Trading our native fauna – offsetting


Should we be trading our native fauna? Offsetting generally aims to compensate for the loss of biodiversity and in recent times there has been an apparent increase in the use of offsets by land developers and mining companies to enable their specific developments to proceed (Maron et al. 2012). As the use of offsets increases, there has been a growing market based mechanism for assigning a value to the residual impacts on biodiversity once other approaches have been exhausted, or so the policy(ies) say(s). But can we place an economic value on the loss of native fauna?

Imagine for a moment a hypothetical scenario where a government that is pro-development places a value on the fauna and fauna assemblage that is being lost. This government then has one department assigning a value to the loss of fauna and another government department that is the recipient of the offset funds. Would this government agency apply the same economic value to the offset as a conservation agency that is unlikely to benefit from the offset?

In WA, offsets only seem to apply to the loss of conservation significant fauna and not to fauna assemblages or non-threatened species, yet the EPA Position Statement No.3 (2002, p.12) states:

‘Best practice assessment now requires that biodiversity be considered to have two key aspects, namely:

a) its biodiversity value at the genetic and ecosystem levels; and

b) its ecological functional value at the ecosystem level.’

with the EPA’s emphasis being clearly on ecosystem values and function.

If this is the case, then why aren’t the government regulators requiring land developers and mining companies to offset the loss of non-threatened and non-conservation significant species?

Ives and Behessy (2015, p567) ask the question:

‘if it is acceptable to offset residual impacts of a development project, why make any attempt to first avoid or minimize unnecessary impacts if these too can be offset without reducing net ecological outcomes?’

and then follow it up with:

‘can the protection of organisms in one place compensate for the wilful destruction of others at another location?’

If offsetting is so effective, then why should it be used as a ‘last resort’?

Traditionally, government policy did not support the trading of high-quality habitat for a development, but that also appears to be changing (e.g. Roe 8 highway extension). Is our community headed for an environment where all the government regulators and EPA do is determine the size and extent of the offset for a project, prior to the Minister’s pre-accepted approval being provided? (I hope not!!)

All offsets should be outcome oriented and there should be ‘no net loss’ or better still a ‘net gain’. However, in WA we are unlikely to know if there is ‘no net loss’ or a ‘net gain’, as the WA government’s offsets register fails to provide:

  • a statement of the fauna or fauna habitat being impacted;
  • a clear statement of the objectives for each offset;
  • measurable outcomes for each offset or clear criteria for measuring the offsets success; and
  • an indication of the monitoring that will be undertaken of offset outcomes.

This lack of transparency in implementation, poor reporting and lack of public accountability does not instill confidence in the community that we are getting the necessary ‘value’ from the offsets.

Maron et al. (2012) criticised biodiversity offset programs because of poor definition and measurability of the values to be offset, uncertainty in restoration outcomes where restoration of an area was the offsetting response and unavoidable time lags before outcomes are achieved. All of which appear very relevant in the WA situation.

For black-cockatoos, we often transfer native vegetation in private ownership to the state owned conservation estate, but where is the ‘net gain’, when this vegetation was already available for black-cockatoo foraging? In many circumstances there is no obvious net gain, rather a significant loss in foraging habitat. In this context it will be interesting to see how the WA government will ensure ‘no net loss’ of black-cockatoo foraging habitat in the Strategic Environmental Review for the Perth-Peel Region, particularly as it has already cleared much of the Gnangara Pine Plantation, a major foraging habitat for Carnaby’s Black-Cockatoo, without providing a ‘no-net loss’ offset.

Are we devaluing our native fauna, in particular our threatened and conservation significant fauna, in allowing it to be so readily traded, often for projects or activities where there are no clearly defined outcome statements and no monitoring of these outcomes?

Black-winged Stilt Pilbara 3


Environmental Protection Authority. 2002. Terrestrial Biological Surveys as an Element of Biodiversity Protection Position Statement No. 3. Perth.

Ives, C. D., and S. A. Bekessy. 2015. The ethics of offsetting nature. Frontiers in Ecology and the Environment 13:568-573.

Maron, M., R. J. Hobbs, A. Moilanen, J. W. Matthews, K. Christie, T. A. Gardner, D. A. Keith, D. B. Lindenmayer, and C. A. McAlpine. 2012. Faustian bargains? Restoration realities in the context of biodiversity offset policies. Biological Conservation 155:141-148.

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5 Responses to “Trading our native fauna – offsetting”

  1. Bernadette Van der Wiele on January 20th, 2016 10:19 am

    The problem with ‘self-regulation’ (e.g. proponent commitments to undertaken monitoring etc given in Mgt Plans) is that it relies on the proponent to self-manage over relatively short time-frames (e.g. 2-3 years). These time-frames are far to short to accurately assess whether the objectives of the Plan are met or going to be met. The regulators undertake very few audits themselves so rely on proponent’s audits being accurate.

  2. Scott Thompson on January 20th, 2016 10:31 am

    Thanks Bernadette. Do you think it is therefore reasonable that additional proponent commitments are made to do longer term monitoring or provide funding for an external agency to complete monitoring 5 or 10yrs later? Unless we know that the offsets we are implementing are actually benefiting the environment (and specifically the resource/species we have directly impacted and therefore offset) we are just wasting our time.

  3. Geoff Bott on January 20th, 2016 1:58 pm

    As author of the EPA’s ‘Position Statement No 4 – Wetlands Protection in Western Australia’ in 2001 and ‘A Policy for the Establishment of Wetland Banking Instruments in Western Australia’, also in 2001 and co-author of the ‘Wetland Conservation Policy for Western Australia’ (Government of WA, 1997), I find the current fervor around offsets and the ‘currency’ of offsets quite frustrating.

    In relation to wetlands….the EPA has a stated and published goal of attaining a ‘no net loss’ of wetland habitat. It is of some concern then that a project such as Gateway could result in the loss of ~15ha of CCW habitat and be merely required to ‘offset’ this loss by purchasing privately held land containing wetlands and vesting this in the Crown for conservation. This is not ‘no net loss’. The CCW habitat was not ‘replaced’ in either area of habitat or functional value. There is in fact a clear and demonstrable ‘net loss’.

    If indeed ‘no net loss’ is the desired outcome (as stated), then this would necessitate wetland restoration or creation – not merely purchasing existing wetland habitat.

    Wetland banking was identified as the most viable option to achieve this. Hence the companion publication outlined above.

    Notably, promulgation of the Clearing of Native vegetation Regulations in 2004 effectively removed a multitude of activities (clearing, filling, grazing, draining, etc) which were otherwise considered ‘threatening’ to the conservation of wetlands. Up until this point, the acquisition of ‘threatened’ privately held wetland habitat made some sense – but not since the clearing regulations came into force.

    The use of Wetland Banking relies on externalizing the restoration and creation of wetland habitat from the developer/proponent and costing this at the ‘true cost’. This is achieved by establishing a ‘bank’ of previously restored or constructed’ habitat (projects) from which the developer can purchase ‘habitat units’ (area x function) at the actual cost of creation. Independent auditing of the effectiveness and credits created is incorporated into the actual costs and hence is included in the sale price of the habitat units.

  4. Cate Tauss on February 24th, 2016 10:20 am

    The current “Green Growth Plan” is using this same “Roe 8” method of offsetting unacceptable residual impacts on Threatened Species by proposing to buy or reserve extra land elsewhere. In fact their WHOLE CONSERVATION PLAN looks like nothing more than an offset. Is it not legally invalid to say that Green Growth (which is destroying 52% of Carnaby’s roosting sites, and most probably 50% of the current foraging habitat by removing pines and developing Banksia woodlands) can make up for this loss by promising in its Conservation Plan to buy bushland elsewhere on the SCP? This is no nett loss and it breaches the criteria for recovery in the CC Recovery Plan.

  5. Scott Thompson on February 24th, 2016 10:48 am

    Thanks Cate. I have had a preliminary read through the assessment documents and it doesn’t look good for the environment or threatened species. I would encourage everyone to have a good read through the Perth Green Growth assessment documents that are currently out for comment ( and then send the comments and feedback through to the Government. If we don’t make a comment, we can’t be critical of the outcomes in the future.

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