The Business Council of Australia’s (BCA) membership includes more than 120 chief executive officers of Australia’s most impactful companies. We have been engaged with government and stakeholders on the reform of the Environment Protection and Biodiversity Conservation (EPBC) Act since prior to the Samuel Review in 2020. Our membership includes companies directly engaged in EPBC Act assessments and approvals, including in the mining and resources, energy, property, infrastructure, and legal sectors. More broadly, our members also have a strong interest in achieving positive environmental outcomes for the nation, including through policy settings that are durable, credible, and capable of maintaining community confidence.
Accurate and robust data and information underlying EPBC Act decision making ensures that all parties are as well informed as possible in decision making under the Act. Better use of data, through improved transparency and sharing, should deliver more consistent and efficient decisions. It should reduce costs for both proponents and assessors if data can be shared and used by other proponents rather than doubling up on reports where data already is available. Use of new digital tools and data systems, built on high quality data, will be able to provide new insights by bringing together and analysing multiple data sets at once.
If proponents, decision makers, and affected persons all have a shared understanding of the environmental landscape as it relates to a project, it also enables better conversations and better decision making by all concerned. Beyond that, quality data and information that is consistent and comparable is necessary for other stakeholders, such as financial institutions, that are conducting due diligence, portfolio risk assessment, and to inform their own nature related disclosures. At the same time, collecting high quality, detailed, longitudinal data is both costly and time-consuming, and so data requirements need to be proportionate to the environmental risk and context being assessed. Requirements imposed on proponents in terms of ensuring high quality data should also apply to governments in developing their own products, so there is a clear minimum standard for all data and information products, especially given the intention for government data sets and documentation to be made available more broadly to reduce duplication and support consistent decision-making.
Key recommendations
Recommendation 1
- The requirements of the Data and Information Standard should apply to all major inputs into EPBC decision making that are grounded in data and information (e.g. protection statements, recovery plans, etc).
Recommendation 2
- The Standard should recognise that historical and legacy data will not always meet modern metadata, standardisation, or reusability requirements, but still provides a valuable and long-term knowledge base. To address this, elements of the Standard that seek to uplift data collection practices (such as metadata, standardisation, and reusability requirements) should be forward looking, applying primarily to new, rather than historical, data sets. Historical datasets should continue to meet minimum standards of scientific validity and include transparent disclosure of limitations and uncertainty where relevant.
Recommendation 3
- The requirements applied on data and information should be proportionate to the environmental risk, scale and significance of the decision, as well as dataset complexity.
Recommendation 4
- Rather than the note within the Standards that references the CARE and FAIR principles, detailed guidance materials should be developed to provide more substantive expectations for proponents to follow, that clearly operationalise expectations within the Australian EPBC Act context.
Recommendation 5
- Detailed guidelines should be developed to support the implementation of the Standard, subject to consultation, prior to the commencement of the Standard.
View our full submission here.
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