Publish and reuse ecological survey data instead of resurveying
The longest single delay in federal environmental approval happens before any application exists: waiting for the season in which a species can lawfully be surveyed. Survey data is collected at proponents' expense, submitted to government, and then not made usable by the next proponent on the next block.
Steps this would change
Rationale
On the residential subdivision process the ecological survey step is 270 days -- the largest single duration in the process, longer than any assessment, and it occurs before the department has heard of the project.
The cause is not bureaucracy. Many survey protocols require observation in a
particular season, and a project that engages an ecologist in April may not be
able to complete a spring requirement until October. Miss it and the wait is a
year. This database classifies it third_party rather than applicant for that
reason: the constraint is the biology.
Which means no procedural reform touches it. The only thing that shortens a seasonal survey window is not having to do the survey, and the only legitimate way to not do a survey is for someone to have already done it and for the result to be available.
Every one of these surveys is paid for by a proponent, conducted to a published protocol, and submitted to government. Then it stops. The next proponent on the adjacent block, asking the same question about the same species in the same season, starts from nothing.
Three things would need to be true:
- Deposit is a condition of assessment, in a structured format, with methodology and survey effort recorded.
- Negative results are published. Surveying and finding nothing is the most valuable and most systematically discarded result in the entire dataset.
- The data is presumptively reusable for a defined period and radius, with the regulator able to require fresh survey where reuse is not appropriate.
This is the point where this project meets its companion transparency project most directly. The reform is not a change to environmental law. It is a decision to treat data already collected at private expense under public compulsion as a public asset.
What is being traded away
The ecological objections here are serious and a proponent of this reform has to carry them, not wave at them.
Ecological data ages, and it ages unevenly. A survey finding a species present remains meaningful for a long time. A survey finding nothing may be worthless within a season -- because the survey was done in a poor year, in drought, after fire, or simply because the animal was elsewhere that week. Presumptive reuse of negative results is precisely the case where reuse is most attractive and most dangerous, and any reuse rule that does not distinguish presence from absence is unsafe.
Survey quality varies and the record does not show it. Deposited data would carry the same variance in rigour that the underlying consultancy market carries. Making it reusable makes weak surveys reusable too, and confers on them an authority the original report did not claim.
It creates an incentive to survey badly. If a negative result can be reused and shortens a future approval, someone benefits from a survey that finds nothing. That incentive does not exist today in the same form and it should be designed against explicitly -- through accreditation of surveyors, audit, and publication of who conducted each survey.
Commercial and cultural sensitivity. Precise locations of threatened species are withheld for good reason, including poaching, and some Aboriginal cultural heritage information cannot be published at all and is not the government's to publish. A reusable dataset has to be built with those constraints designed in from the start, in consultation with Traditional Owners, rather than discovered after launch.
Precedent
State biodiversity data systems and the Atlas of Living Australia already hold large volumes of survey records. The gap is not the existence of a repository but the obligation to deposit usable, structured, methodology-tagged survey effort — including negative results — as a condition of assessment.
Sources
- Environment Protection and Biodiversity Conservation Act 1999 (Cth), survey guidelines for listed species
- Atlas of Living Australia, published biodiversity occurrence data infrastructure