Posted by Phil Burrell   21.12.07  12.41 pm:

There is also difficulty in DECC to update data through intensive groundtruthing, and this item is missing from some management reports I have seen. Like Warren's earlier message I am concerned that relevant conservation data is going to be missing or contain inaccuracies. This is NOT how we were taught to assess  sites!!

Excellent points Warren and Phil. DECC seem to be biting off more than they can chew. You may not be aware that under the Native Veg Act 2003/Native Veg (Regulations) Act 2005, all private forestry now requires a Private Forestry PVP, which again, is computer modelled based ie old growth, etc. There is scope for site inspection (tho most of it sounds like a drive thru). However, my points are:

• Its (biobanking tool, etc) based on models which haven't been open to review. The PVP tool for instance, when I saw it about 18 months ago, had the ecological profile of the Barred Cuckoo Shrike as "unknown". Scary, huh? It also failed you if you were removing any mature trees, as "mature trees" was listed as breeding habitat for the Square-Tailed Kite.
• DECC, which now includes DNR, currently has PVPs, PFPVPS and now the Biobanking tool to contend with. It sounds like a lot of work, and it puts a lot of pressure on the validity of these black box tools. Perhaps they are not expecting a mad rush into biobanking, but the everyone logging on private land has to have a PFPVP within 12 months from memory. Someone is going to be very busy!

Overall, it seems there are going to be some interesting times ahead. I haven't had time to read the review the pilot study - it may be illuminating.

Like Warren Brown, I am concerned by the resources of DECC and CMA's to assess this scheme in its entirety. CMA people whom I have spoken to across the state, are struggling to fulfil their roles now, without additional responsibilities placed upon them. DECC in the past has often ASSUMED "borrowing " human resources from CMA's and DNR's was a given, and drew up Catchment Management plans, based on this human resource "borrowing".

When the new Catchment areas were drawn up they were obviously seen to be a significant expansion of previous areas. This was viewed with considerable concern by CMA officers, some of whom I discussed these issues with were fellow participants of the scientific panel for the Biobanking dicussion groups.We never were able to find out from DECC how they proposed to deal with the resource issue in Biobanking assessments.

We were also concerned that consultants were not on the proposed list of participants in assessing sites and/or being accredited to determine whether a landholder had enough skills to do their own assessing of credits pertaining to a site

It worries me that the future of ecological assessment is a computer based tool that you punch numbers into! Clearly, what comes out will be a reflection of that data that is input and I think there are way too many holes in the literature for this to work, what about the unknowns! It seems as though the calculator will over-predict occurrence of species which I guess is better than under-predicting but this would potentially mean that developers could be purchasing credits for species which don't actually occur on their site. I assume that when someone is establishing a biobanking site they would need to undertake intensive field surveys to determine what is on the site?

How is DECC/CMA going to undertake biobanking assessments when they don't have enough resources to fulfill their current obligations? If there is demand for biobanking I think that consultants will end up doing the assessments because DECC/CMA won't have the resources and this a problem given that they have set an expectation for the cost!

I'm also still not convinced that it will be possible to fullfill the "like for like" requirements when purchasing credits, particularly given that development pressure is much higher in certain areas.

I managed to squeeze in a read of the docs from the meeting during a car trip. These are informative and clarify my notes above (which at time have captured snippets of info which arent in all proper context - hence read the docs to clarify). The docs are good, but not convincing ie they still leave me a sense of doubt, especially in regard to how the fee structure works (its different to the figures I quoted above that were given at the workshop - dont think they were telling the whole story).

I recommend reading "Proposed Threatened Species Conservation (Biodiversity Banking) Regulation 2007". This is the meaty bit which explains (at times a bit poorly) how it will work from what site is eligible for biobanking, to the fitness test for a person/entity, to the fees (which are a bit confusing as the text doesnt seem to clarify the table). The figures I quoted in the previous post dont seem to make as much sense now. See pages 24-25.

Interesting - it says the scheme is not intended to make work for consultants - most if not all the assessments will be done by DECC or CMA (as per the PVP and PNF PVPs), though acreditation is open if you want to fork out $1500 for  3 day course. I found the details on who does the site assessments and how are bit grey. And not cheap ($25 000 per site - in addition to the Scheme fees) - but are not likely to be done by consultants (p26). The scheme is also intended to run at a loss in terms of admin.

All in all, dont sit on the fence. Dpwnload all the docs and form your own opinion, as if this gets a jersey and goes ahead, it could have a significant impact on the nature of the industry. In principle, it sounds like a good thing, but as they say, the road to hell is paved with good intentions.

Greetings all,

The DECC is currently midway thru their public consultation phase of finalising the development of the biobanking scheme via calling for submissions and holding public meetings. I attended the latter (as well as the ECA conference) last nite partially out of curiousity to see if they'd be putting up the same slide show we saw at the conference, and be left with the same level of doubt and greyness.

To my surprise, the presentation was very different. DECC appear to have refined the scheme somewhat, and produced a range of new information and examples which I found quite informing. Some perintent notes I made are as follows:

• The Biobanking Credit Calculator (draft form) will be publically available on the DECC website.

• DECC may do the assessment themselves; have CMA staff do it (they are currently negotiating this option) - obviously the Calculator will be very similar if not a clone of the PVP tool; or allow accredited persons (note "persons" - they said anyone can take the training and become accredited, hence this could potentially be govt staff, consultants, or private landholders wishing to assess their land for potential as a biobank site).

• Accreditation will start before the scheme commences. The scheme is scheduled to commence in April 2008

• The site assessment will be censusing similar value as the PVP tool ie vegetative layer cover/condition, species richness, exotic spp components, hollow bearing tree abundance, landscape context (ie corridors, fragmentation).

• Credits will be divided into Ecosystem and Species Credits. Ecosystem credits are based on vegetation communities (and I think modelled species occurrence but dont quote me), and use predictive surrogates. Species credits are based on species not predictable by a vegetation community surrogate eg due to dependance on key habitat components such as rocky outcrops, hollow-bearing trees, caves, etc. - I think these species have to actually have been recorded on site.  A site can have both kinds of credits.

• Red flags: This is a concept borrowed from the PVP. The gist is that a site with a red flag cant be offset. Red Flag sites are detailed in "draft Biobanking Assessment Methodology...". To my surprise, EECs is low condition aren't Red Flags (tho I wonder if that will apply to BGHF). The Regulations (which should be posted in a week or 2) will contain an EEC condition test - this should be interesting, and expect it to be bastardised for the 7pt test assessments as a new benchmark (till it hits the L&E Court).

• DECC predicts the cost to a developer of getting a biobanking statement is $10 700. BUT this does not include the site assessment costs.

• The Application Fee and Site Assessment cost is (I think may be separate to the above but dont quote me) is $3600 (subsidised they said - but dont know by who or how) - this includes the site assessment (apparently based on $500/day - the cost of a CMA officer - and 5 days to do the assessment), and the cost of preparing a management plan. I found DECC's explanation of this cost confusing - 5 days sounds like a PVP assessment ie a laptop with a tick and flick check of vegetation associations, JANIS mapping of old growth components, AOW/Bionet records and anecdotal observations, a random meander - not any true qualitative survey; yet one of the DECC staff mentioned in question time to some landowners that surveys may be required at an additional cost. Hence we may have a role in this still! LOL

• a Management Plan will be issued with the Biobanking Statement which will detail the actions to be undertaken over time, with costings.

• A Fitness Test will be applied to potential biobankers to ensure they can viabily perform the actions required to maintain a site.

• A compliance assurrance strategy is also in draft form on public exhibition.

I also asked the question which I heard a lot of people voice at the conference. Is there an incentive for a landowner with a currently high quality site, to degrade it in order to gain extra credits to restore it? DECC stated that the scheme/regulations/methodolgy had been revised to ensure this would not happen (tho I dont feel convinced, yet I havent read all the new docs I acquired at the meeting) - rather there was now a disincentive ie earn less credits. Main reason I wasnt convinced what due to a graphic they flashed up which showed a site in low condition in an urban area was worth more than a site in high condition. Hence, the jury is still out for me on this till I read up.

In terms of others at the meeting (which included planners (no govt), bush regenerators, consultants, conservationists and developers), there was mixed feeling. Some private landowners werent happy with the costs - mainly in the aspect of what if they get credits and no-one wants them - hence the money is wasted. Response was as the calculator is publically available, you can do your own test to see what you have, and then see if there is a market for those credits. My impression was most of the developers didnt get it - in terms of what condition your site has to be in to offset it. Another graphic which moved a bit fast before I could fully analyse it was an estimated credit calculation. The credit was worth $350 000. I think some eyes widened when they saw that, and it reaffirmed my impression from the ECA conference - the credits may simply be too expensive to buy.

Regardless, I recommend attendance to these public meetings if they havent passed you by. I did email a schedule some time ago to members and you can see them on the DECC website under Public Consultation. Otherwise, download all the docs and get reading. Submissions close 1st Feb 2008, and then the curtains go up in April 2008.