Broadly, we are comfortable with the content of the Standard, including the single headline Objective that decisions made under the EPBC Act “are based on appropriate data and information and to extend the availability of credible data and information assets for use in such decisions”.
However, we continue to hold strong concerns regarding the Principles-led approach to implementation, including inconsistencies in the language used to describe how Principles are to be applied in-practice and in a manner that is actually consistent with the Objective and Outcomes of the Standard, and the broader EPBC Act. We are also concerned about how proportionality will operate, and whether the intention for requirements to be scaled and applied proportionately is sufficiently reflected in the draft Legislative Instrument.
The NFF’s full submission can be found here.