Published name
1. Is the biodiversity assessment instrument an appropriate means of achieving consistency in how methods describe biodiversity ?
Yes, we believe it is an appropriate means of achieving consistency if the projects meet their targets in line with the BAI across different methods. Alternatively, a standard unit could be applied to biodiversity gain across different methods. The approach suggested is the best way to achieve consistency apart from a unit-based approach.
2. Does the biodiversity assessment instrument assist in ensuring that methods comply with the biodiversity integrity standards?
Yes, we believe the BAI is well designed to ensure that the methods comply with the biodiversity integrity standards.
3. Do you have any feedback on the scope of this biodiversity assessment instrument?
The BAI is comprehensive and considers aspects that are not always fully considered in biodiversity assessment for example, first nations knowledge/consideration and climate change. It is very encouraging that the scope considers climate change, because this is not considered by the ACCU scheme.
4. Do you have any feedback on the First Nations knowledge, values and data section of the biodiversity assessment instrument?
If there is a conflict between first nations knowledge and scientific knowledge, say on fire management of a project, it is not clear which will take precedence. A dispute resolution process could be put forward that seeks to resolve knowledge and data conflicts if they arise.
5. Do you have any feedback on the measuring and assessing change in biodiversity aspects of the biodiversity assessment instrument, including:
Broader biodiversity benefits mentioned for a project need to quantifiable, certified and monitored and not just assumed to be there and ongoing. There could be a way to assess these and monitor this over time.
6. Do you have any feedback on the consistency and transparency aspects of the biodiversity assessment instrument, including:
-Defining key terms and concepts: In addition to key terms and concepts, examples in text demonstrating the more complex concepts and how these would apply to projects would be helpful.
-Certainty and confidence: if something cannot be measured on projects or proven, it would be good to have a taxonomy of acceptable terms that can be used to demonstrate the confidence level associated with the measure and the requirement for a statement on what would be needed at the project level to improve that confidence level.
-Data transparency is paramount to driving integrity and buy in for this market. A centralised data platform, such as Environment Information Australia would provide this function very well. For this platform to perform efficiently it will need to include meta data and any associated caveats for using particular datasets. Clear data sharing agreements will need to be available. Additionally, a legislated requirement for proponents to share the data they used to apply for relevant certificates/credits would help ensure project-based data becomes publicly available. We encourage the department to consider the successful design and implementation elements of the Digital Earth Australia data platform when designing EIA.
7. Is the proposed Replanting Native Forest and Woodland Ecosystems method consistent with the biodiversity assessment instrument?
Yes
8. Do you have any other comments on the biodiversity assessment instrument?
The Federal Government seems to expect that most purchasing will be by the private sector. We do not think this is realistic at the early stages of the market and would encourage the Federal Government to allocate a budget for biodiversity conservation purchasing and implement a purchasing round as soon as possible after the scheme comes into effect.
In the ACCU Scheme, the Federal Government purchasing of carbon credits was a very effective catalyst for getting the scheme off to a strong start. This should look to be repeated for the Nature Repair Market.
Asking private sector investors what their needs are for a product and educating the Australian marketplace and people in what Biodiversity is and how Biodiversity gain is realised, will be extremely relevant to help commoditise Biodiversity in a way that builds market performance.
What we have seen that will make the private sector invest in a voluntary sense is a requirement to integrate nature into their decision making and movement towards legislated nature-related financial disclosures.
-Additionally we are supportive of issuing more than one biodiversity certificate per project, as this would be more suitable to a trading market.
