ACSI response to the Department of Climate Change, Energy, the Environment and Water’s (DCCEEW) discussion paper on Implementing Australia’s Strategy for Nature 2024-2030.
Summary position
Nature-related risks can pose a significant financial risk to companies with operations that are dependent on, or impact, biodiversity. Given the potential scale of nature-related risks and opportunities, ACSI prioritises nature-related issues in our engagement with listed companies, in our research program and in our public policy advocacy.
The Discussion Paper on Implementing Australia’s Strategy for Nature 2024-2030 (the Discussion Paper) is a positive step towards a coordinated national approach to meeting Australia’s international commitments and addressing the risks posed by the degradation of nature. We recommend an ongoing focus on this issue over the longer term to consider how a coordinated national approach could contribute to a more resilient economy.
Our submission makes targeted suggestions to inform the ongoing development of the Implementation Plan. Firstly, it would be valuable for the Implementation Plan to clarify how the reforms to the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) relate to the Implementation Plan. Secondly, the Implementation Plan should be integrated with the Government’s recently articulated climate change priorities. Finally, there is an opportunity to provide detail on a more comprehensive approach to achieving circular economy objectives and how this works towards both nature and climate related objectives.
Clarify the role of EPBC Act reform
Graeme Samuel’s 2020 review of the EPBC Act concluded that the legislation “does not enable the Commonwealth to effectively fulfil its environmental management responsibilities to protect nationally important matters.” The Government has committed to reforming the EPBC Act, including by establishing National Environmental Standards that set clear outcomes to guide project approval processes. However, references to legislative reform are absent from the Discussion Paper.
Given the potentially significant impact of EPBC Act reform on national environmental outcomes, ACSI recommends that the Implementation Plan include the Government’s reform priorities and the anticipated impact of legislative change. Incorporating the Government’s plans for establishing enforceable National Environmental Standards, and how they would contribute to meeting the targets set out in Australia’s Strategy for Nature 2024-2030, would help bring the various elements together to provide a more holistic policy signal to the market.
Integrate with the Government’s climate change priorities
The Government’s recently announced 2035 emissions target, as well as the expected climate impacts outlined in the National Climate Risk Assessment, have highlighted the challenging task ahead for Australia to effectively reduce emissions and adapt to the impacts of climate change.
The Discussion Paper outlines some important links between the protection of nature and responses to climate change, including by identifying the value of nature-based solutions. ACSI supports consideration of these issues holistically and encourages the Implementation Plan to set out a more specific, coordinated strategy for achieving Australia’s nature and climate change objectives. Policies which influence how competing land uses are balanced are significant in this context.
The Government’s Net Zero Plan includes a section on “Balancing land-based abatement with other land management goals”. Further, one of the strategic objectives of the Agriculture and Land Sector Plan is to “support diverse landscapes, balancing agricultural production, carbon storage and nature repair”. In-line with this, it would be beneficial if the Implementation Plan provides more information on how these strategic objectives are to be achieved.
This concept is contemplated in ‘Outcome 3: Integrated climate and nature policy approaches are reflected across policy and decision making’. However, further consideration of land use trade-offs could contribute to credible policy frameworks and enable the development of policy responses which address multiple objectives (for example, to both regenerate nature and sequester carbon).
Detail a more comprehensive approach to achieving circular economy objectives
ACSI supports the target included in Australia’s Strategy for Nature 2024-2030 to “increase Australia's circularity rate and reduce pollution and its impacts on biodiversity by 2030”.
ACSI engages with listed companies on circular economy matters, including by encouraging consideration of the risks of resource-intensive processes and the potential long-term opportunities associated with shifting to more circular practices. However, in some circumstances, policy mechanisms such as regulation or financial incentives, are needed to make significant progress towards a circular economy.
Therefore, there is an opportunity for the Implementation Plan to outline more specific policy responses that can enable progress towards a circular economy and how they might help achieve nature and climate goals, to support a more resilient economy over the long-term.
