The Biodiversity Council welcomes the opportunity to provide feedback on the Draft plan for the Central Coast’s urban growth and environment.

The NSW Government is preparing the Central Coast Strategic Conservation Plan (the CCSCP) to provide long-term certainty for biodiversity and development in the Central Coast. The CCSP outlines: the approach to assessing biodiversity values within the CCSP area; the biodiversity values found during surveys and likely impacts; steps taken to avoid and minimise impacts; actions that should be taken to mitigate impacts during development, and associated essential infrastructure projects; approach to offsetting residual significant impacts on biodiversity values.

Our key concerns with the CCSCP and resulting recommendations include:

1. Inadequate surveying undermines avoidance of harm to biodiversity values

Recommendation 1: The Biodiversity Council recommends that land that is ‘unsurveyed’ is not classified as ‘certified-urban capable land’. If landholders did not permit surveys to be undertaken the land should be ‘non-certified land’ (i.e. not available for urban development). This would incentivise those landholders to permit access for surveys to ensure that there is a more complete assessment of biodiversity values to inform areas which are identified for urban development, and which should be avoided.

2. There is uncertainty about whether mitigation measures will be implemented

Recommendation 2: The Biodiversity Council recommends that the Mitigation Measures Guideline be subject to public consultation given the lack of clarity about mitigation measures in the Assessment Report and other supporting documents.

3. It is unclear if offsets will compensate for impacts on threatened species and ecosystems

Recommendation 3: The Biodiversity Council recommends that Strategic Assessment release a comprehensive offset strategy outlining:

• the details of confirmed credits or offset sites, including the biodiversity matters they will be offsetting, their location, management details and estimates of gain for each

• a commitment to measuring and tracking gain from offsets and comparing that to losses on a matter by matter basis, and reporting transparently

• the details of outstanding offset obligations and how they will be proposed to be met.

Please download the submission for the full analysis of our concerns and more details.