12 October 2006

The Hon Morris Iemma, MP
Premier,
Level 40 Governor Macquarie Tower,
1 Farrer Place,
Sydney NSW 2000

Dear Premier,

OPPOSITION TO THE THREATENED SPECIES CONSERVATION
(BIODIVERSITY BANKING) BILL 2006

The Coastwatchers Association wishes to register, with you personally, our opposition to the Threatened Species Conservation (Biodiversity Banking) Bill 2006 which had its second reading in parliament recently. Coastwatchers view is that the biobanking scheme will result in a net loss of threatened species habitat and undermine public participation, in order to fast-track the development approval process.

With the present alarming rate of extinction, biodiversity must be improved, not merely maintained. Allowing destruction of land containing a threatened species in one area because steps have been taken to ensure the safety of the species elsewhere does not constitute a conservation gain. Enabling developers to use offsets encourages the use of sites that would have previously been left undeveloped because reconfiguration and additional on-site work would not meet requirements for approval.

A clear threshold has not been set for the protection of diversity. The Bill does not include provision to designate any habitat areas that should be considered to be irreplaceable. In fact, the recent amendments contradict the assertion that there will be permanent protection for offset sites since these offset sites can later be "offset" themselves for mining or approved for development by a public authority.

The Bill will result in an instant loss of biodiversity to be traded for a slow gain in habitat quality on offset sites. Biodiversity credits can be sold before management actions have been completed or biodiversity outcomes delivered. The scheme could also push efforts towards conservation of cheap land with different ecological values to that in areas of development.

The Coastwatchers Association is a community organisation that has served the Eurobodalla Shire for over 20 years. Eurobodalla is a rural coastal region four hours drive south of Sydney. The Association acts as the environmental watchdog for the area, working closely with the wider community to help protect the health and beauty of our region. The biobanking scheme will have a big impact on opportunities for Coastwatchers to have a voice in the decisions that are made in response to pressure from development and population growth in our local area. Since 2005 the extensive use of the Environment Planning and Assessment Act has downgraded community consultation and participation for all major developments to pre 1979 levels. There is no active role for Coastwatchers in the biobanking scheme either. Our role will be reduced to that of mere spectators, able only to peruse the registers of biobank sites, biobanking statements and biodiversity credits which are planned to be made available to the public on the appropriate government department web site.

It is vital that public participation prior to the issue of biobanking statements be preserved. Local environment groups are the very organisations that are likely to have detailed knowledge of the vegetation that is under threat from development. They are also aware of its importance to the community for social, educational and recreational use as well as scenic value.

In conclusion Coastwatchers considers the proposed scheme should be used only for the expansion of existing public infrastructure or other projects of community significance. A biodiversity levy should be applied to all green-field development to fund conservation on public and private land.

Yours sincerely,