This list is missing social and environmental benefits, risking excluding otherwise eligible projects with public benefits (eg disaster recovery) from fast tracking if they do not provide one of the proposed additional economic benefits. Additional benefits must include social and environmental benefits (including maintaining and restoring ecological integrity, environmental justice, reconciliation) and reduce the breadth of eligible economic benefits.

Additional benefits should include reconciliation, environmental justice, ecological integrity, climate adaptation and mitigation, biodiversity and ecosystem health. This would allow for projects with much-needed environmental or social impacts to receive the same benefits as those projects that present market-based opportunities for economic benefit. To do otherwise is to greenwash this Act, by narrowing the ability for environmentally and socially beneficial Projects to be approved.

A different approach to assessing benefits should be taken. Priority should be given to ‘no regrets’ projects that make the greatest mutually reinforcing, lasting, positive contribution to environmental, cultural, social and economic sustainability, e.g., ecological restoration.