Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Mr Robert Neil

Acting Commissioner for Sustainability and the Environment
PO Box 356
Dickson ACT 2602



Dear Mr Neil,


Offsets in 2011 ACT State of Environment Report


Friends of Grasslands (FOG) is a community group dedicated to the conservation of indigenous 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 members include professional scientists, landowners, land managers and interested members of the public.


FOG welcomes your 2011 ACT State of Environment Report, in particular the recommendations for government to review and update Action Plans where appropriate, to report publicly on progress against Action Plan objectives and proposed actions; and also to better integrate biodiversity values within urban planning through integrating biodiversity corridors and habitat connectivity in the Territory Plan process.


The inclusion of two pages on offsets is a welcome addition to the report. This is the first time that we are aware of the details of the offset package for the Kings Highway deviation having been made public, for example. On the other hand, FOG has some concerns about some of the content here, and its lack of detail.


Our first concern relates to the lack of an offsets policy in the ACT. We are aware that there have been internal documents and reports prepared, but these are not available for the community to determine the types of activities that are identified as being offsets. We are therefore unable to consider whether agreed offset packages are likely to effectively counter development of areas of conservation value. For example, in relation to EPBC referral 2010/5439, in your report you list as an offset “Forde North developers are investing $100,000 on Golden Sun Moth research, including translocation studies; $10,000 in weed control for adjoining nature reserve; and construction of a dog-proof boundary fence between the suburb and the nature reserve and construction of a walking track into the reserve”. The actual EPBC document does not list these as offsets at all, but identifies these as actions “to avoid significant impacts on listed threatened species and communities”, which include a $100,000 research project on GSM translocation, and some fencing, weed control and other actions with regard to Mulligan’s Flat. Of these, FOG’s view is that the only one that could be called an offset is the GSM research project. The others are actually construction measures to mitigate the impact of the development on Mulligan’s Flat Nature Reserve, to ensure that there is no long term negative impact on the Nature Reserve. By reporting them as offsets, a rosier picture than actually exists is being painted, particularly as on the ground there is a net loss of endangered grassy ecosystems and species.


FOG’s second concern relates to the completeness of the offset table (Table 3. p260, Commonwealth-required offset packages for the ACT). This table lists four offset packages for developments that were approved late in 2010. Our understanding is that the SoE Report covers the period from 1 July 2007 to 30 June 2011. FOG is aware of other EPBC referrals with final approvals containing offset packages and occurring within this period that are not included in your table. They are, as follows:


EPBC referral no

Name of development

Development approval date


Ngunnawal 2C

31 Mar 2011


Murrumbidgee to Googong pipeline

3 Oct 2010


Transgrid substation, Williamsdale

20 Apr 2009


Canberra Airport master plan

11 Nov 2009


Sub-transmission line, Williamsdale to Theodore

7 Aug 2009


Taxiway extension, Canberra Airport

10 Dec 2008


Would you be able to advise FOG as to why these have been excluded from the table, as all relate to development approvals occurring within the ACT?


FOG’s policy is that the use of offsets should be a last resort, and that there should be no development that impacts on vulnerable or endangered species habitat or endangered communities. The use of offsets is relatively new in the ACT, and to date it appears that there is still net loss of populations of threatened species, their habitat and of areas of threatened communities. On-ground gains from offsets are not guaranteed and a number of the offset arrangements have not been in place long enough to reassure us that offsets are effective in preventing a net loss. For example, offset areas have been purchased for some of the above packages (e.g. at Williamsdale and for Canberra Airport), but rehabilitation of those areas is still occurring and the final outcome is not known. We are concerned that mechanisms are not in place to measure whether offset actions will result in net gain of conservation outcomes. FOG has significant concerns about the use of offset monies to fund research, due to the long timeframes and to uncertainties about whether or not research findings will be applied on the ground. For these reasons, FOG recommends that future SoE reports include in the offset section some information about actual outcomes from offset projects, e.g. research outcomes, land added to reserves or acquiring improved conservation status, results of rehabilitation programs.  This would be of great assistance in terms of reviewing the progress of the different offset packages and whether they are delivering what they are supposed to, or whether in fact net loss is registered in our endangered grassy ecosystems.


Sincerely yours





John Fitz Gerald



25 May 2012