Nature Repair Committee consultation: Biodiversity Assessment Instrument

Yes, the BAI provides required clarity for consistency in method development. However, the guidance included in the BAI for method development does not appear to have been followed in the development of the proposed Replanting Native Forest and Woodland Ecosystems method.

Yes.

The scope of the biodiversity assessment instrument appears helpful, practical and balanced. We do suggest greater clarity on method development principles and consultation process as outlined later in the submission. The main concerns relate to how it has not been suitably followed, in our opinion, in relation to the development of the posed Replanting Native Forest and Woodland Ecosystems method.

No.

These themes in the biodiversity assessment instrument appear largely suitable from an overall method design perspective for the Nature Repair Act.
We note the BAI includes feedback from experts that notes:
"Experts have noted that comprehensive monitoring may provide greater confidence in the project outcome but can be costly. Remote monitoring may be more cost effective but less accurate. There is rapid innovation in commercially available technologies to support monitoring, so stakeholders have suggested that there is benefit in methods being technology neutral."

This important feedback for methodologies to consider the balance of costs and accuracy, and to be technology neutral due to rapid innovation appears to have been expressly ignored within the Replanting Native Forest and Woodland Ecosystems method. This method does not appear to be high risk, given it is converting largely grassed paddocks into forests and woodlands through environmental plantings. Yet the method uses an extreme amount of botanical field sampling. The method does not allow for innovation, or even the application of existing technologies that have higher accuracy and lower cost per ha of sampling, such as lidar.

While we support the BAI, this document has little relevance if it is not well considered or followed during method development.

The general guidance in the biodiversity assessment instrument appears fit for purpose.
We believe there is a need to explicitly note that buyers are interested in the listing status of both ecological communities and species that will benefit from projects. This should be expressly noted, rather than referring generically to the broader MNES.
The BAI notes:

"An object of the Act is to contribute to building a knowledge base, and capacity, related to the enhancement or protection of biodiversity in native species in Australia."

While Climate Friendly agrees that projects should and will help build the knowledge base on biodiversity in native species, we believe the application of this principle within the Replanting Native Forest and Woodland Ecosystems method has included a high level of additional costs, that will impact use of the method. For example, there should be no requirement in this method for faunal monitoring beyond incidental observations made during field work. Targeted faunal monitoring of all listed species is expensive and should be the focus of a separate methodology.

The Replanting Native Forest and Woodland Ecosystems method is inconsistent in many respects to the BAI. The extent of the inconsistencies is too great to outline in full detail in this submission and we are happy to meet to further discuss in depth. Some key examples of inconsistency are:
1. The BAI notes:
"Higher risk projects that may require more comprehensive and accurate monitoring and in-field assessment include where:
• the project site is likely to have high biodiversity or biocultural value (e.g. threatened species or cultural sites)
• existing information on the project area is limited or low accuracy
the proposed management activity is innovative
confidence in activities leading to outcomes is lower."

Yet the method, which appears low risk as it does not appear to fit any of the criteria for high-risk project, includes an extremely detailed, specific and high cost in-field observation requirements. This does not appear aligned with the intent of the BAI.
2. The BAI notes methods need provisions to allow the ‘use an alternative monitoring protocol, provided that projects provide a rationale, or demonstrate that the alternative protocol meets the required standard.’ The method does not include these provisions.
3. The BAI notes the need to consider alignment with the ACCU scheme. The method is restricted to Environmental and Mallee planting carbon projects, rather than accommodating all projects under the carbon scheme that include planting of tube stock or seed. This is required to ensure the planting projects developed under other methods, including the IFLM method that DCCEEW is leading development of which will have a plantings activity module, are interoperable with the method. The method also includes no clear alignment with Land Management Strategies/permanence plans under the ACCU Scheme and project plans under the proposed NR Act method. The method also includes no transitional arrangements for existing plantings projects, despite feedback on the Rule showing broad acceptance of this need.
4. The BAI notes the need to enable innovation, yet the method includes zero flexibility and relies on 1980s style field sampling.
5. The BAI notes that methods should not contain conditions that restrict the use of Indigenous knowledge and practices, then the method outlines restrictions of the application of fire as a management tool.
6. The BAI notes the need for quantified measures of statistical uncertainty, yet the method uses unusual spatial scale rules, rather than statistic certainty estimates.
7. The BAI notes that some methods may be targeted at specific outcomes that are not captured by standard biodiversity project characteristics, including hydrology and chemical characteristics. The proposed method is not focused on hydrology of chemical characteristics, yet requires reporting on hydrology (wetlands) and assessment of chemical contamination. This appears to not align with the intent of the BAI.

8. The BAI notes:
" It would be expected that as part of the method development process:
• methods demonstrate how data and information used to inform the development and implementation of the method and assess biodiversity outcomes (through incorporation) is appropriate and suitable for the application."

The method includes collection of overlapping data from line intercept and box plots, yet doesn’t seem to use the box plot data in calculations (noting box plots can provide the required information suggested to be used in line intercept transects). The method also includes full botanical surveys of all flora species, yet the method does not appear to use this information. A more cost-effective technique would involve identification of 5 dominant species in trees, shrubs, vines, grasses and forbs, and a species count (not floristic ID) of other rarer species.

Overall, the BAI appears to provide a sound base for method development and market interpretation. The issue appears that it has not been well considered during method development. It is unclear how this has occurred given the Nature Repair Committee released both documents at the same time.
To avoid similar repeats in future method development, the BAI may benefit from including some very clear criteria upfront with which methods will be assessed by DCCEEW before public release, and clarity on suitable consultation processes. Criteria could include that methods must:
1. be able to be applied. Including having been piloted on an actual project and tested by practitioners to ensure the method works
2. be cost-effective through balancing risk and sampling,
3. enable innovative technologies with higher accuracy and/or lower cost,
4. Align with carbon farming methodologies,
5. Not be released before all supporting tools are finalised,
6. Checked for consistency and to ensure all collected data is used in the method calculations and analysis is aligned with the BAI,
7. Be check with CER to ensure the method can be successfully administered for compliance.

Many of the above criteria can be achieved through adequate consultation and co-design with practitioners who will likely apply the method, before its provided to the Committee for consideration. We do not believe suitable consultation occurred in this instance, and the consultation that did occur, appears to have been largely ignored.
On a more minor note, we also believe the BAI would benefit from more express noting that the listing status of ecological communities and species should have higher prominence in methods and the register.