Nature Repair Market Legislation

Tuesday, 8 October 2024
Dear Nature Repair Market Team,

Please see responses to the Nature Repair Market Rules from Corporate Carbon below.

Section of the Paper Question
Requirements for Should existing projects be eligible to participate in the Nature Repair Market?
registration Please provide reasons for your answer.

Yes. This is particularly important to ensure the establishment of new projects is
not halted while the scheme is being established/designed.

An example of this is projects on existing Conservation covenants. The pre-
existence of a Conservation Covenant should be clearly eligible, or better still be
preferred, under the scheme. This will ensure existing efforts to grow Australia’s
conservation estate are not thwarted while the details of the Nature Repair
market are debated / finalised.

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.

These rules will need to be clearly defined, as projects that go above and beyond
the legislated requirements should be eligible to participate, even when the
themes are similar. For example, where weed management is legislated; a
project that removes non-native vegetation (beyond those species listed by
legislation) and restores native vegetative habitat should be allowed.

An unintended consequence of only allowing projects outside of legislated
requirements is that the legislation and the scheme cannot be synergistic.
There is a risk that because of the existence of the scheme, Commonwealth,
State or Territory conservation laws are not pushed to be more progressive.

Information to Do you agree that the specified information should be mandatory at the
accompany an application stage?
application Please provide reasons for your answer.

Yes.

Regarding: Details of any natural resource management (NRM) plan(s) or
Healthy Country Plan(s) that covers the project area and how the project has
considered that plan(s).
This should be expanded to include the requirement to align a proposed project
with Commonwealth, State or Territory, regional or local conservation
strategies. Without this requirement, or something on these lines, there is
limited scope for the scheme to assist in implementing larger scale conservation
strategies across whole states/ areas. This would be a missed opportunity to
both ensure the integrity of the scheme and support the continued
improvement of the relevant governmental conservation strategies.

Regarding: Details of the knowledge, skills and expertise of the project proponent
and any other person engaged, or proposed to be engaged, to design and
implement the project.
Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543  Suite 4, Level 16/25 Bligh St, Sydney NSW 2000
AFS Licence No: 430199  1300 227 206 info@corporatecarbon.com.au  www.corporatecarbon.com.au
For this section to be meaningful there will need to be an accreditation scheme
or minimum experience/training requirements for people engaged to deliver the
proposed projects. This could be specified in each method.
Project plans In what ways could the project plan facilitate the registration and
implementation of a biodiversity project?

As Project Plans should identify and mitigate potential risks to the project , a
dedicated section on climate risks should be included.

Types of projects unable Should the listed project types be excluded from the Nature Repair Market?
to participate in scheme Please provide reasons for your answer.

Yes. Activities that may result in land being intentionally degraded prior to the
establishment of a biodiversity project should be excluded from the scheme. As
suggested above, the inclusion of a requirement for projects to align with
existing Commonwealth, State or Territory, or local conservation strategies will
assist in excluding unsuitable projects.

Transitioning for varied Should registered projects be required to transition to new or varied methods?
or ceased methods What exceptions, if any, should be allowed?
Please provide reasons for your answer.

Yes. Registered projects should be required to transition to new or varied
methods, but over timeframes and with support that allows the continued
implementation of the project if the outcomes are still considered
suitable/desirable.
Content of a Do you agree with the proposed content of the biodiversity certificate?
biodiversity certificate Please provide reasons for your answer.

Yes.

However, it is difficult to see how a project can be funded through the issuance
of a certificate if the certificate is only to be issued once the outcome has been
achieved.
The current presentation of the scheme puts most of the implementation costs
onto the proponent. This will likely be a high barrier to entry for the registration
of new projects.
Please consider issuing Certificates at an earlier stage in the project lifecycle
when funds are needed to implement initial project activities. The Biodiversity
reports can then be used as assurance that the expected outcomes are being
achieved.
Perhaps the certificate can be issued in stages of completion i.e. 25%, 50%,
75%,100%. Complete certificates would theoretically fetch a higher value in the
market.

An alternative would be for the government to invest in the scheme initially to
reduce the financial risk taken on by project proponents. This could be in the
form of partnerships with state or federal governments where specific projects
assist governments in meeting their conservation goals.

Project attributes What specific project attributes should be included on a Biodiversity Certificate?

Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543  Suite 4, Level 16/25 Bligh St, Sydney NSW 2000
AFS Licence No: 430199  1300 227 206 info@corporatecarbon.com.au  www.corporatecarbon.com.au
A section should be added that details the Commonwealth, State or Territory or
local conservation strategy that the project falls under / aligns with.

This will help build investor confidence in the fact the relevance of the project.

Project information on Do you agree with the proposed project information to be included on the
the register Register?
Please provide reasons for your answer.
Certificate information Do you agree with the proposed certificate information to be included on the
on the Register Register?
Please provide reasons for your answer.
Category A biodiversity Do you agree with the proposed content for Category A biodiversity project
project reports reports?
Please provide reasons for your answer.
Category B biodiversity Should a Category B biodiversity project report be required every 5 years?
project reports Please provide reasons for your answer.
Yes – in the absence of a Category A biodiversity report for the same project.
Audits at the time of Do you agree with the proposed requirements and contents of an audit report at
certificate issuance the time of certificate issuance?
Please provide reasons for your answer.
Audits to accompany What factors should determine the number and timing of audits for Category A
biodiversity project or B biodiversity project reports?
reports These should be standardised for projects across all methods, as follows:
- Audit after the initial Category A report,
- Audit on the Subsequent Category A report every 5 years.
- In the absence of a Category A report, and if the project is set to continue
after year 5, an Audit of the most recent Category B report.
- In the continuing absence of a category A report, an audit of the most
recent Category B report every 5 years.
Should the CER have authority to set additional audits requirements, or should
these be limited to proponent consent?
These should be limited to proponent consent, but described in the register.
Under what circumstances should the CER require an audit with the next
biodiversity project report?
Notification – significant Do you agree with the proposed definitions of significant and not significant
reversal reversals of biodiversity outcomes for notification?
Please provide reasons for your answer.

Kind Regards,

Dr Kate Dodds
Group Technical Officer
Corporate Carbon Advisory

Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543  Suite 4, Level 16/25 Bligh St, Sydney NSW 2000
AFS Licence No: 430199  1300 227 206 info@corporatecarbon.com.au  www.corporatecarbon.com.au