was allocated to promote the vaccine which
inhibits the production of methane in the rumen of livestock. The vaccine
under development uses the immune system of the animal to inhibit the
methanogens, poses no risk to the animal, improves productivity, would
be easily administered to all livestock and have long term effects. Expected
emissions reductions are yet to be fully quantified but could be in the
order of 18 per cent. [13]
7.180 CSIRO has advised the Committee that work is still in the research
and development phase and commercial viability is yet to be established.
The current focus is to establish whether a vaccine for sheep is commercially
viable by early 2001 and develop an estimate of the likely level of reduction
in emissions. Registration of the vaccine could then take up to 3 years.
Prototype vaccines for cattle and goats are yet to be developed and are
dependant on further funding. [14]
7.181 The cost-effectiveness of the vaccine as a greenhouse gas abatement
measure would depend on the benefits to the purchasers in terms of productivity
gains and reduction in emissions. The Western Australian Government estimates
`suggest annual reduced emissions of 0.8 to 1.0 Mt CO2-e possible from
sheep at approximately $100 per tonne and from dairy and beef cattle,
at approximately $35 per tonne'. [15] The basis
for the above estimates has not been provided.
7.182 There is the potential that the livestock sector will be faced
with costs under an emissions trading scheme, if action is not taken.
This issue is addressed later in this chapter. However, opportunities
for action in the livestock industries have been identified. The outcomes
of the Bureau of Rural Sciences (BRS) 1998 Workshop into the Kyoto Protocol
and Implications for the Australian Livestock Industries note that:
Significant emission reductions could be achieved through the development
of new technologies. There are currently a number of research avenues
that show potential to reduce emissions substantially while increasing
animal productivity. At present most receive little research funding
in Australia.
Australia should invest in the development and commercialisation of
these technologies rather than wait to buy them from other countries.
There are opportunities for greenhouse `credits' if Australia uses these
technologies in Joint Implementation (JI) and Clean Development Mechanism
(CDM) activities. There are also opportunities to enhance the image
of Australian industries.
Funding for research and development should come from both industry
and government as reducing emissions relates to both business advantage
and the `national good'. The existing commitment is small. [16]
Recommendation 78
The Committee recommends that a greater level of support be sought
from governments and industry for research and development in emissions
reduction opportunities in the livestock industries. This could be facilitated
by provision of seed funding by the Commonwealth or matching funding from
the Commonwealth to industry funds.
Sustainable Agricultural Management Practices
7.183 The concept of ecologically sustainable management is generally
accepted. The benefits that can be gained in terms of improvements in
productivity, the environment, and the longer term future of agricultural
production in Australia are widely recognised. However, the potential
role of sustainable agricultural management practices in reducing greenhouse
gas emissions, particularly nitrous oxide from agricultural soils, is
still under investigation.
7.184 Efforts to improve the general management practices of the livestock
industry through improved animal husbandry and improved effluent management
should not be discounted as an option. These can improve productivity
and enhance the long term viability of the industry. Management practices
that will reduce greenhouse gas emissions that could be promoted include:
- improving feed conversion efficiency through breeding and culling;
- supplementary feeding, herd health, improved pastures, optimal stocking
rates and feedlotting (depending upon net feed conversion efficiency);
- encouragement of farm management practices which promote stocking
rates that minimise the risk of degrading pasture cover, root material
and soil carbon; and
- consideration of alternative and new animal species for production.
[17]
7.185 More efficient management of farm effluent could result in reduced
methane emissions and other greenhouse gas emissions through greater energy
efficiency. The Western Australian Greenhouse Council report from the
Sustainable Land Management technical panel notes that:
At present up to half the dairy farms in Western Australia do nothing
to manage dairy shed effluent effectively and many management systems
do not prevent off site drainage of nutrients (in total about 75 per
cent of farms do not manage dairy shed effluent acceptably). [18]
7.186 Other key agricultural management practices that are to be promoted
under the NGS include conservation cropping, reducing energy use in agricultural
production, and reduction of biomass burning. The Western Australian Greenhouse
Council assessments of the potential of measures such as these indicates
that:
Adoption of grazing management strategies in northern Australia to
increase the perennial grass component could sequester approximately
300 million tonnes of organic carbon into the top 10 cm of soil. Rehabilitating
degraded land could possibly store a further 140 million tonnes of organic
carbon. However, it is expected that there would be extra carbon sequestered
in extra biomass from improved pasture management. [19]
7.187 The Council also notes that:
The use of alternative tillage systems may reduce overall rates of
emissions of soil carbon by about 2.5 million tonnes per annum (Lloyd,
1994). Howden & O'Leary (1995) suggested that wheat cropping systems
in Victoria emitted between 1.35 and 2.15 tonnes of carbon dioxide per
hectare per year. Stubble retention wheat cropping systems could reduce
the average net emissions per hectare by up to 37 per cent. [20]
7.188 In presenting evidence to the Committee, Dr Brian Jenkins of the
Western Australian Environment Protection Authority, noted that:
If you look at the main measures in the sustainable land management,
and here you will see some of the areas we cannot actually cost because
they really depend upon individual circumstances - and that is where
the asterisks are - in terms of emission reduction with animal husbandry
we can get in the order of about one megatonne at an estimated cost
of about $35 per tonne.
The major improvements would come from the CSIRO injections or feed
changes that you would need to introduce… to reduce the amount
of belching by the cows and the sheep. If you look at fertiliser management,
we believe that you can get up to about two megatonnes. The cost there
is uncertain but that could be a no regrets measure. With conservation
tillage which you may wish to undertake for land management reasons,
you are getting about 1.8 [Mt saved] and also for the stopping of land
clearing, about 3.9 [Mt saved]. So you are starting to get some sizeable
figures there in land management. These issues come under article 3.4
of the Kyoto Protocol, for which there is not international agreement
yet on their inclusion, but clearly the contribution they can make is
quite substantial in the West Australian context and agriculture is
quite a major component of the West Australian emissions. [21]
7.189 The BRS workshop summary notes that:
There are a number of things farmers can do now to reduce their greenhouse
gas emissions as well as improve their sustainability. However, industry
currently has little exposure to these options. To address this we need
to assess the economic and greenhouse benefits and costs of different
management practices and develop greenhouse `best practice' guidelines.
This was seen as a priority as potential new mitigation technologies
are still a number of years away. [22]
7.190 The Committee accepts that further investigation to quantify the
greenhouse benefits of sustainable agricultural management practices and
the cost-effectiveness of such actions may be required before widespread
action and uptake is achieved. The Committee does not, however, see these
as reasons to not pursue action in this sector and urges governments to
encourage and facilitate uptake of such practices. It is the Committee's
view that Measure 6.9 of the NGS - Incorporating consideration of greenhouse
issues into agricultural management practices, has the potential to meet
the needs identified by the BRS workshop and the Western Australian Government.
Action under this measure should be facilitated and accelerated as a priority.
Recommendation 79
The Committee recommends that the Standing Committee on Agriculture
and Resource Management (SCARM) work program be enhanced with the aim
of:
- improving understanding of agricultural producers about greenhouse;
- involving agricultural producers in identifying options and solutions;
and
- identification of options where sustainable land management leads
to reductions in emissions and greater productivity.
Recommendation 80
The Committee recommends that greater attention and priority be given
by all governments to meet the objectives of National Greenhouse Strategy
relating to agricultural management practices.
Emissions trading and the agricultural sector
7.191 The Committee has indicated support for an emissions trading system
that incorporates as wide a base as possible. The Committee is aware of
concerns that the design of such a system may impose undue hardships on
some sectors such as agriculture. However, there is also broad support
for the inclusion of all sectors in such a system.
7.192 The NFF submission to the inquiry notes that:
Should an ET regime be established in Australia that it must be capable
of accommodating the needs of participants with many smaller emission
sources. The farm sector which falls into this category, could be at
a relative disadvantage with regard to transaction/compliance costs
unless well accepted default measures were devised to easily estimate
and aggregate such emissions. [23]
7.193 However, the NFF also notes that:
The establishment of ET could potentially offer a dynamic, market-based
system which drives greater investment in revegetation and retention
of vegetation in rural Australia. This opportunity could however be
lost if the transaction, compliance and permit costs are beyond the
viable means of small players. [24]
7.194 The summary of the BRS workshop discussion notes the following
with regard to emissions trading and the agricultural sector:
If a free-market approach to emissions trading is adopted and the livestock
industry are unable to make cost effective reductions in emissions they
are at risk of having their permits purchased by other industries which
have lower emissions per unit economic return.
If the livestock sector can make significant reduction in methane emissions,
farmers will have emission permits to sell. If emissions trading eventuates
there may also be potential for claiming carbon credits from forage
shrub establishment and on-farm forestry plantations. [25]
7.195 Possible coverage in an emissions trading system is discussed in
chapter 9. The Committee supports mechanisms to stimulate more sustainable
agricultural practices and emission abatement. It further recognises that
there are a number of abatement opportunities that could be judiciously
pursued in advance of a national emissions trading system without posing
undue hardship in the agricultural sector.
The Scourge of Land Clearing
7.196 The Committee has very serious concerns about currrent rates of
land clearing in Australia and its destructive environmental impacts.
While the actual contribution of land clearing to Australia's greenhouse
gas emissions remains uncertain, the effects of land clearing on greenhouse
emissions, biodiversity, soil conservation and water management are well
documented. The ACF has stated that:
Land clearing is an environmental problem for three reasons:
It destroys and fragments the habitat of native plants and animals,
killing between five and ten million birds a year.
It contributes to greenhouse gas emissions through the burning and
rotting of vegetation.
It often leads to land degradation and salination, with serious economic
and social repercussions.
The State of the Environment Report: Australia 1996 says that
land clearance is the single greatest threat to biodiversity, and may
be Australia's most serious environmental problem. [26]
7.197 Greenhouse emissions from land clearing are the result of the loss
of carbon stored in vegetation and more importantly the soils. The 1998
NGGI report on the land use change and forestry sector states that:
Present emissions are in part a result of past actions - for example,
emissions from soil disturbance reflect previous clearing. The soil
is a large carbon reservoir and clearing of vegetation results in disturbance
of the soil and death and decay of tree roots with consequent release
of carbon from belowground. This release is neither instantaneous nor
uniform.
The pattern and rate of release of soil carbon over time are not known
for the variety of Australian soil and vegetation types. Nor is it known
whether, under different management conditions, there is net uptake
or emission. Release or uptake will be affected by the nature of land
use change and by climatic conditions. [27]
7.198 The uncertainties of measurement of greenhouse gas emissions from
land clearing are being dealt with through the NCAS. In response to questions
from the Committee regarding rates of land clearing in Queensland, and
providing more certainty on the contribution of land clearing to Australia's
national emissions, Mr Ian Carruthers of the AGO, stated:
In terms of the available data for land clearing rates for Queensland,
they have been published up to 1997. At that point they were running
at about 340,000 hectares a year for the period 1995-97. We understand
that the Queensland Government will be publishing more recent information
in the near future. [This study, referenced below, showed the rate for
1997-99 was 425,000 hectares per year.]
What we are embarking upon is by far the largest and most intensive
program of remote sensing of Australia's vegetation cover that has ever
been undertaken in this nation. It will give us high quality information
about changes in vegetation cover, both during the 1990s and stretching
back to 1970, which will obviously have important value for other natural
resource and sustainability purposes. [28]
7.199 To estimate the emissions from land clearing, sound estimates of
the rates of land clearing are required. As land management is primarily
the responsibility of the state governments, estimates are reliant on
the provision of data from the states and territories, the availability
and quality of which varies.
7.200 The most recently published NGGI data indicates that overall, the
rate of land clearing has decreased significantly with the exception of
Queensland. The Queensland estimates for the 1991 to 1995 period were
approximately 289,000 hectares per year and for 1996 to 1998 340,000 hectares.
[29] This represents an increase of over 50,000
hectares per year, more than the total of land clearing per annum for
all other states in the same period. The subsequently released Queensland
Statewide Landcover and Trees Study shows that the average annual rate
of land clearing in Queensland for the period 1997-99 was 425,000 hectares
per year. [30] This rate is 25 per cent higher
than the 1995-97 rate and 47 per cent higher than the 1991-95 rate.
7.201 The Federal Environment Minister, Senator Robert Hill, stated on
5 September 2000:
We believe land clearing, for example, in Queensland is now up to something
like half a million hectares a year - 500,000 hectares - or somewhere
between 80 and 90 per cent of all land clearing taking place in Australia.
[31]
7.202 The Australian Conservation Foundation (ACF) has been undertaking
independent tracking of land clearing rates and has published the following
information on land clearing rates for 1999 in a briefing note on their
website.
Table 7.1
ACF's estimates of Australia's clearing rates for 1999 (hectares
per year) [32]
| State |
Hectares |
| Qld |
400,000 |
| NSW |
60,000 |
| NT |
20,000 |
| Tas |
10,000 |
| WA |
6,000 |
| Vic |
2,000 |
| SA |
1,200 |
| ACT |
0 |
| TOTAL |
499,200 |
7.203 The above estimates reflect only the amount of land cleared and
not necessarily the number of permits or approvals for land clearing given.
Permits and approvals for land clearing have increased in both NSW and
Queensland in recent years. In 1999, permits for the clearing of 644,515
hectares were granted in Queensland, and 86,000 hectares approved for
clearing in 1998 in NSW. [33]
Land clearing and Queensland - A case study
7.204 As noted above, Queensland is not the only the only state in which
land clearing occurs, however, it is the most prominent in the current
debate about native vegetation management. Until recently (September 2000)
there were minimal controls in place for clearing on leasehold land and
no controls on freehold land.
7.205 On 8 September 2000, the Queensland Government passed new legislation
to regulate clearing on leasehold and freehold land. The legislation does
not proscribe a blanket ban on clearing. However, in most instances landholders
will need to seek approval to clear native vegetation. On leasehold land
the clearing of `endangered' [34] and `of concern'
[35] regional ecosystems is regulated while
on freehold land protection is only given to `endangered' regional ecosystems.
[36] This is the result of a compromise between
the Queensland Government and land holders, discussed further below, and
has been the subject of much criticism from the Commonwealth Government
and conservation groups.
7.206 Attempts to control land clearing in Queensland have been described
as a `major challenge'. [37] A 1999 stocktake
of Commonwealth, state and territory native vegetation management, notes
that Queensland is:
A State which is still extending its agricultural base and where there
has been a long tradition of no control over operations on freehold
land and limited controls on leasehold. It is made even more challenging
by its juxtaposition with a range of other issues that are perceived
to impact adversely on rural voters, particularly in forest management
and water reform. The pressures on vegetation in the past have been
primarily those associated with land clearing and there are no signs
that this pressure is abating. [38]
7.207 The most recent state assessment of land cover change in Queensland
has been conducted for the period 1997 to 1999. The Statewide Landcover
and Trees Study (SLATS) has identified that the average clearing rate
for this period was 425,000 hectares per year. [39]
This is 47 per cent higher than the 1991 to 1995 rate. The majority of
this clearing occurred on freehold land (59 per cent). [40]
7.208 The SLATS report also estimates that 34 per cent of clearing, on
areas where regional ecosystem mapping has been undertaken (92 per cent
of the state), included ecosystems considered endangered or of concern.
[41]
7.209 The recent increase in land clearing appears to have been largely
driven by landholder fears that land clearing will be subject to strict
controls and a view that such controls impinge on landholder rights to
develop their land. The 1999 stocktake report noted that:
Concern over native vegetation is occurring at a time when there are
a number of other major initiatives or changes which are impacting on
land managers. In particular, these include the development of water
allocation management plans, uncertainties over the ramifications of
the Wik decision on land title, issues associated with Australia's international
greenhouse commitments, and reforms associated with RFAs. The spectre
of vegetation management controls which impinge on perceived `rights'
or impact negatively on asset values is understandably yet another controversial
issue. Consequently, the constituency is unsettled and the government
under pressure from all sides. [42]
7.210 A 1995 Scientific Forum, established to examine the impact that
tree clearing on leasehold land has had or is likely to have on production,
economics and the environment, concluded that in some areas tree clearing
increase the productivity of land 2 to 4 fold, and that controls on land
clearing can reduce property values for uncleared properties by 15 to
70 per cent. [43] The 1999 stocktake report
notes that the speed with which Queensland acts to reduce land clearing
and implement controls:
Will depend on the extent to which farmers can be convinced that the
broader vegetation management approach will provide them with some benefits.
Unless a system can be put in place which does provide some benefits,
it is likely that there will be little change on the ground. [44]
7.211 The Commonwealth and Queensland have been conducting a vigorous
debate on the rates on land clearing in Queensland and need for tighter
controls. Senator Hill has stated that:
Queensland is the only state in Australia which does not have a regulatory
bottom line in relation to land clearing. So in that instance of natural
resource management there has been a total abdication of responsibility
by Mr Beatties' Labor government. [45]
7.212 The Queensland Premier responded to the Commonwealth's calls for
action with the introduction of new legislation. However, the strength
of that legislation was dependent on $103 million from the Commonwealth
requested by Queensland to compensate freehold landowners for clearing
restrictions. [46] The Commonwealth has argued
that land management is a state issue and that other states have managed
to introduce clearance controls without calling on the Commonwealth for
compensatory funding. The Queensland Government has stated that it `has
already committed $111 million to fund the on-going management of tree
clearing on freehold and leashold land'. [47]
7.213 The Committee understands that a joint taskforce was to be established
with Queensland to find a solution to this issue. The Queensland Premier
gave the Commonwealth a deadline of 20 August 2000 to reach agreement.
That deadline has now passed without an agreement and, as a result, the
new legislative controls on clearing have been watered down and no longer
provide protection for `of concern' regional ecosystems on freehold land.
The Queensland Minister for Natural Resources, the Hon Rodney Welford
MLA, has stated that `we can't go further with regulation on freehold
land without funding support from the Commonwealth'. [48]
Land clearing - A Commonwealth responsibility?
7.214 The above case study highlights the need for greater cooperation
between the Commonwealth and state and territory governments if environmental
objectives are to be achieved. The ACF is very critical of the Commonwealth
Government for avoiding responsibility on land clearing, arguing that:
The Federal Government has expressed deep concern about land clearing,
yet seems unwilling to take real action to regulate or control clearing.
Land clearing is not included in the new Environment Protection and
Biodiversity Conservation Act as a matter of national environmental
significance, and its nomination as a key threatening process under
the old Endangered Species Protection Act was twice rejected
by the Environment Minister, Senator Robert Hill. [49]
7.215 The ACF also pressed states and territories to act more decisively:
There is also an urgent need for strengthening of state clearing control
legislation, particularly in Queensland, the Northern Territory and
Tasmania. Although Queensland recently devised new clearing control
laws, state and Federal politicians have prevented their full proclamation
and implementation. [50]
7.216 The Senate Environment, Communications, Information Technology
and the Arts Legislation Committee inquiry into the Environment Protection
and Biodiversity Conservation (EPBC) Bill 1998, addressed the issue of
inclusion of land clearing as a matter of national environmental significance
under the Act and noted that:
With regard to the inclusion of `broad scale' matters as triggers,
the Committee notes that legislation is not always the most appropriate
way of dealing with these matters and that policies and programs are
the most effective responses. [51]
7.217 The EPBC Bill inquiry noted that the Government has in place a
number of initiatives to control land clearing through the Natural Heritage
Trust and that governments were working together, through the Australian
and New Zealand Environment and Conservation Council (ANZECC), to develop
a national framework for the management and monitoring of Australia's
native vegetation. [52]
7.218 The EPBC Bill inquiry also concluded that:
There are significant practical difficulties in applying an environmental
impact assessment approach to climate change, vegetation clearance,
and land and water degradation in a way that clearly establishes the
Commonwealth's responsibility vis-à-vis the states and territories.
These processes typically result from the cumulative effect of diffuse,
small-scale, individual activities which are more appropriately regulated
at the local and State government levels and for which it is difficult
to justify a direct legislative role for the Commonwealth. [53]
7.219 The dissenting report by the Australian Democrats does not concur
with this view and notes that the clearing of native vegetation is one
of the most serious threats to biodiversity and a significant environmental
challenge and should be subject to the Commonwealth's environmental approval
process. The report also notes that if appropriate thresholds were applied,
the practicality issue of small diffuse actions is avoided. The Committee
suggests that it would also be possible to limit Commonwealth involvement
in assessment through the use of accredited State environmental impact
assessment (EIA) processes. This could streamline the environmental impact
statement (EIS) process for proponents but still provide for meaningful
Commonwealth oversight.
7.220 The Australia Institute suggests that existing Commonwealth programs
are not having the expected leverage or effect on land clearing:
Current Federal Government policies appear to be working in the opposite
direction, especially in pursuit of the Bushcare program objective of
no net clearing of land by 2000. Environment Minister Senator Robert
Hill was recently reported to have threatened to withhold $34 million
in Bushcare grants to Queensland because it appears unlikely to meet
the objective. As a result of pressure from Canberra, and the expectation
that the Queensland Government will respond by introducing legislative
restrictions on land clearing on both freehold and lease-hold land,
land holders in Queensland have reportedly increased clearing activity
greatly. [54]
7.221 The submission also notes that:
The opportunity to end land clearing provides a means of making a large
contribution to meeting Australia's Kyoto target very cheaply. It is
moreover, a Federal Government policy objective for reasons unrelated
to climate change. Based on ABARE data, Ryan (1997) has estimated that
the cost of ending land clearing in terms of forgone agricultural output
would be less than $2 per tonne of CO2 of emissions saved… . This
suggests that ending land clearing in Queensland would make a very large
contribution to meeting Australia's Kyoto target at around one-tenth
the cost of other measures. [55]
7.222 A number of witnesses to the inquiry and submissions highlighted
significant concern about land clearing and that measures to halt land
clearing were viewed as one of the most cost effective actions that could
be taken in reducing greenhouse gas emissions. As noted by Mr Bridson
Cribb:
Then there is the situation where we have land clearing going on in
Queensland. My understanding is that, if you stop land clearing in Queensland,
you would save 65 million tonnes of CO2 equivalent per year. The Queensland
Government has asked for $100 million in compensation in order to get
farmers to stop land clearing. That works out at about $1.50 per tonne
of emissions that is saved. Compared with emissions trading costs that
you are looking at of around $20, $30 or $40 a tonne, to me $1.50 per
tonne of emissions saved - and you are talking about 65 million tonnes,
which is a substantial chunk of Australia's emissions - is a very cost-effective,
low cost measure that we should be embracing very quickly. [56]
7.223 The Committee is concerned at the ongoing rate of land clearing
in Queensland despite the programs currently in place. The Committee understands
that the Commonwealth argues that states should fund their own land clearing
policies. However the Commonwealth's objective should be to produce clear
results now, particularly given the very low cost of the abatement it
would encourage. The Commonwealth should make greater efforts to achieve
reductions in land clearing in cooperation with the states and territories
and ensure that strong controls to contain land clearing are introduced
nationally.
7.224 It is the Committee's view that to facilitate the engagement of
the rural sector support be given to strategies that boost investment
in greenhouse abatement in rural Australia. These strategies should encourage
the retention of native vegetation, investment in revegetation activities
that will enhance the environment and provide a win-win outcome for landholders,
and investment in plant that will support such activities.
Recommendation 81
The Committee recommends that the Commonwealth, states, and territories
introduce strong national controls on land clearing as a matter of urgency.
Recommendation 82
The Committee recommends the Commonwealth act with some urgency to
provide protection for `of concern' regional ecosystems, and provide compensation
to landholders where warranted.
Recommendation 83
The Committee recommends that the Commonwealth allocate funds for
rural strategies that assist in greenhouse responses such as fuel plantations
in salinity affected areas and biomass-based cogeneration plants for agro-industrial
plants in rural regions.
Footnotes
[1] Climate Action Network Australia, Submission
193a, p 4.
[2] Mr Michael Rae, Official Committee Hansard,
Sydney, 23 March 2000, p 441.
[3] Dr Chris Mitchell, Official Committee
Hansard, Melbourne, 20 March 2000, p 114.
[4] Proof Committee Hansard, Perth, 17
April 2000, p 458.
[5] CSIRO, Submission 206, pp 2481-83.
[6] Proof Committee Hansard, Hobart,
5 May 2000, pp E490-1.
[7] Proof Committee Hansard, Hobart,
5 May 2000, pp E490-1.
[8] Proof Committee Hansard, Hobart,
5 May 2000, pp E490-1.
[9] National Farmers Federation, Submission
145, p 1507.
[10] R S Hegarty, `Practical methods for reducing
methane emissions from Australian livestock' in Reyenga P J, and
Howden S M, (Eds), Meeting the Kyoto Target: Implications for
the Australian Livestock Industries, Workshop Proceedings, Canberra,
4-5 November 1998, Bureau of Rural Sciences, Canberra, 1999, pp 97-98.
[11] G McAlpine and C Mitchell, CSIRO –
Solutions for Greenhouse, an overview prepared for the Australian
Greenhouse Office (AGO), June 1999, p 25.
[12] R S Hegarty, `Practical methods for
reducing methane emissions from Australian livestock' in Reyenga,
P J, and Howden S M, (Eds), Meeting the Kyoto Target, Implications
for the Australian Livestock Industries, Workshop Proceedings, Canberra,
4-5 November 1998, Bureau of Rural Sciences, Canberra, 1999, pp 100-01.
[13] Western Australia Greenhouse Council,
Report to Council Sustainable Land Management, Technical Panel
June 1999, p 26.
[14] Advice provided to the Committee by the
CSIRO Animal Production Unit, 23 March 2000.
[15] Western Australia Greenhouse Council,
Report to Council Sustainable Land Management, Technical Panel
June 1999, p 27.
[16] P J Reyenga and S M Howden, (Eds), Meeting
the Kyoto Target: Implications for the Australian Livestock Industries,
Workshop proceedings, Canberra, 4-5 November 1998, Bureau of Rural Sciences,
Canberra, 1999, p 126.
[17] National Greenhouse Strategy, p 79.
[18] Western Australia Greenhouse Council,
Report to Council Sustainable Land Management Technical Panel,
June 1999, p 27.
[19] Western Australia Greenhouse Council,
Report to Council Sustainable Land Management Technical Panel,
June 1999, p 27.
[20] Western Australia Greenhouse Council,
Report to Council Sustainable Land Management Technical Panel, June
1999, pp 29-30.
[21] Dr Bryan Jenkins, Proof Committee Hansard,
Perth, 17 April 2000, p 557.
[22] P J Reyenga and S M Howden, (Eds), Meeting
the Kyoto Target: Implications for the Australian Livestock Industries,
Workshop proceedings, Canberra, 4-5 November 1998, Bureau of Rural Sciences,
Canberra, 1999, p 123.
[23] National Farmers Federation, Submission
145, p 2.
[24] National Farmers Federation, Submission
145, p 2.
[25] P J Reyenga and S M Howden, (Eds), Meeting
the Kyoto Target: Implications for the Australian Livestock Industries,
Workshop proceedings, Canberra, 4-5 November 1998, Bureau of Rural Sciences,
Canberra, 1999, pp 120-21.
[26] http://www.acfonline.org.au/campaigns/landclearing/briefings/background.htm
(25/10/00).
[27] Australian Greenhouse Office, National
Greenhouse Gas Inventory Land Use Change and Forestry Sector 1990-1998,
2000, p A-7.
[28] Mr Ian Carruthers, Proof Committee
Hansard, Canberra, 22 June 2000, p 684.
[29] Australian Greenhouse Office, National
Greenhouse Gas Inventory Land Use Change and Forestry Sector 1990 to 1998,
2000, p A11-A12.
[30] Statewide Landcover and Trees Study
(SLATS 1997-1999), Vegetation Change Report, produced by the Department
of Natural Resources, Queensland. SLATS is a vegetation monitoring program
of the Department of Natural Resources, Queensland, which gathers accurate
vegetation cover and cover change information for vegetation management
planning and for greenhouse gas inventory purposes, http://www.dnr.qld.gov.au/resourcenet/veg/slats/report/index.html#9799veg.
[31] Senate Official Hansard, 5 September
2000, p 15850.
[32] http://www.acfonline.org.au/campaigns/landclearing/briefings/background.htm.
[33] http://www.acfonline.org.au/campaigns/landclearing/briefings/background.htm.
[34] `Endangered' regional ecosystems are defined
as a regional ecosystem that has either:less than 10 per cent of its pre-clearing
extent remaining;10 per cent to 30 per cent of its pre-clearing extent
remaining and the remaining vegetation covers less than 10,000 hectares;
and composed of species characteristic of the vegetation's undisturbed
predominant canopy. Queensland Department of Natural Resources, A Guide
to Vegetation Management Policy in Queensland, 2000, p 11.
[35] An `of concern' regional ecosystem is
defined as - A regional ecosystem that has either:10 per cent to 30 per
cent of its pre-clearing extent remaining; or more than 30 per cent of
its pre-clearing extent remaining and the remaining vegetation covers
less than 10,000 hectares; andcomposed of species characteristic of the
vegetation's undisturbed predominant canopy.Queensland Department of Natural
Resources, A Guide to Vegetation Management Policy in Queensland,
2000, p 11.
[36] Queensland Department of Natural Resources,
A Guide to Vegetation Management Policy in Queensland, 2000.
[37] Griffin nrm 1999, Native Vegetation
National Overview: States/Territories/Commonwealth Stocktake of Native
Vegetation Management, prepared for ANZECC-Environment and Conservation
Ministerial Council and Native vegetation managers in all Australian jurisdictions,
p xiii.
[38] Griffin nrm 1999, Native Vegetation
National Overview: States/Territories/Commonwealth Stocktake of Native
Vegetation Management, prepared for ANZECC-Environment and Conservation
Ministerial Council and Native vegetation managers in all Australian jurisdictions,
p xiii.
[39] Queensland Department of Natural Resources,
Land Cover Change in Queensland 1997-1999, 2000, p 1.
[40] Queensland Department of Natural Resources,
Land Cover Change in Queensland 1997-1999, 2000, p 1.
[41] Queensland Department of Natural Resources,
Land Cover Change in Queensland 1997-1999, 2000, p 8.
[42] Griffin nrm 1999, Native Vegetation
National Overview: States/Territories/Commonwealth Stocktake of Native
Vegetation Management, prepared for ANZECC-Environment and Conservation
Ministerial Council and Native vegetation managers in all Australian jurisdictions,
p 58.
[43] Griffin nrm 1999, Native Vegetation
National Overview: States/Territories/Commonwealth Stocktake of Native
Vegetation Management, prepared for ANZECC-Environment and Conservation
Ministerial Council and Native vegetation managers in all Australian jurisdictions,
p 55.
[44] Griffin nrm 1999, Native Vegetation
National Overview: States/Territories/Commonwealth Stocktake of Native
Vegetation Management, prepared for ANZECC-Environment and Conservation
Ministerial Council and Native vegetation managers in all Australian jurisdictions,
p 56.
[45] Senate Official Hansard, 5 September
2000, p 15850.
[46] The Hon Peter Beattie MLA, Premier, Queensland
Acts on Tree Clearing: Beattie, Ministerial media statement, 20 August
2000.
[47] The Hon Peter Beattie MLA, Premier, Queensland
Acts on Tree Clearing: Beattie, Ministerial media statement, 20 August
2000.
[48] The Hon Rodney Welford MLA, Minister for
Natural Resources, Commonwealth Fails Queenslanders on Tree Clearing,
Ministerial media statement, 24 August 2000.
[49] http://www.acfonline.org.au/campaigns/landclearing/briefings/background.htm.
[50] http://www.acfonline.org.au/campaigns/landclearing/briefings/background.htm.
[51] Environment Protection and Biodiversity
Conservation Bill 1998 and Environmental Reform (Consequential Provisions)
Bill 1998, Report of the Senate Environment, Communications, Information
Technology and the Arts Legislation Committee, April 1999, p 50.
[52] Environment Protection and Biodiversity
Conservation Bill 1998 and Environmental Reform (Consequential Provisions)
Bill 1998, Report of the Senate Environment, Communications, Information
Technology and the Arts Legislation Committee, April 1999, p 51.
[53] Environment Protection and Biodiversity
Conservation Bill 1998 and Environmental Reform (Consequential Provisions)
Bill 1998, Report of the Senate Environment, Communications, Information
Technology and the Arts Legislation Committee, April 1999, p 51.
[54] The Australia Institute, Submission 79c,
p 2294.
[55] The Australia Institute, Submission 79c,
p 2294.
[56] Proof Committee Hansard, Canberra,
23 June 2000, p 783.
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