Introduction

The Biodiversity Council welcomes the opportunity to provide feedback on the draft Enhancing Native Vegetation (ENV) method. There are three elements:

1. Nature Repair (Enhancing Native Vegetation) Methodology Determination 2026 (‘the method')
2. Detailed explainer Exposure Draft Enhancing Native Vegetation Method (‘the Explainer’)
3. Nature Repair Market – Enhancing Native Vegetation Method Explanatory Materials for Nature Repair Committee consultation (‘the Consultation Paper’).

Our understanding

The Nature Repair Market is a national, legislated biodiversity market designed to support voluntary action on nature repair and may also provide a source of environmental offsets.

Methods are legislative instruments made under the Nature Repair Act 2023. Methods must be consistent with the biodiversity integrity standards (BIS) defined in the Act and the biodiversity assessment instrument (BAI).

Projects seeking to trade on the Nature Repair Market must be registered under an approved method. Methods in the market:

• define the conditions that must be met for a project to be registered and for proponents to be issued with a biodiversity certificate
• specify the activities that project proponents can carry out and any restricted or prohibited activities
• specify required reporting, notification, record keeping and project monitoring
• require projects to have a project plan detailing how the project will be implemented to achieve its biodiversity outcome.

The ENV method is the first method to allow offsets.

As noted in our submission regarding the new rules under the Nature Repair Market, we are concerned that the NRM is not fit-for-purpose for offset delivery. We have serious concerns that the offset requirements are simply ‘bolted-on’ to the existing frameworks for carbon credits without considering how the scheme will work holistically considering the role of new institutions and the feedback loops required to ensure that the system has integrity. This is further elaborated in our submission.

In regard to the ENV method, our focus is offset delivery. Specific concerns are outlined below.

Our key concerns are listed below. Please see the submission for more detail.

1. A project can be used to offset an impact on a threatened species even if there is no real world improvement in an outcome for a threatened species
2. No metric for calculating a specific ‘quantum’ of offset to compensate for a specific ‘quantum’ of impact