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Environmental offsets: when hope and promise fade

29 Aug, 2024
Andrew Mack, Talis Consultants
Environmental offsets: when hope and promise fade



Environmental offsets have been utilised worldwide for over 40 years. Defined by the EPA (2011) as “an offsite action or actions to address significant residual environmental impacts of a development or activity,” these initiatives typically cover issues such as biodiversity loss and greenhouse gas emissions.

There is an array of policies, guidelines and metrics available that frame the consideration of offsets at both the state and federal levels. At Talis, we leverage these frameworks to quantify and evaluate offsets for various approvals.

Whilst acceptability of the use of offsets to counterbalance significant residual impacts forms part of the current approvals processes and are widely used, their effectiveness is questionable.

The Review of the Western Australian environmental offsets framework released in 2019 states that “implementation of the framework has not fully counterbalanced the significant residual impacts of approvals”.

Similarly, an extensive study by Guardian Australia in relation to NSW’s offsets framework was critical of “offsets that had been promised and not delivered, as well as…offsets in areas that already had some form of protection and restoration activity”.

Earlier this year, the federal government released an audit report on environmental offsets, revealing one in seven were non-compliant or potentially non-compliant with their approval conditions and a further one in four had not, or potentially had not, secured the necessary offsets.

This is alarming given recent inclusions to the Federal list of Matters of National Environmental Significance, now numbered at 2,224.

Polly Hemming notes the inherent contradiction in treating nature as a low-risk, tradeable commodity (Dec 2022 – The Saturday Paper). In our view, this underscores the problem of offsets.

Proponents want approval and may opt for low-cost solutions that align with statutory requirements.

However, these solutions might not always achieve the intended goal of counterbalancing environmental impacts. Whilst legally acceptable, they may not achieve the desired environmental outcomes.

Ethically, several questions remain to be answered in relation to improving the offsets framework, including:

  • Potential ineffectiveness to mitigate loss and provide a net gain;
  • Temporal and spatial discrepancies between impact and offset;
  • Mismatches between social and ethical values lost locally and those used as offsets;
  • Implementation and monitoring difficulties leading to poor delivery outcomes;
  • Perception issues regarding ‘buying’ an approval; and
  • Inability of offsets to counterbalance intrinsically lost values.

In this ESG world, such a one-dimensional approach is unlikely to remain palatable.

Offsets do not create acceptability for a project’s impacts but should create a net environmental benefit.

Talis suggests that offsets still have a role in the approvals framework, but their application and benefits need careful consideration.

Where used with impunity, offsets could undermine a company’s social licence to operate, damage its reputation, and lead to further environmental degradation.

Assuming nothing changes for the better, Talis suggests the acceptability of offsets may diminish, forcing proponents to demonstrate the acceptability of their proposals without relying on offsets.

What is clear is that all parties involved in the approvals process – proponent, consultant and regulator, must ensure the process remains appropriate and accountability maintained.

This is what led them to investigate the use of microcapsule technology to provide an environmentally friendly method of coal dust prevention and control.

Microcapsules are tiny particles with a ‘core-shell’ structure that belongs to a micro-packaging technology in which natural or synthetic polymer materials are used to embed and seal solid particles, liquid droplets, and even gases.

Using peanut shell waste as the organic material, the researchers separated cellulose nanofibrils (CNF), which is an emerging nanocellulose material that has properties such as high aspect ratio, high strength, and low thermal expansion, as well as a wide range of sources, low cost, and friendliness to the environment.

They then examined the microscopic action mechanism between dust-suppressing microcapsules and coal from a molecular perspective with the aid of molecular dynamics simulation software.

The simulation results were consistent with experimental phenomena, which verified the feasibility and accuracy of the molecular dynamics simulation.

The researchers said: “The dust-suppressing microcapsules prepared from peanut shells are advantageous for their low cost, good performance, and environmental friendliness.

“They can not only realise the recycling of waste but also effectively control coal mine dust.

“This process ensures the clean production of coal mining enterprises, which is consistent with the requirements of coal in the new era.”

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