Dr Megan Evans is grumpy. She is frustrated with the government’s approach to its latest biodiversity legislation, the Nature Repair Market Bill.
In a speech to the Environment Institute of Australia and New Zealand symposium in Sydney on Wednesday, the senior public sector management lecturer at the University of New South Wales is concerned that the government has watered down its definition of Nature Positive.
“If it delivers measurable net positive outcomes against a fixed historical baseline, it’s Nature Positive. If it’s anything else, it’s just toxic nature positivity.”
Toxic nature positivity ignores and experiences losses inadvertently or on purpose doesn’t address the underlying causes, she explained. Anyone that uses “nature positive” as an adjective should be avoided. “Because nature positive is an outcome, It’s not a description of an activity.”
Evans cites a paper from distinguished Oxford University biodiversity professor EJ Milner-Gulland that warns that of nature positive being diluted from an overall measure of net gain. She is particularly concerned that amid all the positive nature claims Fortune 100 companies are making, in 2021 only 10 per cent of these have commitments that are measurable and time bound.
Evans conceded that she is feeling “slightly less grumpy” than she did a few months ago when she first started giving talks on the government’s Nature Repair bill.
She remains concerned that there are no mentions of offsets in the main piece of legislation – it all appears in delegated legislation outside the Act that the government will use as the basis of regulation for offset market, which doesn’t have to do through parliament.
“We’ve got a train going through, basically throwing down the track as it runs along it. It’s all going very quickly, without the framework that we really need.”
Her concern about the nature repair market bill is three-fold: first, she is concerned that it will lead to inadequate offsetting.
Certificates are not a liquid fungible commodity
She said the government conflated a “certificate”, which is issued per project, with a “credit” – a fungible instrument traded in the carbon market. “The point is, certificates are not a liquid fungible commodity. This is a different kind of market, it’s not going to operate in the same way that a carbon market does.”
Third, she is concerned that the process will involve a lot of value judgements about the relative importance of different species, such as whether the loss of a species’ habitat in a certain area is acceptable. “At the moment, there has been no method proposed to make these decisions.”
Evans pointed to a recent PwC report that found that the biodiversity market should not include biodiversity offsets and that they should instead prioritise “stewardship certificates” for good conservation outcomes.
Responsible investment market grows
Estelle Parker, executive manager at the Responsible Investment Association of Australasia said the total “responsible investment market” in Australia – asset managers that invest based on environmental, social and governance considerations – accounts for 43 per cent of the funds management industry.
“There’s a growing interest by big investors in investing in this space in particular green property biodiversity, reforestation, climate change and sustainability. Recently there has been strong interest in sustainable land management and water, and healthy rivers and oceans.”
Parker said she has tracked a growing interest in conservation agriculture and the growth of green and social impact bond. She said super funds are getting a lot of pressure from their beneficiaries to align their investments with their values.
The RIAA did research last year that showed 80 per cent of Australians expect their bank and super fund to invest their money responsibly and ethically. “And 74 per cent would consider moving to another provider if they found out that their super was not invested in line with their values.”
Fossil fuels and logging were activities that super fund members particularly wanted to exclude from their investments.
Parker said the federal Treasury had been aiming to make Taskforce for Climate-Related Financial Disclosures mandatory by financial year 2024-25, and was considering applying the rules to ASX 300 companies. However, she is concerned the timetable may slip a little.
Encouragingly, she said the Taskforce for Nature-Related Financial Disclosures was being taken up even more rapidly than the TCFD. The final framework is due for release in September, and will eventually become mandatory in reporting.
Finding appropriate metrics is becoming easier, with the release of the Science Based Targets Network, which has launched a set of targets for nature-related disclosures, including land use, water withdrawals, nutrient loading and land conservation levels, conservation economist with WWF Australia Joshua Bishop told the conference.
“Ideally, we would bring the idea of planetary boundaries down to a landscape or catchment level and define targets or thresholds [for acceptable use of a particular resource,” Bishop added. “This is currently a data gap, but with sufficient private investment we could get there.”