Published name
Confirm that you have read and understand this declaration.
What sector best describes you or your organisation?
Scientific and Consulting
Should existing projects be eligible to participate in the Nature Repair Market?
Please provide reasons for your answer.
Yes, subject the proviso given that the project proposal represents additionality compared to the pre-exiting project that would otherwise not have existed without the new project proposal.
Do you agree that each registered project must include activities beyond those required under a Commonwealth, State or Territory law?
Please provide reasons for your answer.
Yes. If it is currently required under existing Commonwealth, State or Territory law, then it is not additional and funding and outcomes have already been built into other frameworks and project funding requirements.
Do you agree that the specified information should be mandatory at the application stage?
Please provide reasons for your answer.
Yes. Also that the benchmarking studies include sub-soil carbon and biodiversity assessment to ensure additionality includes not just macro-biodiversity, but micro organism biodiversity also as these as important in supporting overall biodiversity as things like canopy (shade), water and nutrient retention. Consideration should also be given to the timing, provision and type of habitat boxes for the early re-introduction of birds and mammals
In what ways could the project plan facilitate the registration and implementation of a biodiversity project?
The project plan should also set out:
- progress review and reporting processes and periods;
- species types and introduction schedules and be divided into plant, animal, insect and microorganism species.
Should the listed project types be excluded from the Nature Repair Market?
Please provide reasons for your answer.
Yes. For similar reasons, otherwise it is likely to create significant unintended consequences in driving the illegal clearing of land or draining of wetlands. The perpetrators of illegal acts or related companies or individuals should not be able to benefit from their criminal acts for a minimum period of 10 years.
Should registered projects be required to transition to new or varied methods?
What exceptions, if any, should be allowed?
Yes registered projects should be required to transition to new or varied methods.
Please provide reasons for your answer.
The listed exceptions as suggested seem sound and adequate.
Do you agree with the proposed content of the biodiversity certificate?
Please provide reasons for your answer.
Yes but suggest that the Biodiversity Certificate also include local and regional biome and geomorphological descriptors as well as river and estuarine watersheds it drains into and significant ecosystems it adjoins or is intended to add to and GIS Geotags. This will enable better mapping and contextualisation as well as more easy identification of any nearby projects or initiatives that might create synergistic outcomes.
What specific project attributes should be included on a Biodiversity Certificate?
Agree with the suggested content. Biodiversity Certificates should also include local and regional biome (IBRA region and sub-region) and geomorphological descriptors as well as river and estuarine watersheds it drains into and significant ecosystems it adjoins or is intended to add to and GIS Geotags. This will enable better mapping and contextualisation as well as more easy identification of any nearby projects or initiatives that might create synergistic outcomes. Project attributes should also report subsoil microorganism enrichment expectations as well as bird and mammal enhancement strategies and expectations, and feral plant and animal control methodologies.
Do you agree with the proposed project information to be included in the register?
Project reporting suggestions are reasonable.
Please provide reasons for your answer.
Reporting should also included and be based on transparent benchmarking studies and report additionality of macro and micro organisms to the extent reasonable.
Do you agree with the proposed certificate information to be included on the Register?
Please provide reasons for your answer.
Yes, however the Ceased Certificate register should also include a summary of the actual outcomes achieved by the project in terms of macro and micro biodiversity, soil water retention, water quality if relevant. Soil carbon could be included as a proxy measure for microorganism biodiversity.
Do you agree with the proposed content for Category A biodiversity project reports?
Please provide reasons for your answer.
Yes agree with the above, but also any project reporting should be assessing climate risk profile in relation to shifting or extreme events modelling likely for the project area. We cannot blithely assume ‘business as usual’ ecosystem outcomes and project plans should include mitigation strategies for likely climate-change related risks.
Should a Category B biodiversity project report be required every 5 years?
Please provide reasons for your answer.
5 years is too long for either category A or B. To ensure project viability in the early stages the timelines for review should be closer in the beginning and lengthen as plantings establish. Initially 1 year, then 3 years, then 5 years and as planting mature every 10 years might be adequate. But years from the outset encourages ‘cut and run’ strategies and does not adequately monitor establishment and maintenance regimes to ensure early establishment and retention.
Do you agree with the proposed requirements and contents of an audit report at the time of certificate issuance?
Please provide reasons for your answer.
Yes, although the amended reporting regime suggested above would mitigate the need for audits if they were conducted by independent third parties.
What factors should determine the number and timing of audits for Category A or B biodiversity project reports?
The CER Should have the discretion in certain circumstances to add a requirement to an audit. This should allow the CER to follow up matters that have come to their attention through other mechanisms or likely triggers, e.g. abnormal climatic or weather conditions.
Should the CER have authority to set additional audits requirements, or should these be limited to proponent consent?
Yes. They should not be limited only to proponent consent.
Under what circumstances should the CER require an audit with the next biodiversity project report?
Unusual climate, feral or other relevant external or internal issue or reversal event comes to the attention of the CER and appear put project outcomes at risk thereby warranting investigation.
Do you agree with the proposed definitions of significant and not significant reversals of biodiversity outcomes for notification?
Please provide reasons for your answer.
These thresholds seem relevant and reasonable and are in line with other rules for e.g. Environmental Product Declarations (EPDs) under ISO 14025, and EN 15804. These are globally established and implemented standards in use in Australia and relied on by other sectors such as the building sector.
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