Published name
1. Is the biodiversity assessment instrument an appropriate means of achieving consistency in how methods describe biodiversity ?
To be appropriate, the BAI must be developed to align with the many other initiatives taking place to measure and manage biodiversity. In particular, effort must be given to working with agriculture industries to align with their work in this area, to avoid inconsistency and confusion, and to optimise the Nature Repair Market as a tool for impact on private land. Industry research shows the single biggest barriers to farmer action on natural capital is complete confusion over the sheer volume and inconsistency of noise in this space, and a concern that farm-specific action is not coordinated at a regional level. A BAI that creates another inconsistent layer on top of existing market demands, legislation in different jurisdictions, and farm-scale action to measure natural capital will not be appropriate. Some agriculture industries have been working for several years to address this barrier, and a model to do so is emerging. My responses to other questions are predicated on this view.
5. Do you have any feedback on the measuring and assessing change in biodiversity aspects of the biodiversity assessment instrument, including:
Measuring and assessing change would be most effective if it:
* Uses definitions, indicators, metrics, measures and data sources that are consistent across agriculture industries and at different scales (farm - local - regional - industry - state - national), meet the needs of customers of and investors in Australian agriculture, and can be used to inform better decision-making by farms, industries, policy-makers and others. In other words - BAI measures must make sure we measure biodiversity once, and use that data for multiple purposes
* Uses these consistent indicators along with existing regional and catchment planning processes as the glue for identifying regional priorities for action and having a single source of truth for any landholder to know exactly what voluntary action they can take that will most contribute to identified regional priorities
* Uses data generated from these consistent indicators to take a consistent approach to natural capital accounting (building on the farm-scale work of Farming for the Future) and natural capital assessments (building on the industry-scale work of the cotton industry and QDAF) to better quantify and value the public and private good from biodiversity, to enable better decisions by farms, industries, policy-makers and others
* Projects are eligible for the Nature Repair Market ONLY if they can demonstrate alignment to identified regional priorities. This is essential for sellers and buyers of biodiversity credits to be incentivised to take precise, coordinated change for maximum impact. The Nature Repair Market could be an important tool for moving the dial on biodiversity, as long as it is part of a new approach to support specific farm-scale action that is coordinated at a regional level as part of a nationally consistent approach.
* Monitoring and measuring biodiversity outcomes from projects is the same as a consistent approach across industries and at different scales (from farm-level to State of the Environment) to measure natural capital change over time and against reference states, value natural capital and impacts.
6. Do you have any feedback on the consistency and transparency aspects of the biodiversity assessment instrument, including:
Terms and concepts: As noted above, must be consistent with existing legislation and market demands, and applied across jurisdictions and industries.
Climate change: Not directly related to the Nature Repair Market I think. But essential that, as part of a regionally-appropriate approach to coordinating action on natural capital, robust and credible climate scenarios and impacts are undertaken for each region in line with Climate Related Financial Disclosure legislation. These scenarios can then consistently inform regional planning processes (which in turn should inform Nature Repair market project eligibility as noted in question 6). The same scenarios should be used for multiple other coordinated and consistent purposes, including providing regional context for GHG emission calculators, and enhancing business, industry and government planning
Certainty: I strongly disagree with the discussion paper concept that "failed restoration is not a failure". It absolutely is a failure and should be heavily discounted as such. Otherwise we will see massive numbers of project that push the boundaries of what's possible on paper, and allow project developers to walk away from responsibility for failure. It's also why priority, or at least provision for, using the Nature Repair Market to reward landholders for preserving existing biodiversity must be taken.
Certainty and confidence: The Nature Repair Market should allow for different levels of data confidence (eg gold, silver, bronze) that require differing levels of investment in data (high, medium, low) and will be reflected in the price paid for biodiversity credits. Limiting data confidence to gold standard only will greatly restrict the pool of customers, provide additional barriers to any action at all by land holders, and most likely accrue benefit mainly to project developers and auditors (which should be opposed by the Nature Repair Market as much as possible). Don't create more confusion by reinventing the wheel when defining confidence parameters; existing or emerging initiatives like the GHG Protocol, the Natural Capital Measurement Catalogue, Accounting for Nature / SEEA, and the Nature Positive Initiative all have ways to address this that could be applied to the Nature Repair Market.
8. Do you have any other comments on the biodiversity assessment instrument?
The BAI needs to reward past ecosystem maintenance, not just past ecosystem degradation:
*Restoring previously degraded land is long-term, uncertain and expensive; keeping existing high value ecosystems in place is immediate, certain, and less expensive
*Rewarding the restoration of degraded land rewards past 'bad' practices; excluding payments for existing high value ecosystems is inequitable for land managers who have in the past done the 'right' thing
*Incentivising the preservation of "areas of high biodiversity importance, including ecosystems of high ecological integrity" would directly align action to Target 1 of the Global Biodiversity Framework.
The BAI must facilitate a new approach that doesn't assume the current audit model is by default the best way to provide confidence:
*Buyers of Biodiversity Certificates need to know they get what they pay for, but auditing can add significant expense with limited increased confidence (see carbon markets for exhibit A), diverts huge sums of money away from nature repair and into for-profit companies (with all the inherent conflicts that comes with that)
*The Nature Repair Market should establish a nonprofit national natural capital & carbon auditor (or create the same in an existing trusted, science-based organisation like CSIRO) to be run on a full cost recovery basis. In this way, the market will have increased trust, audit will be efficient, and 100% of audit fees will be returned to public good research.
