2024 – the year of Nature Positive in Australia?

Introduction

I can think of at least three national event that will be held this year focusing on Nature Positive, which follows the announcement by Hon Tanya Plibersek MP, Minister for the Environment, late 2022 of a Nature Positive Plan.

So, will 2024 be the year of Nature Positive in Australia? If, so, I’m in. Below is a summary of the presentation I gave last year at the EIANZ symposium on Nature Positive and EIA. It provides a broad background to the topic, discusses two broad definitions of Nature Positive and explores the role of offsets as a possible contributor.

Context and definitions

The United Nations declared 2021-2030 the UN Decade on Ecosystem Restoration, with the aim of halting the loss of ecosystems and protecting and restoring ecosystems all around the world. The UN noted that healthy ecosystems can enhance people’s livelihoods, help counteract climate change, and, importantly, stop the loss and collapse of biodiversity.

The Australian government announced a new environmental policy called Nature Positive. It defines it as

Nature positive is a term used to describe circumstances where nature – species and ecosystems – is being repaired and is regenerating rather than being in decline. (DCCEEW 2022, 2)

The title of the policy is “Nature Positive Plan: better for the environment, better for business”, which as noted by Ermgassen, Howard et al (2022) is popular with business and industry. The World Economic Forum has produced a report titled “The Future of Nature and Business” which, in part outlines:

… what transitions are needed to move towards a nature-positive economy and how businesses can be part of the solution paving the way for new opportunities. (World Economic Forum 2020, 8)

Ermgassen, Howard et al also note that

… if the approach remains vaguely defined and variably interpreted there is a high risk that it could be misleading, and used to ‘neutralise’ criticism of companies’ environmental practices … without driving genuine action to achieve global biodiversity goals. (P2).

To date, the Commonwealth has yet to clearly scope the extent of Nature Positive and how it will be applied to halt the decline in biodiversity in Australia, for example is it only about MNES or all of Nature?

Definitions of Nature positive are typically of two types – normative and holistic. A typical normative definition is:

… an equitable, nature-positive and net zero world [would] ensure there is more nature globally in 2030 than there was in 2020, by halting and reversing the loss of nature to put nature on a path to recovery for the benefit of all people and the planet by 2030. (IUCN Leaders Forum 2022, 3)

Nature positive involves two steps: first, halting the decline of the loss of nature and achieve a no net loss, and second, increasing the amount of nature over time. It requires two targets to be set: the year that net zero will be reached, and, once reached, targets for increasing nature e.g. an annual % increase.

As noted above, the UN sees a key link between human livelihood and ecosystem protection and restoration, which hints at a broader, holistic definition of nature positive.

A typical holistic definition of nature positive is from Obura, DeClerck et al (2023) which identifies two elements of Nature Positive: Nature-positive focus/biodiversity outcomes (interspecies justice) and People-positive focus/human outcomes (intra- and intergenerational justice).They conceptualise Nature Positive as having both a biophysical component and a human component, which recognises the connections between humans and nature, where humans derive a range of benefits from being in nature.

I would like to return to the value of defining Nature Positive in the holistic way in a later post, but this post will use the normative definition and examines how well biodiversity offsetting in WA has to date assisted in achieving Nature Positive outcomes.

Has the practice of Offsetting in WA contributed to Nature Positive outcomes?

Introduction and data used in this analysis

Environmental offsets are indirect compensatory measures used as mitigation for the unavoidable environmental impacts of development proposals. Pope et al (2021) identified three broad types of offsets:

• Habitat protection elsewhere – land that has the same biodiversity values is purchased and conserved using a secure regulatory mechanism, often called acquisition or averted loss;

• Improvement – where either cleared land is restored with native vegetation or degraded vegetation is improved and restored; and

• Other or indirect measures – including research, education and financial compensation.

• Offsets are often required to be like-for-like or in-kind, where the “gains from the biodiversity offset are for the same or very similar biodiversity components to those impacted.” (Bull, Hardy et al. 2015, 522)  In practice, this favours averted loss offsets over restoration offsets. Averted offsets are immediately seen as like for like and avoids the risk with restoration that is may not end up being like for like once the habitat becomes stable and reaches maturity.

Records of offsets set under Parts IV (EIA) and V (Clearing Permits) of the WA Environmental Protection Act 1986 (EP Act) are kept in the WA Offsets register, and these data was analysed to determine if they are contributing to Nature Positive outcomes.

The register shows 65 offsets set through Part IV and 201 set through Part V.

Categories of offsets

Table 1 summarises the types of offset categories for both Part IV and V, which are also shown as percentages in Figure 1. It should be noted that some offsets include more than one type so the totals will be more than the 65 or 201, and the total percent greater than 100%

Table 1: EP Act Part IV and V offsets by category – raw numbers and percentages

Figure 1: EP Act Part IV and V offsets by category – percentages

Clearly, Part V offsets are dominated by acquisition and Part IV by providing money to an offsets fund, 28 of which are in the Pilbara and require contributions to the Pilbara Environmental Offsets Fund (PEOF).

The ‘net’ vegetation outcomes

Table 2 shows the net position with respect to vegetation lost/gained as a result of implementing the proposals and the offsets fully – this is an important caveat as some proposals may not be fully implemented as assessed. The Table shows two ‘net’ position calculations, including offsets which are acquisition and excluding acquisition. The second calculation is the true net position, but both calculations are shown. The table also includes the ratio of offset to the area of native vegetation to be cleared.

Table 2: Net vegetation outcome if proposals and the offsets fully implemented – including and excluding acquisition

 In summary, if acquisition is included, Part IV offsets would lead to a 95% loss of vegetation cover, and Part V a 210% increase in vegetation cover, with a total of 89% loss overall. If acquisition is excluded, Part IV offsets would lead to a 99% loss of vegetation cover, and Part V a 69% loss in vegetation cover, with a total of 98% loss overall.

On these data, offsets are leading to a negative Nature Positive outcome.

But, what if the dollars in the offsets funds were used to restore land with native vegetation, would this lead to a positive Nature Positive outcome?

Using offsets funds for restoration

On the surface of it, it would seem that changing the focus of offsetting to restoration would lead to a better outcome for Nature, but there are concerns about the effectiveness of restoration. For example, Crouzeilles, Ferreira et al (2017)argue that natural restoration is 34-56% more effective than active restoration. Florentine, Gardner et al (2013) argue there is a lack of real data on the effectiveness of restoration noting that only 14% of 2,247 restoration projects in Victoria required monitoring. The key criticism is that restoration takes considerable time to reach full maturity - Xu, Dong et al(2022) note it takes 15-20 years for grassland restoration to be complete – although this can be ‘offset’ by using multipliers for restoration, which would also lead to a long-term net gain in vegetation cover.

Notwithstanding these concerns, restoration is likely to be a key policy measure in Nature Positive.

Kimball et al (2015) provide estimates for restoration costs as follows:

• Site works - $2,500 per ha;

• Seeding/establishment - $2,500 per ha; and

• Maintenance (e.g. weeding) - $1,200 per ha per year.

If we allow 25 years for restoration to reach maturity and requiring maintenance, the total cost is $40,000. Given that these are 2015 figures, the cost is likely to be $50,000 in 2024 figures.

Table 3 below shows the data for offsets fund, including for research, and the average fund contribution per ha of clearing.

Table 3: Offsets funds summary

These data clearly show that even if the research money went into restoration, the funds would not even cover site works of restoration.

So, how much restoration would this money actually buy and would it lead to a positive Nature Positive outcome.

These data are summarised in Table 4.

Table 4: Area of restoration that offsets funds could deliver

 The total area that could be restored from both funds is 2,682.7 ha or an improvement of only 1.7% if acquisition is excluded. If research money is also used for restoration (both funds total $34,911,450), this would add an extra 634.8 ha or a net improvement of 2.1% if acquisition is excluded.

Conclusions

I think the conclusions are fairly obvious.

First, if we consider offsetting acquisition to be a gain, then Part IV would lead to a net loss of 146,019.0 ha of vegetation, whereas as Part V would lead to a net gain of 6,759.8 ha of vegetation. However, this net gain argument of acquisition is hard to maintain – i.e. if not acquired, any proposal to clear any of this acquired land would need to go through an assessment process with no guarantee that approval would follow.

More accurately, therefore, Part IV would to a net loss of 151,765.5 ha of vegetation, and Part V a net loss of 2,230.0 ha of vegetation, a total of 153,995.5 ha lost.

If all of the offsets funds were used for restoration, this would add an additional 3,3175ha of vegetation, with the net outcome a loss of 150,678 ha of vegetation.

In short, offsetting in WA is delivering a net negative outcome for Nature.

Finally, it is very clear that the dollar value associated with native vegetation offsetting does represent the true value of clearing this vegetation, and is a hindrance to achieving a Nature Positive outcome. As noted in Table 3 the average value set for offsetting in Part IV is $838.94 per ha and for Part V $1,507.66. This is 1.5% and 2.7% respectively the cost of full restoration.

References

Bull, J. W., et al. (2015). "Categories of flexibility in biodiversity offsetting, and their implications for conservation." Biological Conservation 192: 522-532.

Crouzeilles, R., et al. (2017). "Ecological restoration success is higher for natural regeneration than for active restoration in tropical forests." Science advances 3(11): 1.

DCCEEW (2022). Nature Positive Plan: better for the environment, better for business. Canberra ACT Department of Climate Change Energy the Environment and Water, Australian Government.

Ermgassen, S. O. S. E. z., et al. (2022). "Are corporate biodiversity commitments consistent with delivering ‘nature-positive’ outcomes? A review of ‘nature-positive’ definitions, company progress and challenges." Journal of Cleaner Production 379: 1-12.

Florentine, S. K., et al. (2013). "Plant recruitment and survival as indicators of ecological restoration success in abandoned pasture land in Nurcoung, Victoria, Australia." Ecological Processes 2(1): 1-13.

IUCN Leaders Forum (2022). Towards an IUCN nature-positive approach: a working paper. Summary highlights. Jeju, Republic of Korea, International Union for the Conservation of Nature.

Kimball, S., et al. (2015). "Cost‐effective ecological restoration." Restoration Ecology 23(6): 800-810.

Obura, D. O., et al. (2023). "Achieving a nature- and people-positive future." One Earth 6(2): 105-117.

Pope, J., et al. (2021). "When is an Offset Not an Offset? A Framework of Necessary Conditions for Biodiversity Offsets." Environmental Management 67(2): 424-435.

World Economic Forum (2020). New Nature Economy Report II: The Future Of Nature And Business. In collaboration with AlphaBeta. Geneva.     

Xu, Y., et al. (2022). "Target species rather than plant community tell the success of ecological restoration for degraded alpine meadows." Ecological Indicators 135.

SAT decision on coastal setbacks a win for coastal planning and climate change

For those unfamiliar with coastal planning in WA, the WA Planning Commission’s (WAPC) State Planning Policy 2.6 - Coastal Planning (SPP 2.6) has guided coastal planning since its gazettal in 2013. A critical element of SPP 2.6 is a requirement to take into account the impacts of climate change at the coast, notably, because of predicted sea level rise and increased storm activity, increased coastal erosion of sandy coasts and more frequent and extensive inundation of low lying areas. Planners and developers are required to apply a 100 year timeframe – i.e. predict the likely impacts in 2120 and plan for this. 

SPP 2.6 requires that a CHRMAP process be applied to calculate the likely impact of erosion – i.e coastal hazard risk management and adaptation planning. This first part of this work (the CHR) is highly technical and usually leads to lines on a map which show the likely shoreline at a particular time in the future – typically 2030, 2070 and 2120. Critically, the width of public foreshore decreases, and, depending on the adaptation action chosen, the beach could disappear.

The second part of the process (MAP) is more subjective and involves making decisions about how to respond to the predictions, given that future erosion would likely impact on coastal infrastructure (paths, carparks etc.), roads and in some places, private houses.

SPP 2.6 sets up a decision making hierarchy as follows:

·      Avoid;

·      Planned and managed retreat;

·      Accommodate; and 

·      Defend/protect.

The avoid option is not possible for existing development, and the subsequent choice of the adaption option is highly contentious, but was not the subject of the SAT hearing I will discuss below, so I won’t ‘go there’ for the debate around existing development. I will tackle that in a later blog.

The case that was before the SAT last year involved setting the width of the coastal foreshore for some yet to be developed land in Two Rocks (Two Rocks Investment Pty Ltd and Western Australian Planning Commission [2019] WASAT 59).

The developer submitted site to the WAPC a structure plan for the development of 834ha land at Two Rocks which included a proposed foreshore for about 2.6km of coast. The extent of the coastal foreshore had been previously agreed to between the previous owner and the WAPC in 1997, but did not take into account climate change (as noted above, SPP 2.6 came in effect in 2013). 

The new owners were required to carry out a coastal hazard risk assessment to predict the likely shoreline for the 100 year planning timeframe. That work showed that landward movement of the shoreline would move between 145m and 171m depending on the location. The biggest movement would be in the central part of the site. This would mean that in 100 years’ time all of the foreshore as proposed by the developer would disappear, as well as an additional 9.9 ha of the non-reserve land. 

The WAPC rejected the structure plan and requested it be amended to take into account coastal erosion – i.e. a wider foreshore reserve was required. The developer appealed this decision to the SAT.

The developer proposed a different strategy to allow for the predicted erosion. The developer recognised that more land would ultimately have to be ceded to the crown as a reserve, but suggested that the land furthest from the current shoreline, but within the land subject likely to erosion in 50-70 years, could be developed in the interim. The developer proposed that this land be included in a 'Special Use (Coastal) zone' that would allow development and use in the interim – i.e. delaying vesting of the land to the Crown. The provisions of the Zone would require this extra land be reserved without compensation when it becomes vulnerable to coastal erosion.

This is not the preferred avoid option, but is the less preferred planned retreat.

The SAT found as follows. 

First, it dismissed the appeal and upheld the WAPC position requiring that the foreshore be extended to accommodate likely erosion by 2120. This is a significant decision which gives great weight to both the impact of climate change and SPP 2.6 in coastal planning and decision making.

The second finding is more nuanced but just as important, and involves on-going planning for coastal nodes.

A key principle of coastal planning in WA is that there will not be strip development of our coast (i.e. like the Goldcoast), but development will occur at pre-determined coastal nodes – e.g. Scarborough, Rockingham and Hillarys. These nodes have significant public, social and economic value, and it has been assumed that these nodes would be defended for as long as possible, beyond the time when erosion would begin to impact on these sites.

The Two Rocks sites had two proposed coastal nodes and the SAT found that these sites could be included as 'Special Use (Coastal) zones’ and developed in the interim, but that when the shoreline reaches within 40 m of each development, the land would then need to be ceded to the Crown (reserved). This was conditional on the Zone and relevant provisions are added to the local planning scheme within 10 years, i.e.  by 2029. This decision could well have implications for all the other coastal nodes in WA – it maybe that defend/protect will not be the medium to long-term planning options for these sites. 

Interesting decision!

Workshop Outcomes - National Biodiversity Offsets Conference

Description

In August this year the EIANZ organised a 2 day conference to explore the current state of offsetting in Australia, in particular, the conference allowed participants to

• Discuss their history and effectiveness in addressing environmental impacts;

• Share the experiences from all levels of government;

• Learn from academics, the legal fraternity and those involved in offset markets;

• Hear from individuals involved in the hands-on delivery of offsets;

• Explore different metrics for measuring impact and calculating offset delivery; and

• Debate the relative benefits of direct, indirect and ‘pay and go’ offsets.

A key part of the conference was a workshop at the end which was aimed at identifying priorities for biodiversity offsets into the future by addressing this question “Where do we want to be with offsetting?” 

Three broad outcomes resulted:

• Addressing the broad question by jurisdiction;

• Addressing the broad question at a higher strategic level; and

• Developing a consensus Conference Statement about the state of offsetting and how best to progress its practice in the future to ensure biodiversity outcomes are further enhanced.

I was the facilitator for this workshop, and the principal author of the report that described the workshop outcomes. You can download a full copy of the report by clicking on this link - full report

The session addressing offsets by jurisdiction were set the following 3 questions to guide participants to answer the overall workshop question:

1. What is being done well?

2. What areas need work?

3. What do we need to do to make offsetting better?

The full report provides the outcomes of these deliberations.

The following broad question was posed for the strategic part of the workshop: “What can we do to improve the practice of offsetting and the offsetting community?” As a guide, the following four topics were proposed to guide the discussions:

1. Knowledge gaps,

2. Expertise gaps

3. Key elements of best practice

4. High level barriers to better practice.

The 7 topics that emerged from this part of the workshop were:

1. Better education of, and communication with, key stakeholders to improve understanding of offsets and their benefits and reduce misunderstandings – landholders, finance institutions (offsets have value), other government agencies.

2. Provide sufficient and flexible funding and resources for follow-up – management, management plans, compliance, auditing, monitoring of the offsets including oversight and expertise and ability to be adaptive and are outcomes being achieved and are they what is wanted, develop evaluation cycle.

3. Develop a consistent overarching framework/guidance that can be applied, including standardisation where appropriate, consistent use of terminology – principles not methods.

4. Greater use of, and resources for, strategic offsets including for connectivity benefits, and at landscape scale, having metrics that deliver both local and strategic outcomes.

5. More professional forums and discussions including sharing of expertise across and between jurisdictions, and the development of good practice case studies, for example monitoring, adaptive management, strategic approaches. Development of a nation-wide community of practice.

6. Incentives for landowners – using market credits, better education about conservation outcomes, and establish under a regulation/legislation, greater financial certainty, financial support for surveys.

7. Improved transparency, accountability and consistency – methodology, risk, weightings, losses and gains, reporting, and regulation independent of government.

The final part of the workshop was dedicated to producing a conference statement. 

Statement from the 2019 EIANZ National Biodiversity Offsets Conference held in Canberra

Biodiversity offsetting has evolved considerably over time, and will continue to do so. Conference delegates strongly support the continual improvement of biodiversity offsetting policy and practice by addressing the following seven matters:

1. Proponents of all development proposals likely to have impacts on biodiversity should continue to demonstrate that every effort has been made to both avoid and minimise environmental impacts

2. Offsets exist to maintain or improve the conservation, protection and ecological health of the affected biodiversity.  Implementation models and mechanisms must never deprioritise or compromise this.

3. Offsets should apply to all sectors where residual environmental impacts on biodiversity occur 

4. Strategic biodiversity offsets are preferred over ad hoc offsetting as they are more likely to deliver better biodiversity outcomes;

5. All stakeholders, including financial institutions and landowners, need to be better informed about the costs, benefits and obligations of developing and maintaining biodiversity offsets throughout their lifecycle;

6. A nationally consistent and agreed set of principles that guide biodiversity offsetting, including those for monitoring and measuring effectiveness, is required; and

7. Public accessibility, transparency and accountability of offsetting processes must be lifted to a higher standard.

Picturing Coastal Stories - new book

Picturing Coastal Stories - new book - download here

The idea for this book came out of a special session held in the 2018 Coast to Coast Conference held in Hobart, Tasmania. The session was called “Picturing coastal issues” and built on the idea that a picture is worth a thousand words. Photographers were invited to submit one of their photos that told a coastal story. These were shown in a darkened room on a screen one photograph at a time. The session concluded with a general discussion about the power of photography to tell stories, and it was decided that the photographs and the intended storied be turned into a book: this is that book.

Click here to download a PDF version of the book.

Click here to download an “.PUB” version of the book.

If you want to print a hard copy, down load this PDF version of the book - click here.

Green Growth Plan for Perth

As most of you know, the State Government has released “Perth and Peel Green Growth Plan for 3.5 million” report – or GGPP – and a whole pile of supporting documents.  These documents are, in effect, the environmental impact statement for the assessments by both the Commonwealth Government and the WA EPA of the environmental implications of the WAPC's draft Perth and Peel@3.5million. The GGPP sets out the likely impacts of the proposed urban expansion for Perth-Peel, how thsoe  impacts are to be managed, and a proposed conservation and broader environmental plans that will compensate for these impacts. These collections of documents are make up the Strategic Conservation Plan.

For your information I have prepared an unofficial summary of the GGPP, which you can download and read by clicking here. Happy reading and happy to get any feedback if you think I have missed something important or made and errors.