10.3 - Recommended reforms
10.3.1 - A national environmental information supply chain
The provision of information can be viewed like a supply chain. Information is delivered through a series of processes that convert raw data into end products that can be used – by decision-makers to inform their decisions, by proponents to help them understand and design their project proposals, and by the community to understand the impacts of decisions and the outcomes that are achieved.
As with more traditional supply chains, effort and resourcing is needed for an efficient chain that delivers the right products at the right time to the right customers. The customer (or user) is central to the design of the supply chain.
A national environmental information supply chain will cover the entire system of processes and skills to convert raw data into the end products needed to inform the implementation, evaluation, reporting and assurance of the National Environmental Standards and other aspects of the EPBC Act, including State of the Environment reporting. The supply chain will ensure that consistent information is available to each decision-maker (for example, across the Commonwealth or in a State or Territory under an accredited arrangement), and will make it easier for governments to demonstrate that their systems deliver decisions that meet the Standards.
The opportunity to derive benefit from a national supply chain for environmental information is broader than just the EPBC Act. While the focus should be on delivering to the National Environmental Standards, incremental effort can provide a supply chain that delivers to the broader national system of environmental management (Chapter 11).
The steps in the information supply chain, the limitations and inefficiencies in the ‘current state’ and the outcomes from a ‘future state’ that would support the recommended reforms are shown in Figure 9 and Figure 10. An aspect of information delivery that is often overlooked in planning and program design is the need for investment in strong links between the ‘analyse’ step and the ‘use’ step. Technology can increasingly provide user-friendly interfaces and decision-support tools to help end users query and explore information. However, providing tools and reports that are suited to the full range of end users in the context of the EPBC Act, which include assessment officers, policymakers, program managers, industry, landholders and the community, is extremely challenging. There is still a need for easy access to trusted experts who understand the content and context and are skilled at working with the relevant groups. Another important feature of a future-state supply chain is the use of metrics to measure the performance of the supply chain, and good data sharing along the chain to understand where and how the chain could be improved.
Figure 9 - Current state of the national environmental information supply chain
Figure 10 - Future state of the national environmental information supply chain
The supply chain should be based on these principles:
- outcomes focused – delivers value to users across the national system of environmental management, with clear outcomes supported by monitoring, evaluation and reporting
- strategic – delivers sustainable infrastructure, continuous data supply and decision-making tools
- comprehensive – captures, curates and shares environmental data from a range of sources and scales, and supports integration with data from other domains
- collaborative – coordinates and shares data and methodologies managed by experts
- authoritative and transparent – accurate and current, fit for purpose, peer reviewed and publicly available
- future-focused – flexible to new technologies and techniques, with predictive capability to assess cumulative pressures, future scenarios and risks
- respectful – incorporates and protects Indigenous data and knowledge in a culturally appropriate way, consistent with the National Environmental Standard for Indigenous engagement and participation in decision-making
- efficient – reduces duplication and maximises the value of the information assets
- sustainable – ensures that responsibility to maintain, develop and resource the supply chain over the long term is clear and legislated at relevant levels.
An efficient, future-state environmental information supply chain, supported by capable people with the range of capabilities requires strong leadership and a clear vision. The range data streams required will result in the supply chain drawing from multiple sources, including States and Territories. This ‘federated approach’ will focus on building on existing information architectures and standards, technical infrastructure, data sources and modelling capabilities, making them fit for purpose and durable. This will facilitate better sharing and aggregation of data collected under different frameworks.
Demand and accountability for ongoing investment should be supported by embedding clear requirements and expectations for improved information management, reporting in legislation and the National Environmental Standards.
10.3.2 - A framework to deliver a national environmental information supply chain
The Review recommends a framework to deliver a national environmental information supply chain that will complement the other recommended reforms.
Building on Figure 1 in Chapter 1, which shows the components of a robust reform framework, Figure 11 shows the components in the data and information framework and how they work with the other recommended reforms to address many of the barriers faced by previous initiatives, including:
- providing a clear legal mandate and requirement to curate, organise and deliver environmental information
- setting clear outcomes for the regulatory system through a set of National Environmental Standards for MNES (Chapter 1)
- implementing an approach to monitor, evaluate and report on environmental outcomes and performance (Chapter 11)
- an institution, legally accountable for driving, coordinating and setting priorities for environmental information, delivering efficiencies and providing long-term stewardship
- a National Environmental Standard for data and information that sets legal requirements for the use of best available evidence and the provision of data
- a compliance and enforcement regime to ensure people meet the National Environmental Standards for MNES (Chapter 9).
Figure 11 - Components of the data and information framework and how they will improve the supply of environmental information
10.3.3 - A supply chain Custodian with a clear legal mandate and a clear strategy
Given the significant investment required, the supply chain should be delivered in a strategic and coordinated way. A comprehensive roadmap is needed. Responsibility for planning and delivering the supply chain should be assigned to a national institution – the national environmental information supply chain custodian.
The Custodian will have overall responsibility for the long-term stewardship of environmental information and be accountable for ensuring the efficient and effective operation, and integrity, of the environmental information supply chain. It must be independent to decision-making and trusted by stakeholders. To support the implementation of the National Environmental Standard for data and information (section 10.3.4), the Custodian will outline expectations for best available evidence, provide clear guidance on requirements for the sharing and publishing of information, and design and implement a collaborative process for identifying and establishing National Environmental Information Assets. The Custodian will work across the range of existing institutions involved in delivering and coordinating environmental information to learn from existing and past efforts to avoid ‘reinventing the wheel’, identify and fill gaps, make the necessary links and embed best-practice approaches to the use and sharing of Indigenous knowledge (Chapter 2). Over time, the Custodian should seek efficiencies in the stewardship of environmental information of relevance that is beyond the scope of the EPBC Act.
Stakeholders identified that the custodian role could be approached in several ways and there are numerous potential candidates among key national institutions. However, the Review is not going to suggest a particular candidate.
It will be critical for the custodian role to be embedded in legislation to provide a long-term mandate and accountability and avoid unnecessary changes in direction that can arise from short-term program drivers. A potential model for the legal mandate is the responsibility given to the Bureau of Meteorology to manage water information in Part 7 of the Water Act 2007.
The EPBC Act should be amended to strengthen the powers of the Custodian and reflect the objectives and responsibilities of the role. Prior to these amendments, an interim Custodian may be established.
Strategic objectives for the Custodian should include:
- mobilising environmental data from all available sources to make them promptly and routinely available to the entire environmental management community in a standardised, searchable and accessible form
- supporting the curation and management of individual surveys into integrated datasets that give them context and meaning, as a member of the ESD Committee to identify and fill critical data gaps, and providing the systems and expertise to enable these data to be turned into tailored, trusted products and advice
- informing National Environmental Standards and supporting evidence-based decision-making across the EPBC Act
- leading the appropriate management and use of Indigenous data and Indigenous knowledge, drawing on the advice of the Indigenous Engagement and Participation Committee
- working with the Environment Assurance Commissioner to advise the Environment Minister on the application and settings of the National Environmental Standard for data and information
- enabling robust, repeatable and sustainable analysis; allowing optimised policy and decision-making and transparent, efficient decision-making processes; informed monitoring, evaluation, review and reporting frameworks; and providing investment confidence and an informed community
- creating and leading a culture of shared expertise across the Commonwealth, States and Territories with common data standards, policies and incentives for data sharing, and promoting the integration of environmental data with data from other domains
- supporting a network of systems for the persistent storage and archiving of environmental data.
10.3.4 - A National Environmental Standard for data and information
A National Environmental Standard for data and information is an important component of the suite of National Environmental Standards that will clarify expectations and improve accountability.
A recommended National Environmental Standard for data and information, developed with input from experts, is included in Appendix B. It sets out the expectations for all parties involved in the operation and review of the EPBC Act to support the delivery of the national environmental information supply chain.
The National Environmental Standard for data and information will require the collection, curation, integration, analysis, use and sharing of information to agreed technical standards. Its intended outcome is to ensure that decisions made in the operation and review of the EPBC Act are informed by the best available evidence, and that the nature of the environmental outcomes from activities under the Act are understood, documented and accessible.
A requirement for the sharing of environmental data is a major element of the National Environmental Standard for data and information. Proponents will be required to submit data and information supporting development approval applications in a standardised way and this information will be made publicly available. Researchers and program managers will be expected to contribute environmental data into the system where data have been generated as part of a government-funded project.
There are some valid cases where public disclosure of information is not beneficial. Examples include where releasing information would potentially threaten species; to ensure the culturally appropriate use of Indigenous knowledge; for public safety; or where non-disclosure is demonstrably in the public interest. There are established processes in place to deal with sensitive ecological information. Consistency with Australian privacy law, the advice of the Office of the Australian Information Commissioner, and with the National Environmental Standard for Indigenous engagement and participation in decision-making (Chapter 2) and the advice of the Indigenous Engagement and Participation Committee should ensure these valid cases are managed appropriately and respectfully.
The National Environmental Standard for data and information will put clear requirements in place to overturn the impediment to sharing created by claims of commercial-in-confidence. Compliance with the Standard will be a requirement for all activities under the EPBC Act or an accredited arrangement, such as an application for development approval. Once the Standard is in place and the expectations are clear, the market will respond. Consultants unwilling to enter into agreements that allow the sharing of raw data will be not be commissioned as they will not meet proponent needs. When redrafting the Act and the Regulations, every opportunity to remove barriers to and hardwire expectations for data sharing should be taken.
The recommended National Environmental Standard for data and information at Appendix B represents a step change in expectations but is consistent with the current settings in the EPBC Act, which is largely silent on data and information. The EPBC Regulations should be reviewed and updated as soon as possible to remove any impediments to the implementation of the Standard.
The efficient implementation of the National Environmental Standard for data and information will rely on a Custodian with the appropriate technical and policy expertise, and with sufficient resources to develop and sustain the supply chain. Short-term implementation of the Standard will be less effective before further investment and effort to refine the supply chain and the infrastructure to support efficient collection and sharing of information.
Supply chain priorities framed around the National Environmental Standards
The National Environmental Standard for data and information will establish National Environmental Information Assets (NEIAs). These are the essential information streams that underpin the National Environmental Standards for MNES.
A suite of NEIAs, established in a process overseen by the Custodian, will become legal instruments that provide certainty and accountability for priority components of the information supply chain. Prior to legislative change, the NEIAs will be defined in policy.
The NEIA approach is broadly aligned with government commitments to identify, designate and prioritise high-value and critical datasets (DPMC 2020). The approach builds on a 2017 Productivity Commission recommendation to designate ‘National Interest Datasets’ to promote the development of a valuable suite of datasets, with broader community benefits ‘that are be treated – and funded – as the valuable strategic assets that they are’ (PC 2017).
In the context of environmental information, the NEIAs are a prioritisation mechanism that addresses barriers identified from previous attempts to reform the environmental information system. The NEIAs focus effort and resourcing on the datasets or ‘information streams’ (including integration and analysis as relevant) that are essential to support effective implementation of the EPBC Act. This will help ensure the priority information is high quality and well maintained. The NEIAs will:
- provide for the delivery of information to implement, monitor and improve the suite of National Environmental Standards for MNES
- name a responsible organisation and collaborative partners, and identify the data and tools to model and map the state and trends at different scales.
NEIAs should draw on the process, led by the Ecologically Sustainable Development Committee, of delivering a monitoring and evaluation framework for the EPBC Act, including identifying key environmental indicators (Chapter 11), and provide stewardship of the information sources and methods to deliver these indicators. The NEIAs will refer to technical standards that will establish the more specific expectations and format for different data types to support linking, integration and re-use.
10.3.5 - Building the information supply
A first task of the Custodian, or interim Custodian, will be to develop a strategy for delivering the national environmental information supply chain that will identify the ‘quick wins’ and activities that need investment now to deliver benefits in the future.
Make the most of existing information
The environmental information currently available to support implementation of the EPBC Act is clearly inadequate, but imperfect information should not be a barrier to implementing the Review’s recommended reforms. It is counterproductive to wait for perfect information because decisions that impact the environment continue to be made with current information.
Significant gains can be made by making better use of existing information and data by focusing on parts of the supply chain beyond raw data collection and collation. For example, models can provide a way to fill information gaps through structuring expert input and drawing insights from a huge array of remotely collected information. Early implementation of the National Environmental Standards may draw on proxies and surrogates based on readily available information. This will improve over time as data collection and modelling activities improve understanding of state and trends. There are also benefits to investing in identifying and maximising the accessibility and use of priority existing and historic sources – for example, through technologies to automatically extract standardised information from PDF documents (Box 36).
Box 36 - Unlocking 20 years of trapped knowledge from PDFs
Statutory documents about fauna and flora conservation, such as conservation advices and recovery plans, contain over 20 years of key information about threatened species and ecological communities, their habitats, threats and associated on-ground protection activities.
This information is crucial for many environmental decisions, but the knowledge is locked in unstructured, PDF documents that are hard to search, compare and update. Ideally, this knowledge would be available in a format that is easily accessible through search or browsing interfaces to support further analysis. However, the work involved in doing this manually would take considerable time and resources.
A feasibility study undertaken by CSIRO’s Data61 and funded under the Platforms for Open Data program investigated and piloted an approach to automate the extraction of knowledge from PDF conservation advices and recovery plans. The approach used natural language processing to transform a collection of PDF conservation advices and recovery plans with unstructured text into tabular form for searching and browsing to support further querying and analysis.
The study found that a significant amount of the knowledge held in the documents could be automatically extracted into a structured format, providing a first step to making the information contained in these documents more available and reusable. This work can help fast track the update and review of these documents, and support the creation of a single database of similar information held by jurisdictions across Australia that is automatically created and updated. The approach could also be used to extract knowledge from other unstructured text files, such as biosecurity documents.
Build on and focus current initiatives
Many initiatives are already underway to address deficiencies in environmental information. These should continue but with the flexibility to align with the accreditation model, the Custodian’s roadmaps and strategy, and the delivery of data, information and methodologies to support the implementation and evolution of the National Environmental Standards.
The Digital Environmental Assessment Program (DEAP) is a significant investment targeted at digital transformation of environmental assessment. It will support streamlined, integrated and transparent processes, including better management of existing information and improving the interface with regulators and the community. DEAP will be delivered as a partnership between the Commonwealth and Western Australian Government and is further discussed in Box 37. The DEAP is only a pilot at this stage, working with one State. If the pilot is successful, a national roll-out is envisaged, but this will need to be resourced.
Box 37 - Current programs addressing the environmental information supply chain
Digital Environmental Assessment Program
The Digital Environmental Assessment Program (DEAP) is a partnership between the Australian Government and Western Australian Government. Over 3 years the program will deliver:
1) The DEAP portal and assessment system project – providing a significant first step in streamlining the assessment process of the Commonwealth and WA systems. This work will:
- provide a single online portal and shared and standardised approach across the two jurisdictions and an end-to-end workflow system to enable proponents to track progress
- enable the community to see elements of applications, track progress and provide comment (such as formal submissions), which will significantly improve transparency
- increase information capture to support sharing and re-use across systems, providing valuable input to understanding the cumulative impact of projects, and monitoring, evaluation and reporting.
2) A biodiversity data repository – to store and share environmental information (such as wildlife surveys) between proponents, Commonwealth, State and Territory regulators, and the community.
This repository will capture data from field-based ecological surveys of species (native and introduced) and their habitat, vegetation and ecological communities. It will include on-ground measurements and observations, supported by metadata to enable the national collation of high-quality, high-resolution and comprehensive biodiversity data. The data will be relevant to monitoring trends, predictive modelling and management of environmental assets and their threats. The repository will be nationally federated, so data are exchanged freely between Western Australia, the Commonwealth and the Terrestrial Ecosystem Research Network (TERN) in the short term. Over time, other States and Territories and other repositories such as the Atlas of Living Australia (Box 31) will be progressively added. Agreed ecological survey protocols and data standards will reduce the resourcing spent on data integration, which will enable greater sharing, use and re-use for many purposes.
The Australian and Western Australian governments have committed combined funding of $55 million for the 3-year program for digital transformation of environmental assessments. This includes $37.2 million for Western Australia’s delivery of the Environmental Online initiative and Biodiversity Information Office, $15.7 million for the DEAP Portal and Assessment System project and biodiversity data repository, and $2.1 million for other States and Territories to work towards data sharing with the national biodiversity data repository.
Collaborative Species Distribution Modelling Program within EcoCommons
The Collaborative Species Distribution Modelling Program within EcoCommons will provide assurance of the models used by governments to inform environmental management decisions. It aims to provide greater national consistency in modelling and decision-making.
The shared, cloud-based platform currently includes more than 17 peer reviewed species models, each with default parameters. The system provides the ability for government analysts and researchers to compare and share data and models for sensitive species in a secure environment, with the option to re-run the models using the same data and parameters, providing an audit and reproducibility trail.
For more information, see the Environmental data initiatives further reading at the end of this report.
Overhaul the Department’s information management systems
The Department’s information management systems need to be overhauled to provide a modern interface for interactions related to the EPBC Act and to embed within systems the key decision-making frameworks that harness information and knowledge.
A modern interface includes:
- a case-management system that supports the full project lifecycle, including application, assessment, approval, compliance and enforcement (Chapter 4)
- the capacity to link with others – so that information can be provided once and shared many times (for example, with the supply chain Custodian or other regulators and accredited decision-makers)
- the ability to record, share and search information related to EPBC Act decisions in a way that is accessible to both the public and proponents
- the ability to readily communicate decisions using modern communication channels, rather than relying on newspaper advertisements and the Government Notices Gazette (Chapter 3).
The Regulatory Maturity Project (Woodward 2016) identified a range of functions for the ‘ideal IT system’, which were also highlighted in the Craik Review of interactions between the EPBC Act and the agricultural sector (Craik 2018). The DEAP program (Box 37) will deliver some of the necessary improvements to internal systems.
This overhaul needs to be consistent with broader digital transformation efforts across government and draw on whole-of-government leadership on digital systems and services. This includes a greater focus on capability within the Department to make better use of systems and the data behind them. Data should be treated as an asset and staff need to have the capability, motivation and mandate to drive better use of data. This requires a change in culture as well as systems – buy-in from senior leaders will be fundamental (DPMC 2019).
Invest in centralised predictive and ecosystem models
To apply granular standards to decision-making, governments need the capability to model the environment, including the probability of outcomes from proposals, drawing on predictive modelling capabilities and decision-making frameworks for ESD that will be delivered as part of the information supply chain. Predictive modelling efforts will save money and time, ultimately better focusing expensive field surveys and increasing the efficiency of the regulatory system.
To do this well, investment is required to improve knowledge of how ecosystems operate and develop the capability to model them, which is essential for testing scenarios and making informed, risk-based decisions. Predictive ecosystem models that draw on local-level information and understanding will be vital to effective regional planning and understanding cumulative impacts. These models can also support the setting of National Environmental Standards and thresholds (Box 34).
The Commonwealth has a clear leadership role in coordinating the development and application of an ecosystem modelling capability. There is an argument for a predictive modelling capability to be centralised due to the specialist skill sets, high performance computing requirements and benefit of national consistency and potential efficiency.
The 2019 Australian National Outlook work led by CSIRO is an example of how an integrated assessment model can be brought together with expert insight to explore future scenarios for Australia’s natural resources, energy, productivity and services, and cities and infrastructure (CSIRO 2019). In recent years, as part of the 2016 National Research Infrastructure Roadmap, an expert committee has investigated the design needs and requirements for a National Environmental Prediction System. This work could provide a strong contribution, but this scoping effort is only the first step. In the longer-term the focus needs to move beyond the research sector and have enduring funding and governance.
Developing a national ecosystem modelling capability will take time. The strategy delivered by the Custodian can provide a structure to guide short-term investments, so they incrementally contribute towards a longer-term goal, delivering improved capability at each step. A key step will be to overcome the current silos and bring together the main government and business investors. The Shared Analytic Framework for the Environment work being undertaken as the next step for digital transformation of environmental assessment in Western Australia is a starting point to providing a consistent way to identify ‘quick win’ tools and deliver more complex modelling needs.
Operationalising new systems and approaches developed through research programs can be challenging given limitations in departmental IT systems, internal skills and capability, as well as short delivery timeframes. Increasingly, access to computing and modelling capability is moving to the cloud (Box 37). Innovative approaches such as the UK Met Office Informatics Lab can help trial new analytic techniques and tools cheaply and at lower risk to existing systems. For implementation of new IT systems, investment in new modelling capability needs to be complemented by a focus on improving staff capability and expertise.
10.3.6 - Resourcing and sequencing reforms
The Review acknowledges that the quantum shift in information and data systems will come at significant cost. Upfront investment is required to deliver an information supply chain in which all stakeholders have confidence. Ongoing investment will also be required to maintain the system over time. This will improve the effectiveness of Australia’s environmental management and deliver efficiencies for governments at all levels and for business. There is evidence from private sector forecasting that an initial, more significant investment to support digital transformation can reduce the high costs of running and operating out-of-date systems, which can lead to significant ongoing financial benefits as well as better services (DPMC 2019).
A national information supply chain, with a Custodian, should deliver efficiencies for all governments over time. It is an up-front investment that negates the need for multiple systems to be developed by individual governments or to fund new one-off initiatives requiring grants or program funds. However, the investment should be phased and managed appropriately and flexibly, responding to the needs and priorities identified in the supply chain roadmap and strategy. The traditional funding and procurement approach of large one-off investment and change has been one of the impediments to providing sustained and ongoing solutions in the past and should be avoided.
The need for investment in data, information and systems is in part generated by the need to regulate the impacts of development on the environment. Consistent with the principle that the impactor (or polluter) pays, proponents should be required to pay the efficient cost of the share of information, knowledge and systems that underpin the regulation of their activities (Chapter 6).
An efficient information supply chain that provides a forecasting capability and supports the application of granular National Environmental Standards will take time. For success a clear strategy and ongoing funding is required. A coordinated and strategic approach that maximises the use of available information will support short-term advances in priority areas and enable the reforms recommended in this Review to be implemented.
Improvements to data and information will deliver cost savings to decision-makers and proponents, enabling decision-makers to make faster decisions. However, the need for this reform is more than just to provide for more efficient development assessments and approvals. It is essential for the Commonwealth to execute its national leadership role, and overall responsibility for delivering environmental outcomes in the national interest.
Better data and information are also needed to understand the baseline starting point, and to monitor and report on the difference that is being made. Without better data, information and systems, there is no way to determine what activities will deliver the biggest gains, if they are working, or if adjustments are needed to enable outcomes to be delivered (Chapter 11).
The implementation of the recommended reforms should not be delayed for the sake of a better information base. The effort and precaution imposed by working with our existing evidence base will provide a strong incentive to improve the quality of environmental information to fully realise the benefits of the recommended reforms.
The Commonwealth should initiate immediate improvements to the environmental information system by:
- adopting a National Environmental Standard for data and information to set clear requirements for providing best available evidence, including requiring anyone with environmental information of material benefit to provide it to the environmental information supply chain
- appointing an interim supply chain Custodian to oversee the improvements to information and data
- designating a set of national environment information assets to ensure essential information streams are available and maintained to underpin the implementation and continual improvement of the National Environmental Standards for MNES
- expanding the application of existing work with jurisdictions on the digital transformation of environmental assessments and ensuring it is aligned with implementation of the national environmental information supply chain
- commencing the overhaul of the Department’s information management systems to provide a modern interface for interactions on the EPBC Act and support better use and efficient transfer of information and knowledge.
The Commonwealth should build, maintain and improve an efficient environmental information supply chain to deliver the best available evidence to improve the effectiveness of the EPBC Act. Aligned with the second tranche of reform, the supply chain should:
- have a clearly assigned Custodian responsible for providing long-term stewardship and coordination
- have a legal foundation with provisions in the Act that details responsibilities, governance, National Environmental Information Assets and reporting to ensure accountability
- be underpinned by a long-term strategy and roadmap prepared and maintained by the Custodian, with the first strategy due within 12 months
- be supported by a coordinated effort to improve national ecosystem and predictive modelling capabilities
- have adequate up-front and ongoing funding.