On the basis of comments received, EIANZ was able to make the following recommendations to the Senate:
- To find a way to substantially improve recognition, at the senior-management and office-floor level, of the true relationship between threatened species and overall biodiversity management, as it relates to the objectives of the EPBC Act. Ultimately, this needs to underpin a ‘re-education’ of the public, as to the real economic value of biodiversity.
- To find a way to identify and implement basic policy needed to make the Act work. These policies are far-ranging and in many cases, do not need to be particularly prescriptive. They should mostly be geared towards identifying appropriate needs, requirements and standards where this is not readily available to planners and the public. EIANZ Ecology is particularly interested in any opportunity to develop national guidelines for ecological impact assessment. This process has been achieved recently by the Institute of Ecology and Environmental Management and the UK government.
- To consider how the implementation of the Act could be made more efficient, by a cross-pollination of experience and ideas between public administrators and the private consulting sector, who work daily within the planning legislation and have either very strong academic or practical experience credentials.
- The profession is just as concerned about poor standards within the consulting trade, as much as lack of skills in the public sector. The success of environmental legislation like the EPBC Act depends on us as much as it does on the government. We would like to consider how minimum qualifications / experience, as reflected through Full and Association membership of Institutes like EIANZ and the Certified Environmental Practitioner (CEnvP) process, could be better recognised.
- To consider how the scope of Australia’s commitments to the Convention on Biological Diversity (CBD) could be realised through more over-arching biodiversity controls. Our members believe the Act fails because the scope is limited to threatened species, whilst biodiversity management is more holistic. In order to protect threatened species, the EPBC Act cannot only apply to them alone – even though they may be triggers to decide at which locations the Act should apply. In accordance with Part 3 and Part 3A of the Act, it exists to maintain and enhance biodiversity as a whole, consistent with Australia's obligations to the CBD. If a threatened species is relevant, then it survives due to its relationship with whole-site ecology (all species are linked together in the landscape). Perhaps once triggered, the regulations and policy should apply to the landscape in question, not simply the controlling provisions. If this were to occur, it could begin to address another concern of members that is the limited scope of Commonwealth intervention in major projects.
- To consider how the current listing process can be strengthened, drawing on independent data and becoming more proactive, rather than reactive to species decline.