Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



EPBC Act Cost Recovery consultation
EPBC Reform Taskforce
GPO Box 787
Canberra ACT 2601



Dear Sir/Madam


Consultation paper on cost recovery under the EPBC Act


FOG is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and other on-ground work. FOG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.


FOG has provided many submissions to the Department under the EPBC Act, relating to development proposals affecting natural temperate grasslands and grassy woodlands in the ACT and surrounding areas of New South Wales. FOG is also aware of the increased use of offsetting when development proposals impact on endangered and vulnerable grassy ecosystems and species. With this background, we provide the following responses to some of the questions raised in the paper.


Questions—Cost recovery (general):


What are your views on the introduction of cost recovery to reform the EPBC Act, including the proposed benefits that cost recovery would fund?


In the past so little value has been placed on our native ecosystems that it is been a major factor in the current situation of many ecosystems and species becoming extinct or vulnerable to extinction. FOG’s view is that our native grassy ecosystems and dependent species in fact have a high values (both monetary and environmental). Placing a cost on the assessment of the impact of development proposals merely reflects that value. It also may have the effect of signalling that destruction of high value conservation areas actually has serious cost implications, so that developers may consider alternatives that do not impact on these areas.


Many of the offset proposals in our region involve rehabilitation of a native grassland or grassy woodland area, a process that can take some years. Consequently, FOG is fully behind the objectives and plans set out in the Consultation Paper’s section 3.5.3, in particular, “The management of post-approval requirements is one of the biggest resourcing issues facing the department, as the increasing number of project approvals over the life of the EPBC Act must be managed. Cost recovery also sends an important pricing signal to proponents regarding the need to make commitments regarding management objectives and environmental outcomes during the assessment process, and provide the opportunity for public input into this assessment process.”. FOG considers it essential that such cost recovery supports post-approval monitoring and audits over the longer term, in addition to covering the initial referral/assessment/approval process. FOG is enthusiastic about the opportunity for public input into such evaluation processes. In fact FOG would also be in favour of cost-recovery fees for post-approval activities being related to project complexity and scale – this is logically multiplied by time frame through being annually charged.


In what circumstances should fees be waived or reduced for activities being considered for cost recovery under the EPBC Act?


In relation to development proposals that impact on endangered and vulnerable grassy ecosystems and species, FOG does not think that fees should be waived or reduced. To do so would imply that the value of some high value conservation areas is less and their significance reduced, with a possible result being loss of these ecosystems and species in the longer term.


Questions for stakeholders—environmental impact assessments:


What are your views on the full cost recovery model proposed for environmental impact assessments?


One cost driver not mentioned under Post-approval monitoring is the total timeframe over which some monitoring would be needed. Offsets, particularly those requiring rehabilitation, will need to be monitored over long periods to ensure that they deliver the planned environmental outcome. While the annual fee proposed is not large, the cumulative fee for long term monitoring will be more significant.



Sincerely yours





John Fitz Gerald



28 October 2011