One of the major concerns about the NSW government’s biodiversity laws is the fundamental flaws in the Biodiversity Offsets Scheme, which will lead to the widespread clearing of remnant bushland in the Greater Sydney area, in return for developers' cash payments – see STEP Matters Issue 191. The application of these payments is unlikely to make up for the biodiversity that is lost. Several groups are so concerned that they have written a joint open letter to the premier. It is not only environment groups involved. Others are the Heart Foundation, the Institute of Landscape Architects and the National Trust.

The letter (see below) calls for action from the government to make the rhetoric a reality that the legislation will improve biodiversity within Sydney. Members of the general public are invited to sign the letter.

Dear Premier

With Sydney’s population projected to grow to 6.4 million by 2036 and the worsening climate change-related urban heat island effect, we write to urge you to ensure that adequate levels of green space are provided to all Sydney-siders and Sydney’s unique bushland and wildlife is protected.

Sydney-siders highly value access to a range of formal and informal green spaces – trees, bushland, parks and sporting fields. This is borne out in previous public surveys and the strong community reaction whenever public green space is sold-off or alienated for development.

Extensive research, both in Australia and overseas, clearly shows that the environmental, social, spiritual and economic benefits of green spaces are irrefutable. Green spaces cool our city, reduce energy costs, increase property values, promote healthy lifestyles, improve air and water quality, reduce net carbon emissions, prevent stormwater runoff and provide important wildlife habitat.

Sydney's green spaces also play a key role in the health of Sydney's iconic blue spaces. For example, the revitalisation and resilience of Greater Sydney's six major river systems – Hacking, Georges, Cooks, Parramatta, Nepean and Hawkesbury, as well as Botany Bay and Sydney Harbour depends on the health and connectivity of the surrounding vegetation.

Despite these benefits, current NSW government policy and legislation is failing to protect Sydney’s green spaces as these are actively being depleted by clearing and alienation for grey urban and industrial infrastructure development. The Total Environment Centre’s SOS Green Spaces map highlights over 70 green spaces currently at risk of destruction. This includes peri-urban areas undergoing rapid development and the impacts of major transport infrastructure projects such as the South East Light Rail and WestConnex. This deteriorating situation must be addressed as a matter of urgency.

A Plan for Growing Sydney Direction 3.2 aims 'to create a network of interlinked, multipurpose open and green spaces across Sydney' also known as the Green Grid. This concept is also supported by the work of the Greater Sydney Commission. However, specific actions, policies, legislative changes and funding are required to shift this concept from rhetoric to reality.

As key stakeholders representing a wide range of interests and expertise about urban green spaces, we urge you to:

• Assign responsibility for planning, implementing and monitoring Sydney’s green spaces to an independent body with the mandate, skills, funding and resources to achieve a comprehensive network of formal and informal green spaces designed to maximise benefits to Sydney-siders and protect Sydney's unique bushland and wildlife in the long-term.
• Prevent the clearing of bushland in the Greater Sydney area unless strict like-for-like offsets can be located and protected in perpetuity within the close vicinity of the bushland being cleared (note: under the government’s current draft Biodiversity Conservation Regulation 2017, the proposed Biodiversity Offsets Scheme will lead to widespread clearing of Sydney’s remnant bushland, including threatened species habitat, particularly in Western Sydney).
• Prevent the alienation of community and Crown land, as well as removal of the tree canopy, from Sydney’s green space network.

Sydney's green spaces are a vital component of its liveability and resilience as a city. Your positive action in protecting and enhancing our green spaces would strengthen your leadership in Australia’s much-loved and admired iconic first city, for current and future generations.

We, the sixteen signatories to this open letter look forward to an opportunity to discuss this important issue further with you.

STEP’s public fund, the Environment Protection Fund, is registered as a Deductible Gift Recipient (DGR) via the Register of Environmental Organisations administered by the Department of Environment and Heritage. This means that donations to the fund can be claimed as a tax deduction.

We have received the annual return form. This form used to be a simple exercise especially for a small organisations like STEP. However this time there are more questions. The government wants to know the breakup of the application of donations in categories of on-ground environmental remediation (no definition provided), research, education, advocacy, legal, overseas, administration and staff. Is this question anticipating a change in the eligibility requirements for DGR status of donations?

In 2016 the Senate Standing Committee on the Environment conducted an enquiry on this issue. The committee’s report concluded that the purpose of granting DGR status should be to support practical environmental work in the community but then took a very narrow interpretation of the meaning of ‘practical’ and recommended that:

annual expenditure on environmental work be no less than 25% of the organisation’s annual expenditure from its public fund.

Treasury has released a Discussion Paper on this issue and the general administration processes for charities. Currently there is overlap and some confusion between reporting and responsibilities under the Charities and Not-for-profits Commission and the Register of Environmental Organisations. Resolving these issues is welcome but they are also proposing that eligibility should be based on the amount of remediation work carried out.

Why single out the environment organisations for what is basically a financial penalty compared with other charities and lobby groups?

The Discussion Paper states that:

DGR tax arrangements are intended to encourage philanthropy and provide support for the not-for-profit (NFP) sector. Along with other tax concessions to the NFP sector, DGR status encourages the delivery of goods and services that are of public benefit.

It asks for ‘stakeholder views’ on the recommendations of the parliamentary committee, and also whether the government should go even further:

Views are sought on requiring environmental organisations to commit no less than 25% of their annual expenditure from their public fund to environmental remediation, and whether a higher limit, such as 50%, should be considered?

We ask the question, is the revenue forgone in providing tax deductions to environment groups a cost or a benefit? It is more cost effective to prevent damage to the environment in the first place rather than clean up the mess afterwards.

Activities like research, education and monitoring are vital for the prevention of damage. Take as an example the recent ABC program on Four Corners of illegal dumping of construction waste next to the Hunter River discovered by the Community Environment Network on the Central Coast. They were doing the job for the Environment Protection Authority. How much would the clean-up cost if dumping continued unabated? This monitoring would not count as remediation.

Donations and their tax deductibility are especially valuable for organisations like the Environmental Defenders Offices that provide a vital means for the general public to receive advice of their rights when threatened by developments.

Often it is the people living near the development site or mine who are aware of the potential damage not the government bodies. Take the coal seam gas exploration operations as an example, local farmers had no way of obtaining the scientific analysis to be able to object to miners entering their land. Ultimately when the full picture of potential groundwater pollution became clearer the NSW government had to take steps to limit the powers of miners to explore.

Business lobby groups like the NSW Minerals Council are actively supporting the limitation on deductibility status on the grounds that groups like Lock the Gate are simply activists ‘destroying the economy’.

If the proposal goes ahead it will demonstrate that the financial clout and expert lobbying teams of business interests are more important than the views and wellbeing of individual citizens who are concerned about the environment or are adversely affected by a development.

Submissions are now closed but STEP found out about the paper in time to make a submission. It is not too late to send a protest to your local member of federal parliament.

The NSW government thinks that raising the spillway wall of Warragamba Dam by 14 m will significantly reduce the risk of floods inundating homes in western Sydney. But experts have questioned whether the raising will achieve worthwhile benefits and whether the ecological damage can be acceptable. They argue the water levels in the dam storage should be better managed instead.

Brief History of Sydney’s Water Supply

The first water supply dams built to supply Sydney were the Upper Nepean dams (such as Avon and Cataract Dams) that still provide 20-40% of our supply. When this supply became inadequate the next step was the construction of Warragamba Dam that commenced in 1948 and was completed in 1960. The resulting storage in Lake Burragorang is one of the largest reservoirs for urban water supply in the world.

Following 1988 and 1989 high rainfall years, the NSW government re-evaluated the potential rainfall and flood risks and raised the dam wall by 5 m and constructed an auxiliary spillway on the east bank of the dam.

Back in February 2007 the Warragamba Dam water supply fell to its lowest recorded level of 32.5% after the prolonged drought from 1998. In response conservation measures and water usage restrictions were introduced. The desalination plant was built at Kurnell but this has hardly been used as we have had a period of above average rainfall ever since. Now the concern is flood risk. In 2012 and 2015 water had to be released to prevent a mass overflow. Currently the level is around 91%.

The benchmark for flood risk often used is the worst recorded flood that occurred in 1867 when the water height at Windsor Bridge was 19.2 m. This figure (from Sydney Morning Herald) provides data of past major floods and the flood extent in 1867.

According to the State Emergency Service, the estimated rainfall in 1867 in the lead up to the flood was 770 mm over three days averaged over the entire Nepean River catchment. The flood experience would be different now because several dams have been built in the Nepean catchment.

Government Proposals for Flood Mitigation

The high rainfall experienced in 2013 led to the need to release water causing minor flooding. The NSW government initiated another Hawkesbury Nepean Flood Management Review.

The review concluded that there is no simple solution or single infrastructure option that can address all of the flood risk in the Hawkesbury Nepean Valley floodplain. The risk will continue to increase with population growth. Evacuation is the only mitigation measure that can guarantee to reduce risk to life. According to the State Emergency Service a flood at the 1867 level would now lead to the evacuation of 90,000 people, damage to 12,000 homes and a cost of $5 billion.

As Prof Paul Boon explained during his STEP talk on 11 July on the Hawkesbury River, the topography of the river valley creates several challenges in understanding and managing flood risk.

The Hawkesbury has two main sources, the huge catchment of rivers that flow into Warragamba Dam that has its own flood plain from Emu Plains to Castlereagh. Then the Hawkesbury starts at Yarramundi when water sourced from the Grose Valley catchment in the Blue Mountains joins the Nepean. There is a flood plain around Richmond and Windsor through to Cattai but then more rivers join in and the valley narrows again with steep sandstone gorges and many twists and turns. This means that floods can bank up and spread out over broad areas of western Sydney.

Recommendations of the Review

Some points from the first review report are:

• Due to time constraints the review only assessed the flood mitigation potential of raising of the Warragamba Dam wall crest by 15 and 23 m. Pre-feasibility construction costs and reduction of flood levels have been calculated. However, economic, environmental and social costs and benefits have not been included at this stage. Detailed cost benefit analysis will be conducted for the options for the raising of Warragamba Dam in Stage 2 of the review.
• The review also assessed the potential for changing the operation of Warragamba Dam at its current configuration to provide for flood mitigation. Options examined different ways to create airspace to capture a portion of incoming floodwaters, by reducing the full supply level of the dam, ‘pre-releasing’ water if major flood inflow are expected based on forecast rainfall, or ‘surcharging’ the dam level during floods using the dam’s gates.
• The review concluded that only minor floods, below levels where significant damages occur, could be mitigated using the current dam unless its role as the main water supply to Sydney was compromised. It was also concluded that ‘pre-releasing’ of water from the dam prior to a flood was limited due to the inaccuracies in rainfall forecasts beyond three days, and the potential to increase or prolong downstream flooding.
• Reducing the full supply level of Warragamba Dam provides only a reduction in minor flooding and needs to be assessed against the impacts on Sydney’s water supply. The review considered lowering the full storage level by 2, 5 and 12 m, and concluded that the 2 m lowering had minimal flood mitigation benefits, and the
  12 m lowering would have significant impacts on Sydney’s water supply.
• Stage 2 of the review will further analyse surcharging the gates and reducing the full supply level for the mitigation of smaller floods, including the operational risks and the impact on Sydney’s water supply.

Even though Stage 2 of the review has not been completed, WaterNSW has been preparing environmental impact statements based on a proposal to raise the dam wall by 14 m and made a referral under the Federal Environment Protection and Biodiversity Conservation Act on specific matters of national environmental significance.

The intended operation after the spillway wall is raised is for water to be held back during a heavy rainfall event and then released slowly in the following weeks. This will provide additional time for evacuation and reduce the downstream flood peak. The stated intention is not to increase the current overall water storage level.

Environmental Impacts

The Colong Foundation for Wilderness has expressed serious concerns about the impact of the current proposals. The fundamental points made in their Colong Bulletin (July 2017) are:

• Raising the dam level does not deal with the flood waters coming from the major rivers further downstream such as the Grose, Macdonald and Colo.
• The extra water storage is intended to be temporary but the vegetation around Lake Burragorang and its tributaries that will, nevertheless, be flooded for several weeks will die leaving ugly scaring of the banks. The upstream flooding will impact the Kedumba and Colong River valleys that are part of the World Heritage listed wilderness areas. A further 1800 hectares could be flooded and another 33 km of rivers inundated.
• The backed up water in the Kedumba River will be visible from Echo Point, the iconic lookout in the Blue Mountains at Katoomba. The figure illustrates the projected increase in areas affected by inundation.
• Even flooding from a 1 in 50 year flood will extend 5 km into the Kedumba Valley and cause the death of 40% of the critically endangered Camden White Gum Forest. This species is listed as vulnerable under the Threatened Species Conservation Act. The Department of the Environment includes the forest in the Kedumba Valley as part of the Save Our Species biodiversity restoration program with an objective ‘to secure the species in the wild for 100 years and maintain its conservation status under the TSC Act’. Methinks WaterNSW should talk to the Department of the Environment.
• Aboriginal cultural heritage will be destroyed.
• Classic bushwalking areas will be lost, historic campsites drowned and access restricted. Bushwalkers are drawn to the pristine Kowmung River, a wild river that has inspired generations of walkers.

Can the Water Storage Level be Managed Instead?

Assoc Prof Stuart Khan, an expert in water engineering, disagrees with the need to raise the dam level. Management of the water level by controlled releases is a safer option so that the dam is never full. The desalination plant that can supply 15% of Sydney’s water needs, could be put to use when the need arises by way of earlier releases. Basically he disagrees with the review’s conclusions.

This is a fascinating risk management problem. Should we:

• reduce the water level if a period of heavy rainfall is projected and thereby reduce the water supply capacity with the backup of the desalination plant; or
• increase the dam wall at great expense and environmental damage that would threaten the tourism industry but still not eliminate the flood risk

Whatever option is taken flood risk cannot be eliminated. However the government is still going ahead with allowing massive population increase in the flood plains of the Hawkesbury Nepean system. As population grows the warning time needed to organise evacuation will increase.

Given the improvement in longer term weather forecasting. The government must explore options for smarter use of risk management techniques to adjust the storage levels. Raising the dam wall ignores this potential and could be a waste of $700 million.

Also future governments could easily be tempted to use the raised dam wall to increase water storage permanently to provide water supply for Sydney’s projected massive increase in population.

Other Serious Water Management Issues

As reported in the Sydney Morning Herald on 21 August, coal mining is impacting on the Sydney water supply catchments but the government is not carrying out adequate monitoring.

The 2016 Audit of the Sydney Drinking Water Catchment was tabled in parliament on the quiet. The National Parks Association discovered the report. It revealed that groundwater losses from longwall mining under the catchments in the Woronora areas has not been quantified. This is despite mining company reports have indicated that about 25 to 40 million litres a day have been entering the mines.

The 2013 audit report revealed that research was underway into the connectivity of surface and groundwater but no results have been revealed in the 2016 audit. This is not good enough given that these mining companies are still applying to expand their mining operations under the catchment.

There are also problems with coal mines leaking toxic chemicals into catchment rivers. Examples are the Springvale mine that has been pumping untreated waste into the Coxs River and the closed Berrima mine that has been leaking pollutants into the Wingecarribee River.

In the early days of settlement in NSW development decision-making took little heed of its impact on the environment, the loss of flora and fauna and associated ecological communities.

In the 1970s, as human impact on our natural environment became more pervasive, a greater understanding developed of what was being lost and appreciation grew of our unique flora and fauna. Changes in attitudes led to the passing of legislation such as the Threatened Species Act, planning laws that include assessment of environmental impacts and the creation of the National Parks and Wildlife Service (NPWS).

The NPWS was established in 1967, 50 years ago, when the Fauna Protection Panel that was constituted under the Fauna Protection Act 1948 amalgamated with the Parks and Reserves Branch of the Department of Lands. The purpose of the act was to provide for the protection and preservation of fauna, while permitting the destruction and control of those species which were harmful to primary producers. The act applied to all fauna whether native or introduced.

The national park estate has been steadily increased over the years so that now 872 reserves and parks are under NPWS management. However the declaration of new national park areas has been reduced to a trickle in recent years. The area of the state represented is now about 9% of the total land area.

NSW has fallen well behind in achieving its international commitments to biodiversity protection. As a signatory to the International Convention on Biological Diversity, NSW has voluntarily committed to protect, by 2020, at least 17% of terrestrial and inland water, and 10% of coastal and marine areas. There is a lot of catching up to do.

It is hard to see these international commitments being met when the current government attitude is to treat the NPWS as a poor relation. There has been a steady reduction in funding since the Liberal National government came into power in 2011.

Staff numbers have been cut through regular redundancy programs so that vital long-term experience has been lost in areas like remote area bushfire fighting and vegetation restoration.

Staff have been subject to repeated structuring, the latest being a reduction in the number of regional managers from 14 to 8. Regional managers will now have impossibly large areas to manage.

Funding has been diverted to eye catching new projects rather than repairing degraded facilities and heritage sites.

In a frank internal memo in June last year, then deputy chief executive Michael Wright acknowledged that NPWS staff were facing:

… ongoing budgetary pressures associated with increasing costs and salaries, and decreasing expense allocations across future years … We need to be proactive in identifying and implementing opportunities for savings to be made and revenue to be increased, to ensure we can continue to implement our core conservation, emergency response and visitor services for the people of NSW.

The savings are being imposed despite the NSW being in a bumper financial position following asset sales and booming stamp duty income. And yet the Office of Environment and Heritage website describes national parks as a ‘bedrock of nature tourism’.

No wonder the government is making the 50 years anniversary a low key event! The situation is an embarrassment to a state with such magnificent natural areas that are a major drawcard for local and international visitors. The newspapers have been full of complaints about the deteriorating visitor facilities. The money is being spent on high profile development such as the mountain bike tracks in Garigal National Park and sports stadiums.

The current executive of the Office of Environment and Heritage has refused a proposal to update a 2006, 40th anniversary document, made available through a freedom of information request, to mark the 50th anniversary. The document, NSW NPWS Commemorative History 1967–2007 was withheld, effectively suppressed, by the then Department of Environment and Climate Change executives when the authors refused to make requested changes. It has remained in draft form under copyright ever since.

The treatment of national parks is consistent with other Baird/Berejiklian government decisions to reduce land clearing restrictions and threatened species protection and facilitate development with reduced standards for biodiversity offsetting. It seems care for the environment is not consistent with the politicians’ mantra of growth at any cost.

Royal National Park Threat

The latest insult is the suggestion by the powerful Roads and Maritime that 60 hectares of the Royal be acquired for an extension to the F6 freeway from Loftus to Waterfall.

The Royal is Australia’s first national park that was reserved for protection. It was formally proclaimed on 26 April 1879.

To make matters worse there has been a push to have the Royal National Park inscribed on the World Heritage list. This process has widespread support from conservationists and the local communities. In July a technical obstacle to including the Royal on the World Heritage List was removed by UNESCO’s World Heritage Committee when they added a listing criterion of ‘an area of importance in world protected area history’ (Mosley 2012). If the land excision for the F6 goes ahead there would be little chance that the listing could be accepted.

Mosley, JG (2012) The First National Park: A Natural for World Heritage, Sutherland Shire Environment Centre

Over the past century, average land surface temperatures have risen by almost 1°C across the Australian continent. Models suggest this may have already had significant impacts on Australia’s ecosystems and biodiversity, but these impacts have not been systematically investigated.

CSIRO Land and Water and the Department of the Environment and Energy are undertaking an exciting project to collect observations and anecdotes that will help to build a national picture of the kinds of ecological changes that have been occurring across the country over the past 10 to 20 years or more, and where changes may not have been occurring. We are looking for people with strong links to Australian environments (e.g. farmers, natural resource managers, ecologists, naturalists, rural scientists) to share their perceptions of recent ecological change (or lack of it) in an area they know well, and how this might link with climate or other change.

To participate, you would need to be able to select a natural area (e.g. your local region or farm, a nature reserve, urban bushland) that you have been familiar with for at least the last 10 years. Note that we are interested both in areas where change has been observed and where change has not been observed.

The survey will take about 30 min. Click here for additional information about the project.

Please consider sending a submission opposing Mirvac's rezoning and development proposal for land adjoining Cumberland State Forest in West Pennant Hills to:

• Minister for the Environment, Gabrielle Upton This email address is being protected from spambots. You need JavaScript enabled to view it.
• Shadow Minister for Environment, Penny Sharpe This email address is being protected from spambots. You need JavaScript enabled to view it.
• Minister for Planning This email address is being protected from spambots. You need JavaScript enabled to view it.
• Hills Shire Council This email address is being protected from spambots. You need JavaScript enabled to view it.
• Member for Baulkham Hills This email address is being protected from spambots. You need JavaScript enabled to view it.

Background

The proposal is to rezone the majority of the 26 hectare site of heavily forested land to R4, high density residential. About 12 hectares on the southern side is of high ecological value containing critically endangered Blue Gum High Forest or endangered Sydney Turpentine Ironbark Forest. The rest of the site contains many mature trees believed to be over 30 years old.

The initial development plan is to allow for 400 apartments and 200 medium density houses in the northern part of the site with associated tree removal for bushfire protection. The proposed rezoning would allow eventual construction of apartment dwellings plus a recreational area on the entire site with no protective environmental zoning. This is a crucial example of the potential destruction under the NSW government’s new Biodiversity Offset laws.

The government is currently considering whether to give this rezoning proposal its in principle blessing under the Pre-Gateway review process and it is expected to be before the Hills Council before the end of the year.

Draft Submission Points

Thank you for the opportunity to make a submission on the proposed amendment to the Hills Local Environment Plan 2012 to facilitate medium to high density development at 55 Coonara Avenue, West Pennant Hills. This proposal is strongly opposed for the reasons outlined below.

1. The proposed rezoning to R4 (high density residential) would apply to over 23 hectares that contains critically endangered Blue Gum High Forest and endangered Sydney Turpentine Ironbark Forest but no protective environmental zoning has been proposed. Any high density development would also destroy Powerful Owl habitats. This owl species is listed as a vulnerable species in NSW. An ecological assessment of the site discovered nesting trees and roosting habitats on, and adjacent to the proposed 28 hectare development.
2. The initial development plan is to allow for 400 apartments and 200 medium density houses on the northern part of the site. Not only is the proposed development environmentally damaging – it also lacks appropriate infrastructure and amenities, with the nearest public transport link more than a kilometre away up a steep hill. Apart from losing treasured local bushland, neighbouring residents would also have to contend with additional traffic gridlock on local roads, especially Castle Hill Road, as a result of the increased local population.
3. The bulk of this land should be rezoned as E2 for environmental conservation with strong protections for mature trees on any part of the site rezoned residential. We want this beautiful rare forest to be protected, not bulldozed for high-density apartments.

A special resolution will be moved at our AGM to modify our constitution.

In accordance with the constitution, official notice is hereby given of the proposed resolution.

Click here for a copy of the proposed constitution and a brief summary of the main changes.

Summary of Main Changes

The Department of Fair Trading has prepared a model constitution and we have used this to update our constitution. The main changes are that we have:

• updated the objects
• defined family and life membership as up to 2 members living at the same address
• stated that 4 constitute a quorum
• provided for a number of management processes and procedures to be carried out electronically, i.e. application for membership, register of members, signing of minutes, use of technology at committee members, making decision, electronic ballots, calling of special general meetings, use of technology at general meetings

If you have any questions, please send them to This email address is being protected from spambots. You need JavaScript enabled to view it. or call Helen on 9144 2703.

Our economy and society ultimately depend on natural resources: land, water, material (such as metals) and energy. But some scientists have recognised that there are hard limits to the amount of these resources we can use. It is our consumption of these resources that is behind environmental problems such as extinction, pollution and climate change.

Even supposedly 'green' technologies such as renewable energy require materials, land and solar exposure, and cannot grow indefinitely on this (or any) planet.

Most economic policy around the world is driven by the goal of maximising economic growth (or increase in gross domestic product – GDP). Economic growth usually means using more resources. So if we can’t keep using more and more resources, what does this mean for growth?

Most conventional economists and policymakers now endorse the idea that growth can be 'decoupled' from environmental impacts – that the economy can grow, without using more resources and exacerbating environmental problems.

Even the then US president, Barack Obama, in a recent piece in Science argued that the US economy could continue growing without increasing carbon emissions thanks to the rollout of renewable energy.

But there are many problems with this idea. In a recent conference of the Australia-New Zealand Society for Ecological Economics (ANZSEE), we looked at why decoupling may be a delusion.

The Decoupling Delusion

Given that there are hard limits to the amount of resources we can use, genuine decoupling would be the only thing that could allow GDP to grow indefinitely.

Drawing on evidence from the 600-page Economic Report to the President, Obama referred to trends during the course of his presidency showing that the economy grew by more than 10% despite a 9.5% fall in carbon dioxide emissions from the energy sector. In his words:

…this 'decoupling' of energy sector emissions and economic growth should put to rest the argument that combating climate change requires accepting lower growth or a lower standard of living.

Others have pointed out similar trends, including the International Energy Agency which last year – albeit on the basis of just two years of data – argued that global carbon emissions have decoupled from economic growth.

But we would argue that what people are observing (and labelling) as decoupling is only partly due to genuine efficiency gains. The rest is a combination of three illusory effects: substitution, financialisation and cost-shifting.

Substituting the Problem

Here’s an example of substitution of energy resources. In the past, the world evidently decoupled GDP growth from buildup of horse manure in city streets, by substituting other forms of transport for horses. We’ve also decoupled our economy from whale oil, by substituting it with fossil fuels. And we can substitute fossil fuels with renewable energy.

These changes result in 'partial' decoupling – that is, decoupling from specific environmental impacts (manure, whales, carbon emissions). But substituting carbon-intensive energy with cleaner, or even carbon-neutral, energy does not free our economies of their dependence on finite resources.

Let’s get something straight: Obama’s efforts to support clean energy are commendable. We can – and must – envisage a future powered by 100% renewable energy, which may help break the link between economic activity and climate change. This is especially important now that President Donald Trump threatens to undo even some of these partial successes.

But if you think we have limitless solar energy to fuel limitless clean, green growth, think again. For GDP to keep growing we would need ever-increasing numbers of wind turbines, solar farms, geothermal wells, bioenergy plantations and so on – all requiring ever-increasing amounts of material and land.

Nor is efficiency (getting more economic activity out of each unit of energy and materials) the answer to endless growth. As some of us pointed out in a recent paper, efficiency gains could prolong economic growth and may even look like decoupling (for a while), but we will inevitably reach limits.

Moving Money

The economy can also appear to grow without using more resources, through growth in financial activities such as currency trading, credit default swaps and mortgage-backed securities. Such activities don’t consume much in the way of resources, but make up an increasing fraction of GDP.

So if GDP is growing, but this growth is increasingly driven by a ballooning finance sector, that would give the appearance of decoupling.

Meanwhile most people aren’t actually getting any more bang for their buck, as most of the wealth remains in the hands of the few. It’s ephemeral growth at best: ready to burst at the next crisis.

Shifting the Cost onto Poorer Nations

The third way to create the illusion of decoupling is to move resource-intensive modes of production away from the point of consumption. For instance, many goods consumed in Western nations are made in developing nations.

Consuming those goods boosts GDP in the consuming country, but the environmental impact takes place elsewhere (often in a developing economy where it may not even be measured).

In their 2012 paper, Thomas Wiedmann and co-authors comprehensively analysed domestic and imported materials for 186 countries. They showed that rich nations have appeared to decouple their GDP from domestic raw material consumption, but as soon as imported materials are included they observe 'no improvements in resource productivity at all'. None at all.

From Treating Symptoms to Finding a Cure

One reason why decoupling GDP and its growth from environmental degradation may be harder than conventionally thought is that this development model (growth of GDP) associates value with systematic exploitation of natural systems and also society. As an example, felling and selling old-growth forests increases GDP far more than protecting or replanting them.

Defensive consumption – that is, buying goods and services (such as bottled water, security fences, or private insurance) to protect oneself against environmental degradation and social conflict – is also a crucial contributor to GDP.

Rather than fighting and exploiting the environment, we need to recognise alternative measures of progress. In reality, there is no conflict between human progress and environmental sustainability; well-being is directly and positively connected with a healthy environment.

Many other factors that are not captured by GDP affect well-being. These include the distribution of wealth and income, the health of the global and regional ecosystems (including the climate), the quality of trust and social interactions at multiple scales, the value of parenting, household work and volunteer work. We therefore need to measure human progress by indicators other than just GDP and its growth rate.

The decoupling delusion simply props up GDP growth as an outdated measure of well-being. Instead, we need to recouple the goals of human progress and a healthy environment for a sustainable future.

James Ward, Lecturer in Water & Environmental Engineering, University of South Australia; Keri Chiveralls, Discipine Leader Permaculture Design and Sustainability, CQUniversity Australia; Lorenzo Fioramonti, Full Professor of Political Economy, University of Pretoria; Paul Sutton, Professor Department of Geography and the Environment, University of Denver, and Robert Costanza, Professor and Chair in Public Policy at Crawford School of Public Policy, Australian National University

This article was originally published on The Conversation. Read the original article.

Ku-ring-gai Council is anticipating that there will be a strong demand for biodiversity offsets once biodiversity legislation comes into operation in August. At the council meeting on 13 June a decision will be made whether to support the adoption of the Biodiversity Banking and Offsets Scheme (BioBanking) as an ongoing biodiversity management approach within council owned or managed land classified as Community Land under the Local Government Act 1993. Public consultation to assess the community’s acceptance of the ongoing creation of BioBanking sites will take place before the scheme is finalised.

So far there is one BioBanking site at Rofe Park, Sheldon Forest and Comenarra Creek Reserve and a decision has been made for another site yet to be determined in respect of land clearing by the North Connex project. Ongoing BioBanking within council-owned or managed land will strengthen the protection of biodiversity values and increase the funds available for management activities which improve biodiversity conservation.

As pointed out in the council meeting papers and in the article about offsetting on changes under the Biodiversity Conservation Act 2016, the impacts of development within Ku-ring-gai could be offset elsewhere in NSW. This could be circumvented if offset lands are made available.

Also the new system is weaker in its requirements for like-for-like offset requirements. Plant Community Types (PCTs) which don’t exist within Ku-ring-gai could in some circumstances be offset with different PCTs occurring within Ku-ring-gai, creating further offsetting opportunities.

The selection of potential BioBanking sites in Ku-ring-gai will seek:

• to maximise landscape connectivity;
• to protect sites of high ecological value and resilience, as directed by council’s 2015–17 bushland prioritisation matrix; and
• to align with regional conservation priorities, including the Office of Environment and Heritage’s Biodiversity Investment Opportunities Map – this map identifies areas for investment within the Cumberland subregion, which include either core areas or biodiversity corridors of state or regional significance.

If you are interested in obtaining further information look out for developments on council’s website.

The Australian and Queensland governments are still pushing for the Adani mine to go ahead and are bending over backwards to make this possible. The local native title holders are opposed but the Australian government is trying to legislate away the aboriginal rights.

We still haven’t heard if the Northern Australia Investment Facility will provide a concessional loan of $1 billion to finance the rail line from the Carmichael Basin to the port at Abbot Point on the Great Barrier Reef.

Queensland has offered financial inducements such as the deferral of royalty payments and no payment will be required for the mega litres of water that will be drained from the Great Artesian Basin. Local farmers are concerned about the effect on their water supplies.

Adani has announced a decision to go ahead in principle. But where will the finance come from when already 16 major banks have declined to participate? They can see that the project is not viable. When will reality hit the politicians?

There are many reasons why the mine will be a disaster:

• Adani has a dubious record that is hard to pin down due to complicated corporate structures and use of offshore tax havens.
• The chief benefit being promoted is jobs, jobs, jobs but realistic figures are for only about 1,500 full-time equivalent direct and indirect jobs as against the hype of 10,000 jobs.
• The Minister for Resources and Northern Australia, Matt Canavan, claims that the coal will bring the Indian peasants out of poverty. But solar energy has been shown to be more affordable.
• The mine is a total environmental folly. The opening of the Adani mine and construction of the railway line will open up the whole Galilee Basin that contains enough coal which, if burned, could blow away any hope of keeping global warming within 2°C and undermine any national and state action to tackle climate change.
• The mine threatens the Great Barrier Reef not only because of the increase in sea temperatures from climate change. The recent heavy rains led to coal washing into wetlands next to Abbot Point, the coal loader leased to Adani. Is this an example of worse to come?
• The mine would harm the economy of other coal mining states. The massive increase in production would reduce the coal price for coal mined in the Hunter Valley.
• The current rapid move to renewable energy is likely to reduce demand for coal to the extent that the coal market will collapse. The governments’ support could well be wasted.

Lord Howe Island is a magnificent island about 600 km off the coast of NSW. Its unique landform as an eroded volcanic peak and endemic biodiversity led to its classification as a World Heritage site. The southern end is dominated by the basalt peaks of Mt Gower (875 m) and Mt Lidgbird (777 m) covered in dense forests. The northern end is undulating and partially cleared for settlement. Lord Howe’s crescent shape embraces a sheltered lagoon and the southernmost coral reef on the planet.

The number of residents and visitors is limited by its small size and mountainous topography. Its economy depends on tourism and propagation and export of the kentia palm. The maximum number of tourists on the Island at any one time is constrained to 400 and the number of residents is about 350.

When I last visited the island in 2002 there was talk of a project to eradicate rodents. Rats and mice arrived in 1918 as escapees from a grounded ship. Rodents have contributed to the extinction of a number of species and are recognised as a threat to at least 13 bird species, 2 reptiles, 51 plant species, 12 vegetation communities and numerous threatened invertebrates.

The problem is that there is no native mammal species on the island that can compete with, or predate, on the rats and mice. Any impact on the natural values of the island diminishes tourism and recreation values since these are inextricably linked to the islands unique biodiversity and World Heritage values. (Attempts have been made to bring in other predators that are another example of the problems humans can cause when we interfere with nature – see the end of this article.)

Predation by rodents on kentia palm production reduces values associated with this commercial activity, via reduced production and added costs. In addition, rodents impose costs to residents and tourism operators via the need to bait to reduce visual presence of rodents, the spoiling of food stuffs and potentially health impacts to residents and tourists alike.

There has been a long process of investigation and consultation with concerned residents and I understand that the issues are still not resolved. The main problem is the acceptance of widespread use of poison baits. It is hoped that final approval will be granted later this year. The ABC Radio National Off Track program had two episodes on Lord Howe Island’s ecology during early June including discussion of the project and the damage being done by rats.

I recently discovered one of the reports on the project. The Economic Evaluation of the Lord Howe Island Rodent Eradication Project prepared by Gillespie Economics (November 2016). It is an interesting example of cost benefit analysis, the sort of analysis expected by government. As expected with an economic evaluation the report covers the financial aspects of the project. But it is also tries to quantify other community and environmental effects that cannot be directly related to money using some of the techniques of environmental economics.

Cost Benefit Analysis

Cost benefit analysis (CBA) provides a comparison of the additional costs and benefits with the rodent eradication project (REP), relative to without the REP. Provided the present value of additional benefits exceed the present value of additional costs, a project is considered to improve the wellbeing of society and hence is desirable from an economist’s point of view.

The net present value of a benefit or cost arising in the future takes into account the value of time through the process of discounting. The discount rate is a huge area of controversy. Business and government usually use commercial interest rates while society may consider a much lower rate is appropriate so that the interests of future generations are not discounted using the questionable theory that they will be better off than current generations.

A prime example is the issue of climate change – some argue that the costs borne in transitioning to renewable energy sources now do not justify the benefits of avoiding the loss of crops, bushfires, heat stress, sea level rise 50 or 100 years hence. If the benefits of avoiding costs in the long term are discounted at commonly used interest rates then the costs of transition today may exceed these benefits. Part of the problem is the broad assumptions needed to value loss of biodiversity and other environmental assets. The REP project analysis provides some examples of surrogate methods that are used. I will leave the reader to decide on the validity of the methods.

Scope of the REP

The Lord Howe Island Board currently implements a limited rodent control program at a cost of $85,000 per year. However, it is not reducing the rodent population sufficiently to limit landscape scale ecological impacts and there is a risk that continuation of the current approach will result in bait shyness and/or resistance in the rodent population.

The Lord Howe Island REP will use cereal baits laced with the anticoagulant Brodifacoum dispersed from helicopters in the uninhabited areas, and a combination of hand broadcasting, bait stations and bait trays in the settled area. Preparation is required to ensure some species are not killed by the baits. The iconic woodhens that were rescued from extinction and the local currarongs will have to be captured and caged for the period the baits are potent.

Without the REP, the current rodent control program would continue but this can only cover accessible areas of the island. The rodents have plenty of food sources all over the island. There would be continued presence of poison in the environment, continued impacts on the kentia palm and nursery industry, further degradation of World Heritage values (including endemic and threatened species) and the potential for Lord Howe Island to be inscribed on the List of World Heritage in Danger.

Cost Benefit Analysis Results

The analysis calculates that the present value of costs of the project and follow up management including measures to return species that are currently extinct from the island over 30 years is $9 million. By contrast the value of the benefits is $150 million. Hence this analysis shows that the economic value of the project is obvious.

Just looking at the cost of the project compared with ongoing costs of the current methods of control the net cost is about $8 million. Funding commitments have already been received from the NSW and Australian governments.

The removal of the effects of rodents on the kentia palm industry and vegetable production is valued at $1 million.

Some of the valuing of the benefits would be subject of much debate, for example:

• The improvement in biodiversity is deemed to increase visitor numbers. In warmer months when accommodation is already fully booked, increased demand is assumed to increase prices by 35%. In cooler months the accommodation demand is assumed to increase by 20% and prices by 7%. All this is assumed to have a present value over 30 years of $80 million.
• It is estimated that seven future extinctions will be avoided. The value of extinction prevention is based on several studies of community willingness to pay for the protection and recovery of threatened species. On an Australia-wide measure of community willingness to pay they are valued at $8 million each adjusted for a chance that the REP makes no difference to the chance of extinction to give a total of $40 million.
• There are also four species that are locally extinct, the Kermadec petrel, the white-bellied storm petrel, phasmid (stick insect) and wood-feeding cockroach. The return of these species is valued similarly with a deduction for the possibility of failure to reestablish the species at $27 million. One wonders if the general public would value the return of a species population by a transfer from another island in the same way as prevention of extinction of the only population of a species.

Even though some of these figures are debatable it is clear that the REP is worthwhile from an economic point of view. It is hoped that the local residents can be convinced of the benefits.

A Further Complication – the Masked Owl

Not long after rats became a problem the authorities thought it was a good idea to introduce various owl species to control the rats. There is still a large population of Tasmanian Marked Owls. After the REP is completed their major food source will have disappeared so it is likely they will turn to other species. We don’t want more extinctions so a removal program will be required of these Masked Owls.

There has been much media interest in the report that Sydney's population has reached 5 million. What has also been reported is that Melbourne’s population is growing faster than Sydney’s and may soon exceed it.

Sydney

The problem I have with this is that Sydney includes the Central Coast and the Blue Mountains, but not Wollongong. I don't advocate including Wollongong but leaving out the other two plus the Wollondilly Shire (Picton) we have 5.25 – 0.33 – 0.08 – 0.05 = 4.79 million. We could go further and leave out the farther reaches of Hornsby, Baulkham Hills and other local government areas.

Melbourne

Melbourne includes the Mornington Peninsular (0.16 million) which is debatable. Other areas should also be removed (allow 0.05 million). So, 4.67 – 0.16 – 0.05 = 4.46 million which is 93% of Sydney’s population.

Distortions

Part of the problem for the Australian Bureau of Statistics is that the outer suburban local government areas cover large areas of peripheral rural land. The Sydney map at a guess is at least 75% rural and this leads to massive distortions when people try to compare densities.

This data below (from Population Australia) is rubbish. Population Australia is a website specialising in research for Australia population growth trends and estimation. It is not clear who is behind this group but the data seems to be coming from the Australian Bureau of Statistics.

More on this some other time.

Jim Wells has been delving into published statistics that are more than meets to eye.

STEP is supporting a great initiative by organised by Forestmedia, a small not-for-profit organisation that is aiming to increase community awareness of the plight of our threatened species and help to develop the next generation of environmental leaders. The children’s art competition is supported by a number of organisations including the National Parks Association, the Nature Conservation Council, WIRES, Featherdale Wildlife Park, Humane Society International, Animals Australia and Taronga Zoo.

The competition is open from 5 June to 4 August to all primary aged children in NSW and the ACT. Fifty finalists’ works will hang in a two week exhibition in September at the Botanic Gardens and Surry Hills Community Centre, with winners announced on 7 September, Threatened Species Day.

There will be prizes in several categories. STEP is sponsoring a prize for a nocturnal animal artwork. Last year’s prize winners are shown on the website. They are very impressive.

In May the NSW government released regulations and codes that provide some of the detail on how the biodiversity legislation will operate in practice. But it is not complete so there is still a lot of uncertainty. The call for submissions is an opportunity to express a view on what should be in the areas that are missing as well as the available drafts.

There is a large volume of information to digest. The most useful one is the Submission Guide: Ecological Sustainable Development.

Consistent with STEP’s interests we focus on the aspects that relate to the management and preservation of urban bushland. Refer to our article on the issues regarding the Biodiversity Offsets Scheme.

The major areas that are missing are the Vegetation State Environment Planning Policy (Vegetation SEPP) and some of the maps that will underpin the decision-making process. This is most unsatisfactory! The legislation is due to come into force on 25 August. It is an abuse of due process to be conducting consultation on incomplete information.

The Vegetation SEPP will regulate clearing of vegetation in urban areas and environmental conservation/management zones where clearing does not otherwise require development consent under the main planning act, the Environmental Planning and Assessment Act. So the zones that are covered include E2, E3 and E4 zones.

The major concern is the inclusion of E2 zones in the clearing provisions. This zone is for areas with high ecological, scientific, cultural or aesthetic values outside national parks and nature reserves. The zone provides the highest level of protection, management and restoration for such lands whilst allowing uses compatible with those values.

E3 (environmental management) and E4 (environmental living) zones accommodate low-impact residential development but contain, or are near, bushland so have particular environmental or risk factors.

So why is the Vegetation SEPP regulating clearing on E-zone land, in particular E2 land? Clearing should not be allowed except for bushfire safety and other protection reasons.

Examples of land that could come under the new regulations are near the Blue Gum High Forest area in Dalrymple Hay Reserve and the area between Berowra Heights and Cowan near the Great North Walk. Most people assume the latter is national park but much of the natural scenery enjoyed by walkers is zoned E2, E3 and even RE1 (public recreation) and would have little protection under the proposed SEPP. Some E2 land is protected by being a BioBanking site or part of a conservation agreement, but not all.

Sensitive Biodiversity Values Land

There are certain areas, regardless of land area, that will require a biodiversity assessment (and offsetting if clearing is approved) if they are mapped in a Sensitive Biodiversity Values Lands map. The definition of areas included is very restricted.

Comment for submissions

The final map is not available and we understand many parts of NSW have not been properly assessed yet.

The resolution of the draft map on the website is too low to identify particular sites.

Areas that don’t meet the definition and should be included are endangered ecological communities (e.g. Sydney Turpentine Ironbark Forest and Duffys Forest EECs), buffer zones around EECs and areas of critical habitat, e.g. Ku-ring-gai Flying Fox Reserve.

Will it be possible to nominate areas for inclusion? Local land managers should be able to have a say on what is Sensitive Biodiversity Values Land.

There is a real danger that clearing of EECs such as STIF could rapidly turn it into critically endangered. A council’s discretionary DCP would be the only protection. It takes some time for a change in classification of vegetation communities to be finalised. In the meantime will they be cleared beyond hope of recovery?

Clearing Provisions

The clearing provisions are determined by categories of development.

Development consent required

Development consent is required (under the Environmental Planning and Assessment Act) for larger developments and infrastructure.

The Biodiversity Assessment Method (BAM) applies to clearing and the flawed offset provisions will apply.

Development consent NOT required

When development consent is NOT required, e.g. clearing of undeveloped land, the Biodiversity Offset Scheme (BOS) thresholds apply as prescribed below:

The thresholds are high.

For clearing above the threshold the BOS applies and approval will be determined by the Native Vegetation Panel. A biodiversity offset obligation will be imposed. Local councils could be given authority to do this assessment. We don’t know who will be appointed to the Native Vegetation Panel.

Clearing below the threshold will be regulated under the local council’s Development Control Plan (DCP) through a permit system. This will be the most likely situation in urban areas,

There is currently wide variation in the standards of DCPs, for example in relation to individual trees. Ku-ring-gai requires a permit for clearing of most native trees and vegetation and non-native trees while Hornsby only controls clearing of locally endemic native trees or trees in heritage zones. It is possible that the government will impose standard clauses in DCPs. Indeed would these be desirable if a high standard is applied?

Comment for submissions

It is essential that the objectives of clause 5.9 of the standard LEP are carried over to DCPs under the new scheme that is ‘to preserve the amenity of the area, including biodiversity values, through the preservation of trees and other vegetation’.

Submissions should explain desirable standards for the DCP regulations. One area that has not been covered is how the DCP clearing codes will fit in with the need for wildlife corridors and the Greater Sydney Commission’s guidelines for the Green Grid and minimum tree canopy cover.

Other Impacts of Clearing Regulations

A major issue with the local regulation of clearing is that there will be no monitoring of loss of vegetation communities and assessment of cumulative impacts. There needs to be a database of regional clearing approvals.

There is uncertainty about the legal status of DCP regulations and the ability to prosecute if breaches occur.

Areas of western Sydney that will be subject to the greatest amount of new development need as much protection as possible of native vegetation and habitat. The Cumberland Plain Woodland has already had large areas cleared. The allowable clearing and the use of offsets under the proposed regulations will further reduce the area of remaining native vegetation and habitat.

Conclusion

Given the limited areas of bushland in urban areas, it is inevitable that there will be more losses of irreplaceable biodiversity. The offsets provisions do not adequately factor in the scarcity of suitable offsets in urban areas (see article below). The rules must be amended to ensure maximum protection of native vegetation in urban and E zones, particularly areas containing threatened species.

Please Send a Submission

Closing date: Wednesday 21 June. Lodge online or post to Land Management and Biodiversity Conservation Reforms, Office of Environment and Heritage, PO Box A290, Sydney South, NSW 1232.

Over the past 200 years NSW has lost almost half of its bushland through land clearing and only 9% of what is left is in good condition. Clearing of native vegetation and habitat modification are the greatest threats to the survival of the majority of species on the threatened list.

The biodiversity laws that the government passed in late-2016 place a great deal of emphasis on offsetting as a means of allowing development to occur. The theory is that biodiversity lost when clearing for a development can be replaced by providing for restoration or protection of biodiversity in another place.

The Nature Conservation Council recently published a report on the operation of NSW’s biodiversity offset schemes, called Paradise Lost: The Weakening and Widening of NSW Biodiversity Offsetting Schemes, 2005–16. This article outlines the key findings of the report.

As you can tell from the title, the principles of offsetting have been severely compromised. We can expect worse to come under the new laws.

Concept of Biodiversity Offsetting

Biodiversity offsetting has been in use in NSW since 2005 under various pieces of legislation.

One example is the money that was paid by NSW Transport Infrastructure Development Corporation to compensate for the loss of 0.33 ha of Blue Gum High Forest when the railway station at Hornsby was expanded. The money was used to help purchase land to expand the area of protection of Blue Gum High Forest next to Dalrymple-Hay Nature Reserve.

We have written before about the theoretical difficulties of using offset schemes to compensate for lost vegetation and habitat loss and the measures that should be taken to counteract these difficulties.

The basic principles that should be observed are given below.

Offsets hierarchy

Offsets should only be used after appropriate avoidance and minimisation measures have been taken according to the mitigation hierarchy. A biodiversity offset is a commitment to compensate for significant residual adverse impacts.

No net loss

A biodiversity offset should be designed and implemented to achieve measurable conservation outcomes that can reasonably be expected to result in no net loss and preferably a net gain of biodiversity.

Some areas should be off limits – red flags

There are situations where residual impacts cannot be fully compensated for by a biodiversity offset because of the irreplaceability or vulnerability of the biodiversity affected.

Consider whether restoration is possible

Biodiversity offsetting assumes ecosystems and habitats can be re-created. This is often not the case, particularly if offset sites have been highly degraded and lost essential characteristics. In Australia, a number of studies have shown revegetated areas rarely resemble the ecosystem it was intended they would replicate.

Timing mismatch

It takes some time for species to establish a viable population in a new habitat. Offsetting should allow for a phased-in approach to prevent the total loss of species that are already threatened. The loss of hollow-bearing trees is a particular example.

Stakeholder participation

In areas affected by the project and by the biodiversity offset, the effective participation of stakeholders should be ensured in decision-making about biodiversity offsets. All stages including their evaluation, selection, design, implementation, monitoring and communication of results to the public should be undertaken in a transparent and timely manner.

Long-term management

The design and implementation of a biodiversity offset should be based on an adaptive management approach, incorporating monitoring and evaluation, with the objective of securing outcomes that last in perpetuity.

Case Studies

There are five types of offsets schemes operating in NSW. The performance of each of these schemes was examined through the lens of eight case studies:

• Namoi catchment property vegetation management plans – approval for land clearing under the Native Vegetation Act
• Kellyville in northwest Sydney – creation of credits under the BioBanking scheme
• Wagga Wagga local environment plan – biodiversity certification for strategic planning
• Albury local environment plan – biodiversity certification for strategic planning
• Huntlee development in Hunter Valley – Office of Environment and Heritage principles for biodiversity offsetting
• Boggabri and Maules Creek coal mines – development consent – Office of Environment and Heritage principles for biodiversity offsetting
• Warkworth mine extension – Office of Environment and Heritage principles for biodiversity offsetting
• Mt Owen mine expansion – NSW biodiversity offsets policy for major projects

The report provides a detailed description of the features of each case study and compares them with the expected standards. The criteria for the analysis were:

• be a last resort after avoidance and mitigation (including appropriate ‘red flags’)
• deliver biodiversity equivalence (like-for-like)
• provide security and achieve benefits in perpetuity
• deliver a net gain in biodiversity
• be additional to conservation measures already in place
• be enforceable, resourced and well-managed
• be subject to a rigorous monitoring and evaluation framework
• be open and transparent

 It was demonstrated that biodiversity offsetting is failing to deliver the environmental outcomes promised. No case studies resulted in outcomes deemed ‘good’ and the outcomes were:

• ‘disastrous’ in one study (Boggabri/Maules Creek)
• ‘poor’ in five studies (Warkworth, Mount Owen, Huntlee, Albury, Kellyville)
• ‘adequate’ in two studies (Namoi, Wagga Wagga)

For more details read the report.

Comparison of Offset Schemes

The report considers that a scheme should have the following features:

• excludes discounting of offset credits
• excludes supplementary measures
• excludes mine rehabilitation
• clear standard for environmental outcomes
• does not allow payment in lieu of offsets
• red flags
• impacts on water quality and soil are taken into account
• like-for-like offsetting

The case studies demonstrate the features of the five biodiversity offset schemes in operation. It was found that the later models contained fewer best-practice principles and standards than the earlier ones:

• only the first offsets scheme (the Environmental Outcomes Assessment Methodology under the Native Vegetation Act) contained all eight features
• the Biodiversity Offsets Policy for Major Projects introduced by the Baird government in 2014 contained only one of the eight features

Overall, biodiversity offsetting schemes have failed to deliver the promised outcomes and they have become weaker as standards have slipped.

Draft Biodiversity Offset Scheme is Even Worse

The latest Draft Biodiversity Offset Scheme (BOS) and the Biodiversity Assessment Methodology (BAM) that will be used to determine offsetting does not include any of the features described above.

The BAM is a metric-based tool that allows biodiversity impacts and improvements to be assessed and quantified in terms of ecosystem credits and species credits, collectively known as biodiversity credits that will need to be offset.

The proponent can choose to between three methods of meeting their offset obligation:

• buying credits for a suitable site under the offset rules from the market, or they can establish a Biodiversity Stewardship Agreement on their own land and retire the credits generated
• make a payment to the Biodiversity Conservation Trust that will source the offsets
• paying for conservation actions as approved by the consent authority

Key points for submissions

The key points on the features that should be in the offsetting legislation and the changes that are needed are listed below.

1. Discounting of biodiversity credits should not be permitted

The government proposes introducing ‘discounting’ that will allow offset credit requirements to be ‘discounted’ based on claimed social and economic benefits. Economic prioritisation policies are likely to contribute to the incremental and permanent loss of significant biodiversity in NSW, and undermine the credibility of the policy.

2. Supplementary measures should not be included

The BOS allows the use of ‘biodiversity conservation actions’ that may include research or surveys into the biodiversity under threat. This is not a genuine offset. The Scientific Committee stated in a report on this idea that this:

… is clearly a case of developers being able to buy themselves out of any obligation to protect biodiversity in any meaningful way.
NSW Scientific Committee (2014) Submission on the Draft NSW Biodiversity Offsets Policy for Major Projects

3. Allowance of mine rehabilitation

Numerous critics have questioned whether degraded mine sites can be effectively restored and in any case mine site rehabilitation should be an obligation of the mining company. Recently, developers have been permitted to use mine rehabilitation sites to generate biodiversity offset credits. The government proposes continuing this practice under the draft BOS.

4. Clear standards

The Biodiversity Conservation Act requires that the biodiversity assessment method should adopt a standard that result in no net loss but the draft BAM does not have a clear objective to protect biodiversity.

5. No payment in lieu

The draft BOS would allow proponents to discharge offset requirements simply by paying money into Biodiversity Conservation Trust. The development could proceed without certainty that the required offset is possible.

6. Red flags

The BOS does include some restrictions on proposals that cause ‘serious and irreversible impacts’ (SAII) but the criteria for defining SAII are too weak. It includes only the most endangered and restricted area species and ecological communities. In the case of major projects the SAII risks can be ignored. The net effect will be that EECs and endangered species not listed in the list of SAIIs, e.g. STIF and Duffys Forest, could be cleared without offset requirements if the land area is below the clearing thresholds. A council’s discretionary DCP would be the only protection.

7. Other impacts on water and soil

Other impacts should be considered in the BAM. The assessment methodology covers only a limited range of biodiversity values such as vegetation integrity and habitat suitability but not soil health and water quality and availability.

8. Like-for-like principle

The like-for-like principle that offsets should replace the values being lost is undermined in several aspects. For example:

• Offsets can be found from a radius of 100 km. It will be easier and cheaper to find offsets outside urban areas undermining preservation of biodiversity and threatened species and EECs such as STIF. The loss of existing geographic distribution if sites in urban areas are lost will undermine species resilience and long term adaptation to climate change.
• Offsets can be used for species across similar vegetation classes or between species. This even applies to threatened species; a koala can be swapped for a wallaby.

Conclusion

The government is proceeding with this model despite warnings expressed by leading scientists, lawyers and conservationists. The government basically has ignored the advice of the experts because it is wants to deliver development at any cost. Implementing the BOS will in fact add extinction pressures to the very species and ecological communities it is supposed to protect by facilitating the more rapid and widespread destruction of threatened species habitat across NSW.

Please Send a Submission

Closing date: Wednesday 21 June. Lodge online or post to Land Management and Biodiversity Conservation Reforms, Office of Environment and Heritage, PO Box A290, Sydney South, NSW 1232.

Hollows as Homes

The Australian Museum has joined the Royal Botanic Garden Sydney and Sydney University in launching a new citizen science project called Hollows as Homes. Funding support is provided by the Australian government.

The project builds on the Cockatoo Wingtags project and involves the same researchers, led by Dr John Martin.

In urban and agricultural areas large, hollow-bearing trees are in decline, but many species of animal rely on tree hollows for shelter and breeding.

In NSW, hollow-dependent species include at least 46 mammals, 81 birds, 31 reptiles and
16 frogs. Of these, 40 species are listed as threatened with extinction. This is why the ‘loss of hollow-bearing trees’ has been listed as a Key Threatening Process to biodiversity throughout Australia.

One reason that their loss is significant is the length of time that it takes for a tree hollow to form (often more than 100 years). More hollow-forming trees are needed to replace the losses that have occurred already. The solution being trialled is to create artificial hollows and nest boxes.

The Hollows as Homes project aims to conduct the first landscape scale assessment of tree/nest box/cut-in hollow distribution, type and wildlife use. Data generated will inform council plans for retaining important habitat trees, planting future habitat trees and supplementing missing habitat.

The project will harness the enthusiasm of local residents to report, measure and monitor tree hollows in their backyards, streets and parks.

Participating is easy – check the trees in your backyard, street, park, paddock or the bush, and report the hollow(s) online.

FeralScan

Feral animals cause over $720 million damage each year in Australia and threaten our native wildlife. FeralScan allows you to help reduce feral animal damage by mapping feral animal sightings, damage and control activities in your local area.

Ferals covered by the program include Indian Mynas, foxes, rabbits, feral cats and many more invasive species.

Following the serious power blackouts that occurred in South Australia and near misses in other states, gas-fired power stations have been touted as the one of the best means to transitioning away from our aging coal-fired electricity generation system. This is short-term, simplistic thinking that will be detrimental in the longer term, and the Climate Council has just released a report explaining why. The report is called Pollution and Price: The Cost of Investing in Gas.

The Climate Council is the crowd funded organisation led by Tim Flannery that replaced the Climate Commission that was abolished by the Abbott Government shortly after they came into power. They aim to provide independent, expert information on climate change issues.

Here is a brief summary of the main findings.

Use of gas does not reduce emissions sufficiently

Australia must reduce greenhouse gas emissions down to zero by 2050 in-line with international goals. Fossil fuels (coal, oil and gas) all produce greenhouse gas emissions driving climate change. Limiting global temperature rise requires that they are all phased out. Gas is not sufficiently less polluting than coal to garner any climate benefit.

Greenhouse gas emissions are produced both from gas power stations and gas production (for instance, methane from gas leaks). Methane is 86 times more potent as a greenhouse gas than carbon dioxide over a
20-year period.

New gas power plants are less polluting than coal. However, when the entire supply chain of gas production is considered, gas is not significantly less polluting than coal. Current levels of reliance on gas power in Australia must be reduced to play our role in limiting global temperature below 2°C. Expanding gas usage is inconsistent with tackling climate change as it locks in emissions for decades into the future.

Greater reliance on gas will drive higher power prices

Australia’s liquefied natural gas exports are pushing up the price of gas power as domestic gas prices are now inextricably linked to world market prices for oil. This will continue into the foreseeable future.

The most economic and accessible reserves are now being exported. Further gas expansion will drive increased reliance on unconventional gas, which is expensive. Reliance on gas power is also driving power price spikes, particularly in South Australia, Queensland and increasingly in New South Wales, due to lack of competition among gas power companies.

Investment in new gas plants is financially risky

The large increases in future gas prices and volatility resulting from liquefied natural gas exports together with domestic gas prices controlled by relatively few producers, make investments in new power plants using gas very risky. New gas power plants would rely on ageing gas production infrastructure (e.g. processing plants and high pressure pipelines) that is increasingly vulnerable to failure. Costs of updating this infrastructure and accounting for methane leakage must be factored into policy and investment decisions.

New gas infrastructure locks in carbon emissions for decades. Future regulations may impose higher costs or stricter limits on emissions in the future, impacting on the economic viability of gas production and electricity generation, stranding investments.

Significant development of new gas plants is unfeasible without a massive expansion of unconventional gas

The sheer volume of gas required, the cost, the lock in of long-term emissions, environmental risks and lack of support from communities near gas wells makes this unrealistic. Currently the emissions from unconventional gas in Australia are unknown due to a lack of measurement and data. This presents a long term carbon risk to investors as high emissions fossil fuel infrastructure faces the possibility of future regulation due to climate change. Development of new unconventional gas is entirely out of step with meeting the Australian government’s climate change goals.

Renewable energy can provide a secure, affordable alternative to new fossil fuels

New renewable energy is cost competitive with new gas. The cost of renewable power and storage, particularly solar, wind and batteries, continues to fall and has no associated fuel costs. This contrasts with rising and volatile gas prices.

Technologies such as solar thermal, hydro and biomass plants can meet demand for electricity at all times of the day as well as meeting technical requirements for grid stability. Combining these technologies with wind, solar PV, and large-scale energy storage, can meet electricity demand round-the-clock. Using existing gas-fired generators and supply infrastructure prudentially to complement wind and solar power while scaling up a range of renewable energy technologies, energy storage and energy efficiency measures could deliver a limited benefit, provided the end goal is phasing out the use of all fossil fuels as quickly as possible.

Conclusion

The report concludes that Australia should not provide policy support for new gas power plants or gas supply infrastructure. Existing gas plants should be thought of as a short-term, expensive, emergency backup as renewable energy and storage is rapidly scaled up.

Every day there’s an outdoor event to celebrate or commemorate something or other, and balloons will be released. It looks spectacular for a moment or two, but they’re soon forgotten. What happens to them? Most end up in our seas, where they are eaten by marine wildlife, including seabirds. It sounds frivolous, but it’s become a major conservation problem.

BirdLife Australia has thrown its support behind a campaign by Zoos Victoria and the Phillip Island Nature Parks to shine a spotlight on this issue.

Most people aren’t even aware that the simple act of releasing balloons into the air poses a major danger to wildlife. However, the facts are startling. A CSIRO study found that balloons are in the top three most harmful pollutants threatening marine wildlife – along with plastic bags and bottles.

Albatrosses, cormorants, penguins and pelicans are all affected by this, but of all Australia’s seabirds, shearwaters, or muttonbirds, are the most badly affected when it comes to ingesting plastic debris.

For example, the decline of Flesh-footed Shearwaters on Lord Howe Island has been directly linked to the ingestion of debris, with balloons and their plastic attachments, one of the most prevalent and readily identifiable items found inside them. Further, two separate studies have found that 100% of Short-tailed Shearwaters contain plastic in their digestive systems.

The balloons fill the birds’ digestive tracts while offering no nutrition, and slowly poison them as toxic chemicals leach into the birds’ tissues.

Birdlife Australia is joining Zoos Victoria and Phillip Island Nature Parks to encourage Australians to make their outdoor events wildlife-friendly. The best way to do this is by choosing to use bubbles instead of balloons to reduce this source of harmful waste.

Help spread the word to use bubbles instead of balloons at outdoor events. It’s a simple act but it can make such a big difference.

This information comes from Birdlife Australia.

Further reading:

• https://www.zoo.org.au/get-involved/act-for-wildlife/balloons
• https://www.zoo.org.au/get-involved/act-for-wildlife/balloons/about
• https://www.csiro.au/en/Research/OandA/Areas/Marine-resources-and-industries/Marine-debris

Ku-ring-gai Council has commissioned a report on developing the tourism potential of the municipality. Ku-ring-gai Destination Management Plan 2017 to 2020 is open for submissions until Friday 12 May.

The report focuses on a plan:

… to redevelop the St Ives precinct to achieve a ‘wow factor’ to attract visitors, benefit residents and help grow the local visitor economy.

The aspirations presented in the report are:

• to develop the precinct as a distinctive destination for nature-based and Aboriginal cultural tourism experiences
• to establish the precinct as a unique trekking hub and gateway for adjoining national park trails and Hawkesbury River to Sydney Harbour linkages to achieve similar iconic status as the Three Capes Track in Tasmania
• to develop events infrastructure and supporting facilities to position the precinct as centre for international-standard performances similar to those staged at the Hope Estate in the Hunter Valley for music, cinema and performing arts
• to rebrand the precinct to reflect its competitive advantage and world-class potential (e.g. Centennial Parklands and Western Sydney Parklands)
• to commission a revised master plan to balance existing recreational and community activities with a new tourism focus under a trust governance model used elsewhere
• to achieve the precinct’s full potential as a seven day a week, four seasons integrated mixed-use destination for international and domestic visitors

Accommodation Proposals

The possible developments described are more prosaic. Many of the suggestions are for the upgrading of existing facilities but STEP would be concerned by proposals for:

… unique accommodation experiences that complement these experiences (e.g. a five-star eco-tourism lodge sited near the boundary of the national parks escarpment, hostel accommodation for education and recreation groups and flash-camping).

Details are needed on how this sort of development can be achieved without damaging the environmentally sensitive E2-zoned land including endangered the Duffys Forest Ecological Community. The map at the top of the page also seems to show some national park land as being within the precinct. STEP will be looking at these plans very closely.

The report does acknowledge the environmental constraints:

It should be recognised that the recommended strategy, focused on nature based and Aboriginal cultural tourism, has environmental protection and enhancement at its core. There are numerous examples around the world of sensitively designed accommodation and infrastructure within and adjacent to national parks and areas of high ecological value. It is proposed that all new development in the St Ives precinct will be sensitively designed, constructed and operated in accordance with best practice and there should be a net improvement to environmental performance on site such as increased biodiversity, improved drainage runoff, Aboriginal cultural interpretation and signage. It should also be appreciated that many parts of the St Ives precinct are in a degraded environmental condition.

Walking Tracks

Proposals to upgrade walking tracks within the precinct and links to Ku-ring-gai Chase and Garigal National Parks are welcome. Many of the existing tracks are degraded and unattractive because of weed infestations. Funding has always been a problem, both for council and National Parks and Wildlife Service. This highlights the perennial problem, where will the money come from? It seems that public private partnerships and commercial leases are the only hope.

National Parks Development

The report (p19) states that the NSW government is about to release a new master plan for national parks covering partnerships with nature-based tourism stakeholders. A draft new Plan of Management for Ku-ring-gai Chase National Park is due to be released this year. It is going to be another busy year for preparing submissions.

Old Nursery Site

The plan for an indoor sports centre at the site of the nursery does not get a mention. Has that idea fizzled out? Instead there is mention of a native wildflower nursery funded by the private sector.

Road Links and Parking

The report highlights the need for traffic lights and a pedestrian crossing at the main entrance on Mona Vale Road. It also suggests that the exit at the Wildflower Garden be closed with internal roads being used to gain access via the main showground. There is a suggestion for overflow parking on the other side of Mona Vale Road. The effects of car parking on the Duffys Forest vegetation and soils has always been a problem and is currently controlled by the use of bollards and parking restrictions. If the number of visitors is to increase significantly the control of parking will be more important than ever.

Firstly, some history; in 2003 UTS decided to vacate the site and sought a rezoning for residential development with 560 buildings. Ku-ring-gai Council refused the application so the state government intervened and declared the site to be a Part 3A project under the EPAA Act. The Minister for Planning became the decision maker.

STEP was a member of a community consultative committee established to demonstrate that the community had been consulted. The committee opposed many aspects of the development plan. There were some wins in the transfer of 9 ha of the land to management by Lane Cove National Park and some improvements including a reduction in the number of dwellings approved for the site, the retention of a full-sized oval for community use and the retention of heritage buildings.

Of course there are no additional funds available to the NPWS to manage the additional national park land. A significant area of bushland has been modified to establish the asset protection zone and of course there will always be traffic and parking problems especially when the new school is operating. The management of stormwater and the risk of weed encroachment will need to be closely monitored.

Crimson Hill – Defence Housing Australia (DHA)

Crimson Hill estate was designed along simple, environmentally sound principles aimed to establish a new integrated community connected by bushland trails and elevated walkways. The objective was to promote community interaction and well-being. It has 345 dwellings occupying a portion of the 12.6 hectare site of rezoned land that DHA purchased from UTS in March 2011.

A significant area of this land, including publicly accessible bushland and nature trails for bushfire management, is in the care of the new residents via a Community Management Association.

It is DHA’s first multi-residential housing project and is being constructed in five phases. The name is a salute to the colour of the ribbon on the Victoria Cross medal. Each residential precinct is named after one of the five recipients of the VCs awarded for bravery on a single day during the battle of Lone Pine in 1915:

• Burton’s Place – Alexander Stewart Burton
• Dunstan Grove – William Dunstan
• Tubb’s View – Frederick Harold Tubb
• Hamilton’s Corner – John Hamilton
• Shout Ridge – Alfred Shout

The estimated 700 residents, expected to occupy Crimson Hill eventually, comprise a mix of Defence personnel and civilians. There are many owner-occupiers and tenants.

DHA is an Australian government enterprise established by the Defence Housing Act 1987 to supply housing and related services to Australian Defence Force members, in-line with operational requirements. Launched in 1988 as a statutory authority, DHA is now a commercially-funded organisation that has projects all over Australia. During 2015–16, DHA managed 18,767 properties for ADF members and civilians.

Before construction commenced in 2013, the brownfield site had significant areas of native remnant bushland around the university campus. A detailed ecological assessment was done before any clearing started.

Indigenous seeds were collected from endemic species and these were replanted. It is estimated that over 90% of plants on the site now are native and the majority are locally occurring species.

The centrepiece of the estate is Charles Bean Sports Field, opened in December 2013. It was developed by DHA with Ku-ring-gai Council and the Northern Suburbs Football Association. The purpose-built, publicly-accessible sports field has received FIFA 2-star certification, the highest accreditation an artificial grass field can receive. There are football teams coming and going continually and it is rare to see the field without players on the evergreen surface.

Rainwater is harvested within the buildings for re-use and some have solar panels to reduce main-grid energy usage. Environmental consultancy Cundall, estimates the buildings will use 60% less energy and water than standard multi-residential developments. The residential development was designed by two architectural companies: Bates Smart and Architectus. Construction was by two building companies: Grindley and Ganellen.

The recently finished Shout Ridge is the first apartment building in Australia to receive a prestigious 6-Star Green Star – Multi Unit Residential Design V1 certified rating for environmentally sustainable design from the Green Building Council.

New School on the Horizon

The latest good news for Lindfield residents is that planning is underway for a major refurbishment of the empty UTS building that remains from its previous use as a university. The building is earmarked to become a new K to 12 school.

The large concrete building was handed over to the NSW Education Department as part of a land swap with UTS. Eventually 2,000 primary and secondary students are anticipated to attend the new school. It hopes to have high quality technical spaces for science, engineering, hospitality, visual and performing arts, as well as music and film. And there will be a childcare facility.

The former UTS building has architecturally heritage because it won the prestigious Sulman Medal for architecture in 1978. This is the highest award given in Australian architecture.

New Walking Track

NPWS and DHA, with the assistance of Friends of Lane Cove National Park, are building a new track from Crimson Hill to Lane Cove National Park. Locals will be able to walk along this bushland track and stroll among wonderful angophora, wattle and eucalypt trees to get down easily to Lane Cove National Park all without any need to get into a car. At a construction cost of more than $220,000, the track will be one more amenity for the residents of Crimson Hill and other locals.

Note:  As it is, the track is not shown on our new map, Walking Tracks of the Lane Cove Valley. An example of how hard it is to keep up-to-date.

Lots More Development

As President of the Friends of Lane Cove National Park, Tony Butteriss points out in Regenavitis, wherever you look in Sydney now, there is more development and if feels as if it is getting closer to Lane Cove National Park. There are numerous projects coming right on the edge of the Park including the old UTS site, old Screen Australia site (adjacent) and redevelopment of the Acoustic Laboratory. However, the development that makes all the others look as if they are only playing, is the one at the Epping Road end of Delhi Road. Strictly speaking it is not one but at least three different developments planned to have a total of more than 2,200 units. This will have an impact of (at least) 5,000 people.

This particular development is a worry but consider the cumulative effect of all of them. Each development reduces habitat surrounding the Park. Each brings more hard surfaces and increases the speed of run-off after storms. And each brings visitor overcrowding to the Park. What can local groups do about this? The Friends hope to persuade the developers to fund some restoration projects.

The February edition of Regenavitis, the newsletter of the Friends of Lane Cove National Park, included the following update on the development of the former UTS (Ku-ring-gai) site in Lindfield that is now called Crimson Hill. We thank them for permission to reprint.

Click here for more information on the campaign.