Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Policy Reform Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601


Dear Sir/Madam

Draft policy statement: advanced environmental offsets under the EPBC Act

Friends of Grasslands (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 members include professional scientists, landowners, land managers and interested members of the public.

In a political and economic environment where offsets are necessary, FOG considers advanced offsets an important component of preserving our natural heritage. We are aware of situations where small Natural Temperate Grassland areas have been allowed to deteriorate for a variety of reasons, with the final result being that some sites no longer meet criteria for protection under the Act, and are allowed to be developed. Advanced offsets offer the possibility of maintaining and improving the quality of such sites, with long term protection a possible outcome.

In particular, FOG would not want to see any changes to the advanced offset policy statement that weakened its provisions. We consider the potential, improved environmental benefits important and the list of required information for an advanced offset proposal essential.

The requirement for additionality, i.e. the conservation benefit delivered by the advanced offset must be in addition to the usual ongoing care of the proposed site, is critical, as there is a danger that usual care of the site might be replaced by the offset activities. Also, any assessment of proposals should guard against current or past activities by, for example, Landcare groups, being inappropriately counted as part of the offset improvements. It is suggested that the reference to ‘business-as-usual’ in the additionality statement on page 6 be picked up in the list of key information on page 5. Proponents would then be required to demonstrate that their proposal was in addition to ‘business-as-usual’ management and care of the site.

Yours sincerely



Sarah Sharp

24 September 2015