Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

 

Dear Sir/Madam

Battery Energy Storage System, Blocks 1634 and 1635, Ginninderry, Belconnen, ACT

Referral no: 2021/8884

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.

FOG has concerns about the offset proposed for the box-gum woodland impacted this development – payment into the NSW Biodiversity Conservation Fund (BCF) – for a number of reasons:

• Payment into the BCF doesn’t guarantee that the offset will happen. With box-gum woodland listed nationally as critically endangered, there may not be credits offered for this ecosystem within the appropriate IBRA subregion. In this regard we note that the current Credit supply register does not contain yellow box- red gum grassy woodland sites for IBRA subregions SEH06 – Murrumbateman, Bondo – SEH15 or Monaro – SEH17 (or at all). As well, the current BCF Wanted credits list includes several grassland or grassy woodland species, reflecting the limited distribution of this critically endangered ecosystem.
• Timing: FOG’s view is that offsets should be delivered before the development impacts on the MNES. Payment into the BCF means that the offset will not be delivered until later, possibly a long time later.
• Location: offsets for ACT losses should ideally be delivered within the ACT or, at most, in adjoining areas of NSW. It isn’t clear why a NSW offset is being proposed rather than one in the ACT. We are aware that only a third of natural temperate grassland sites in the ACT are in reserves. While the situation may be somewhat better for box-gum woodland, it seems unlikely that there aren’t any suitable sites in the ACT available for this purpose.
• For a community group such as FOG to trust that offsets delivered under the EPBC Act are effective, there needs to be some public accountability – particularly in view of our ongoing concerns that the use of offsets leads to net loss in our grassy ecosystems over time. This concern is reflected by Recommendation 27 of the Samuel review (Independent Review of the EPBC Act – Final Report, October 2020, Professor Graeme Samuel), namely that “The Commonwealth should reform the application of environmental offsets under the EPBC Act to address decline and achieve restoration”. At the moment the ACT governments offset register gives us some idea of what is happening with local offsets and whether or not they are working. Offset payments to the NSW BCF will disappear from our view and leave us with the impression that they are merely a way for the developer to “buy off” their environmental obligations.

Yours sincerely

 

Geoff Robertson
President

8 March 2021