Submitted: November, 2025
Community for Coastal and Cassowary Conservation (C4) welcomes the opportunity to comment on the Environment Protection Reform Bill 2025 and the related bills.
C4 is a volunteer-led conservation organisation established over 30 years ago on Djiru Country in Mission Beach, Far North Queensland. Our region sits between two World Heritage areas, the Wet Tropics and the Great Barrier Reef. It is home to the endangered southern cassowary, rare littoral rainforest, internationally significant wetlands, and coastal ecosystems that support local communities, Djiru cultural values, biodiversity, and regional tourism.
Our members have protected this place through three decades of advocacy, land restoration, wildlife rescue, education, and community action. Many of our predecessors were forced to protest at bulldozer lines to stop the destruction of cassowary habitat. They did this because the laws of the day did not protect what mattered. We would like to believe we have moved beyond that era. Unfortunately, the current reform bills do not show the level of progress that nature, communities and future generations deserve.
We support the intention to reform the EPBC Act, but the bills before the Parliament will not deliver the strong, modern and science based protections needed to stop biodiversity decline or safeguard vulnerable ecosystems in the Far North. These reforms must be strengthened.
1. Clear and enforceable rules, not subjective discretion
C4 supports the move to National Environmental Standards. Strong standards could provide a consistent foundation for protecting nature across sectors and jurisdictions. However, the bills do not make these standards binding in a meaningful way.
We have identified significant weaknesses in the current design of these standards, including tests that rely on whether a decision maker is “satisfied” something will not cause unacceptable impacts. This is too subjective and risks repeating the problems of the past. Excessive reliance on ministerial discretion has already contributed to approvals that have harmed sensitive environments, including Reef catchments and threatened species habitat. This pattern must not continue.
We call for standards that are clear, measurable and enforceable, with objective tests rather than flexible interpretations. The rules must be written in the Act, not left to later regulations developed after commencement. Communities need certainty about what protections will actually exist once these laws pass.
2. Federal protections must remain strong, especially in regions like Mission Beach
Mission Beach is a frontline example of why strong Commonwealth oversight is essential.
Our region contains:
- Habitat for the endangered southern cassowary
- Littoral rainforest listed as a critically endangered ecological community
- Landscapes that link two World Heritage properties
- Reef catchments that are already under significant stress
Federal protection is often the only safeguard when state based processes do not fully consider cumulative impacts, climate risks or long term ecological thresholds. Weakening federal powers or devolving approvals to states will put World Heritage values and threatened species at risk.
C4 is particularly concerned about proposals that would allow increased devolution of approval powers without proven assurance mechanisms, and about exemptions that allow destructive activities to proceed without federal scrutiny.
The lessons from cases like Kingvale Station, show that state approvals alone are not enough to prevent irreversible harm. Communities need a strong and independent federal guardian for nature.
We therefore call for:
- Retention of strong federal approval powers
- No weakening or removal of triggers that safeguard Reef catchments and water resources
- An independent National EPA as the primary decision maker, not a delegate of a Minister
Without these protections, places like Mission Beach will face increased risk of clearing, fragmentation and cumulative development pressure.
3. Close deforestation and land clearing loopholes
Queensland remains the epicentre of land clearing in Australia. Clearing in Reef catchments continues to contribute to sediment loads, water quality decline and ecosystem impacts. Habitat loss is a direct threat to cassowaries and other species that depend on connected rainforest corridors.
Several risks are present in the current reform:
- Loopholes under Regional Forest Agreements
- Exemptions for continued agricultural use
- The lack of oversight for remnant and regrowth vegetation
These gaps undermine public confidence and place ecosystems like Mission Beach’s coastal rainforests and wetlands in ongoing danger.
C4 calls for:
- Removal or reform of clearing exemptions that allow destruction of threatened species habitat without assessment
- Application of National Environmental Standards to native forest logging, with no carve outs
- Strong rules to prevent further fragmentation of cassowary corridors and rainforest remnants
Without these reforms, land clearing will continue to erode the very values these laws are supposed to protect.
4. Climate change must be recognised as a core environmental risk
The bills do not require decision makers to assess or respond to climate impacts. This is a significant omission.
Far North Queensland communities are already living with increasing heatwaves, coastal erosion, coral bleaching, mangrove dieback and extreme rainfall events. Climate change magnifies every pressure on our biodiversity and ecosystems. The Wet Tropics and the Reef, both World Heritage listed, are directly threatened by climate change, yet the EPBC reforms do not meaningfully engage with this threat.
We advocate for:
- Assessment of full emissions profiles for developments
- Consideration of climate change scenarios when evaluating project impacts
- Climate harm to be treated as an unacceptable impact under the Act
Nature laws that ignore climate risk cannot protect nature.
5. Offsets and the Restoration Contributions Fund must not become a pay to destroy system
Offsets have long been misused as a tool to justify clearing rather than avoid it. The proposed Restoration Contributions Fund creates significant risk that developers will pay into a fund instead of avoiding or repairing ecological harm.
This risks further damage in regions like Mission Beach where:
- Habitat is highly fragmented
- Replacement habitat does not exist
- Restoration cannot recreate old growth or complex rainforest systems
Avoidance must always come first. If the law allows payment in lieu of protection, Mission Beach will continue to lose irreplaceable ecosystems.
C4 supports:
- Strong constraints on any restoration fund
- A genuine avoidance first hierarchy
- No approval of actions that cause irreversible harm, even if money is offered
6. Stronger requirements for community engagement, transparency and rights to be heard
The draft bills leave community participation standards uncertain and possibly weakened.
Mission Beach residents have a long history of active participation in planning decisions. That involvement has protected critical habitat that would otherwise have been lost.
We call for:
- A legislated Community Engagement and Participation Standard
- Clear rights to comment on assessments, decisions and variations
- Transparent publication of decisions and environmental data
Communities must not be sidelined, especially in areas where local knowledge is essential for protecting sensitive landscapes.
Protecting Mission Beach
Mission Beach is one of the most significant biodiversity regions in Australia. It is a place where rainforest meets reef, where Djiru cultural heritage remains strong, and where people travel from around the world to experience natural beauty, wildlife encounters and cultural stories.
This region cannot afford weaker protections. The laws passed in 2025 will shape the next 30 years of outcomes for cassowaries, rainforests and coastal ecosystems. We need legislation that recognises the value of this place and protects it for future generations.
Conclusion
C4 urges the Committee to strengthen the Environment Protection Reform Bill 2025 and related bills so they deliver genuine improvement for nature, communities and climate resilience.
We specifically request:
- Strong, clear and enforceable National Environmental Standards
- Objective legal tests rather than subjective satisfaction of a Minister or delegate
- Retention of robust federal oversight and triggers
- Closure of deforestation and clearing loopholes
- Mandatory climate considerations in decision making
- A strong and independent National EPA
- A meaningful participation standard that upholds community voices
- An offsets framework that avoids harm, rather than paying to excuse it
The people of Mission Beach have worked for decades to protect this place. Reform must honour that history and match the urgency of the ecological crises we face. We do not want to return to a time when the only way to protect ancient rainforest and cassowary habitat was to stand in front of bulldozers. Australia can do better than that. These reforms must reflect that.
Thank you for considering our submission.
Community for Coastal and Cassowary Conservation (C4)
Mission Beach, Djiru Country, Far North Queensland