Offsetting

Greater security for biodiversity and less emphasis on developer-friendly offsetting.

The current EPBC Plan appears to rely heavily on offsetting. In the Northern Geelong Growth Area, a ratio of less than 1:6 of protected habitat to cleared known habitat for Matters of National Environmental Significance is proposed. This fails to appropriately consider the avoid and minimise conditions for native vegetation removal. The vast amounts of offsetting needed may not be available, affordable or appropriate.

Grasslands are not like forests. Leave a forest alone and it gets better. Leave a grassland alone and it gets worse. Grasslands require regular biomass removal forever, not just for ten years. Weed issues will also likely require considerable ongoing inputs. These perpetual management requirements demand a system that allows for perpetual funding.

Keeping it local

Where offsetting must occur, offsets must be kept local (within 20 km)

PURCHASES

Upfront purchase and management of conservation areas

Offsets should be purchased within three years to create new or better biolinks or expand areas of high biodiversity. This may involve paying a premium above current land values. An alternative is to pay landowners to place a covenant on their land.

No detail has been provided of when conservation area land will be acquired. Land for conservation needs to be purchased upfront to minimise costs as land value increases, and to reduce substantial future management costs as well.

INTERIM PLAN

The immediate implementation of an interim management strategy

Biodiversity values are in decline across the GSA area, yet City of Greater Geelong is making little effort to ensure biodiversity values are being maintained. This failure to act in a strong, integrated manner, and to actively support current land holders with incentives, will lead to long-term loss of conservation values and greater management costs.

River health

Actions that allow for improved health of the Moorabool River and Cowies Creek, including minimum 200 m conservation buffers and no floodplain development

There is serious potential for significant impacts on the Moorabool River and Cowies Creek. We understand that the extent of the floodplain for the Moorabool River at the western edge of the Western Geelong Growth Area is yet to be determined and will not be determined until after the Biodiversity Conservation Strategy – one of the key documents of the Geelong Strategic Assessment – is finalised, in effect leaving no opportunity for appropriately informed public comment to protect a landscape that will be profoundly impacted by development.

Conservation buffers along waterways need to be a minimum 200 m. Choke points that compromise ecological function must be avoided. Flows from septic tanks must not compromise water quality. Additionally, treated wastewater should not be discharged into the Moorabool River due to the risk of bioaccumulation of emerging contaminants, such as pharmaceutical compounds.

Additional concerns include the potential failure to identity ephemeral water bodies, and the lack of acknowledge the impacts of quarry-related structures on fish populations in the Moorabool.

Cultural heritage

No PSP gazetted until all survey and other actions associated with an appropriate Cultural Heritage Management Plan are implemented

No mention has been made of cultural heritage. Have agreements been made with the Wadawurrung? Without a Cultural Heritage Management Plan, many conservation management measures cannot be undertaken, e.g. those causing soil disturbance, to the detriment of biodiversity. Cultural Heritage Plans must be completed before any PSP process gets to public engagement.

Strong Governance

Strong governance provisions for oversight, protection and compliance

We require assurances that good governance frameworks will be in place. How will monitoring be undertaken in a manner that ensures appropriate ecosystem values are being captured? What targets are going to be set? How will compliance be ensured? The CaLP Act is effectively toothless.

Will areas to be conserved be required to be restored to their previous quality? Who will be held to account for loss of biodiversity?

Restoration targets

Targets that encourage restoration, not simply business-as-usual management

We have heard nothing about restoration. Is there any intention to try to reverse the declining conservation values of this landscape, or is further loss of nature through offsetting the only conservation outcome?

Much of the land is being dismissed as ‘degraded’, ignoring the fact that, despite the high presence of exotic species, these are nevertheless grassy ecosystems with important biodiversity and ecological values. This emphasis on ‘degraded’ also ignores the fact that with time, patience and good management these communities can be moved towards more natural native grassland ecosystems.

FFG Act

Proper adherence to the FFG Act

Section 4B of Victoria’s Fauna and Flora Guarantee Act requires matters of biodiversity significance to be given their due weight by government authorities. The City of Greater Geelong appears to be abrogating its responsibilities in this matter.

BIOLINKS

Biolinks to strengthen biodiversity values within and beyond the growth areas

We are told determination of biolinks will occur during the PSP process. This runs counter to the intentions of a strategic assessment: to do planning for biodiversity early to avoid inevitable land use conflict later. Biolinks have to be put in place at the whole of landscape scale, that is one of the objectives of the Geelong Strategic Assessment.

Biolinks need to be wide to allow proper functionality, and wider still if they passive recreation, bike paths and so on. Biolinks need to link both inside and outside the Northern and Western Geelong Growth Areas.

Better data

Better baseline data to make this strategic assessment more truly strategic

Substantial areas have not been subject to fauna and flora surveys. These areas must be surveyed because it is likely they have good conservation values.

There is a significant chance that small but important areas of grassland have been overlooked across the Growth Areas. It is well known that big is not necessarily better when it comes to grassy ecosystems. It is important to consider that small patches can be protected, and that restoration works can work out from these remnant cores to create larger robust areas of good quality grassland.

Some significant species and communities have been overlooked in the survey process, e.g. Plains Wanderer, and Seasonal Herbaceous Wetlands. The determination of which species to survey for is based on the recorded presence of existing flora, but there are almost no survey records for flora in the surrounding areas – not because of lack of biodiversity values, but because it is farming land that has never been surveyed.

No methodology has been provided for how data has been aggregated. Surveys focus on Matters of National Environmental Significance, not state and local significance. For biolinks to be effective, they need to link to areas of conservation significance beyond the Northern and Western Geelong Growth Areas. However, no data is presented to suggest where such biodiversity values might lie.

RESPONSES

Detailed response to these concerns and more engagement from City of Greater Geelong prior to the proposed June 2023 release of the GSA documents for public consultation.

We have asked for but have yet to receive responses to many of the concerns group members raised with the EPBC team through this process. We require detailed responses to those concerns and the ones we have raised with them since. We require more engagement from the City of Greater Geelong prior to the proposed June 2023 release of the GSA documents for public consultation.