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Strategic Offset Policy and Biodiversity Offset Guidelines · Report
ORDINARY MEETING 17 SEPTEMBER 2026
12.1 STRATEGIC OFFSET POLICY AND BIODIVERSITY OFFSET GUIDELINES
Author Coordinator Conservation and Environment, Rachel Lyons
Environmental Services | Strategy and Environment
Index 41.05 - Environment and Biodiversity Policy
Attachments 1. Attachment 1 - Strategic Offsets Policy - (Biodiversity) Final
2. Attachment 2 - Noosa Biodiversity Offset Guideline Final
EXECUTIVE SUMMARY
Environmental Services has developed a Biodiversity Offsets Framework comprising a Strategic
Offsets Policy and accompanying Biodiversity Offset Guideline to provide a consistent, transparent
and best-practice approach to the assessment, management and delivery of biodiversity offsets
across the Shire. The framework responds to increasing legislative requirements, community
expectations and Council's commitment to achieving nature positive outcomes through
implementation of the Corporate Plan and Environment Strategy.
The proposed framework establishes clear principles for biodiversity offsetting, including application
of:
- the mitigation hierarchy,
- additionality,
- permanence,
- net gain outcomes, and
- the prioritisation of locally delivered offsets.
It provides governance arrangements, financial management requirements, offset delivery
mechanisms, monitoring obligations and long-term reporting requirements for both Council-
generated and third-party offsets.
The framework aligns Council's environmental stewardship objectives with Commonwealth and
State offset requirements while strengthening Council's approach to managing impacts on matters
of local environmental significance. It also creates a transparent process for assessing requests from
external agencies to utilise Council land for offset delivery and provides a mechanism for securing
long-term conservation outcomes through strategic and coordinated offset programs.
Council endorsement of the Strategic Offsets Policy and adoption of the Biodiversity Offset Guideline
will establish a clear governance framework for future offset proposals and provide certainty for
Council projects and third-party proponents seeking to deliver biodiversity offsets within Noosa Shire.
RECOMMENDATION
That Council
A. Note the report by the Coordinator Conservation and Environment to the Ordinary Meeting dated
17 September 2026 regarding Strategic Offsets Policy and Biodiversity Offset Guideline; and
B. Adopt the Strategic Offsets Policy as provided in Attachment 1; and
C. Authorise the CEO to make minor administrative and editorial amendments to the Strategic
Offsets Policy and Biodiversity Offset Guideline that do not alter the intent of the documents; and
D. Request the CEO to report back in 12 months with a quantification of scale and cost for the
inclusion of voluntary Matters of Local Environmental Significance offsets as noted in the report.
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ORDINARY MEETING 17 SEPTEMBER 2026
REPORT
Developments and maintenance upgrade projects may sometimes have an impact to the
environment that may include vegetation removal, impact to threatened species habitat, impact to
marine or protected plants, or impacts to fish and aquatic passage.
Over the last two decades, legislation has been developed by State and Commonwealth
Governments that required offsets to be identified and delivered for impacts against matters of State
or Commonwealth significance. This includes:
• Matters of National Significance listed under the Environment Protection and Biodiversity
Conservation Act 1999 (C’wealth) – including but not limited to World Heritage Sites, Threatened
Ecological Communities, and listed plants and animals.
• Prescribed environmental matters under the State’s Environmental Offsets Regulation 2014
(Qld) and related legislation, including but not limited to some listed animals and plants under
the Nature Conservation Act 1992, prescribed regional ecosystem under the Vegetation
Management Act 1999, section 8(b) and fish habitat area declared under the Fisheries Act 1994.
Noosa Council has developed a Biodiversity Offsets Framework comprising a Strategic Offsets
Policy and an accompanying Biodiversity Offset Guideline. Together, these documents establish a
consistent, best-practice approach to managing and addressing unavoidable impacts on biodiversity
and biodiversity offsets arising from Council operations, infrastructure delivery, and third-party
development.
The framework is grounded in the Noosa Corporate Plan and Environment Strategy, which set a
clear direction for achieving nature-positive outcomes, strengthening ecological resilience, and
supporting a low-carbon future. Council’s Environment Strategy 2019 includes targets for which
offsets are an important mechanism for achieving biodiversity and water quality outcomes:
• By 2030 there is no net loss of ecosystem values across the shire;
• By 2030 half of all land in Noosa Shire is managed for its environmental values;
• By 2030 populations of key threatened indicator species remain viable;
• By 2030 the Noosa River and Mary River catchments achieve an A rating for their environmental
health.
Biodiversity offsets are recognised as an important tool within this broader environmental agenda,
particularly where impacts cannot be avoided or sufficiently mitigated.
The development of strong policy and guidelines reflects both local priorities and increasing global
scrutiny of offsetting practices, with a strong emphasis on ensuring offsets are credible, measurable
and deliver genuine conservation outcomes over time.
The development of the Draft Offsets Policy and Biodiversity Offsets Guideline is also a resolution
of a prior Ordinary Meeting – 15th September 2022 – Item 4, Pg 8 to: Bring forward a report on
Council’s Environment Offset Policy and associated guideline, after initial consultation has
concluded.
ISSUE
Biodiversity offsets are already required under a range of Commonwealth and State legislative
frameworks and are increasingly associated with Council infrastructure projects and third-party
development proposals. While Council currently is involved in biodiversity offset arrangements
where required, there is no overarching policy or governance framework that establishes consistent
principles, decision-making criteria and delivery expectations for offset proposals.
In the absence of a formal framework, offset opportunities have historically been considered on a
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ORDINARY MEETING 17 SEPTEMBER 2026 case-by-case basis, resulting in an ad hoc approach to assessment, negotiation and implementation. While this approach has enabled Council to respond to individual proposals, it does not provide clear or transparent guidance on how offsets should align with Council's broader environmental objectives, nor does it ensure consistent outcomes for the community. The proposed Framework establishes a transparent and consistent approach to offset management across the organisation. It provides clear principles for decision-making, defines governance and accountability arrangements, and ensures biodiversity offsets contribute to broader strategic outcomes, including Council's commitment to achieving no net loss of ecosystem values and improving ecological resilience across the Shire. There is significant benefit of getting this policy in place promptly as there are several current projects and proposed offsets and requests from 3rd party agencies (e.g. Beckmans Road Offsets with the Department of Transport and Main Roads), to use Council sites for offsets. We need a clear framework and policy for these. SUMMARY OF PROPOSED INCLUSIONS The Strategic Offsets Policy establishes overarching principles to guide all offset activities. Central to this is the application of the mitigation hierarchy, ensuring that impacts are first avoided, then minimised, and only offset as a last resort. The policy also embeds key concepts such as additionality, permanence and a requirement to achieve net gain outcomes, ensuring that offsets contribute to measurable improvements in biodiversity rather than simply compensating for loss. The Biodiversity Offset Guideline provides the operational framework for implementing the policy. It outlines when offsets are required, how they are assessed, and the mechanisms through which they can be delivered, including Council-led offsets and those undertaken in partnership with third parties. It further establishes requirements for offset delivery plans, financial arrangements, monitoring and reporting. The framework applies broadly to impacts on Matters of National and State Environmental Significance, ensuring alignment with Commonwealth and State legislation while strengthening Council’s approach to local environmental values. Collectively, the policy and guideline promote a shift from ad hoc offset management to a coordinated, programmatic approach that prioritises long-term ecological outcomes, local delivery where possible, and integration with broader conservation strategies. POTENTIAL COMMUNITY IMPACTS / BENEFITS The Framework has been developed to ensure that Offsets are delivered in a strategic, coordinated and ecologically effective way within Noosa Shire. The proposed Biodiversity Offsets Framework is expected to have a generally positive impact on the Noosa community by ensuring biodiversity offset delivery is directed toward environmental outcomes within the Shire wherever practicable. This approach supports the protection and enhancement of local biodiversity values, contributes to the achievement of Council's environmental objectives, and helps maintain the natural assets that underpin Noosa's lifestyle, visitor economy and community wellbeing. A key community benefit is the retention of offset funding within the local government area during the time when the impact is actually made. Where offsets are delivered locally, investment can support habitat restoration, revegetation works, conservation land management, ecological monitoring and other environmental improvement projects. This in turn will provide opportunities for local employment and support environmental contractors, consultants and community conservation initiatives.
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The framework also provides greater transparency and alignment in how biodiversity offsets are
developed, approved (by State and Commonwealth) and managed by Council. This is expected to
improve community confidence that unavoidable environmental impacts are being addressed
through a clear governance framework that prioritises avoidance and mitigation before offsetting is
considered.
Overall, the Biodiversity Offsets Framework is expected to deliver a net positive community outcome
by keeping and delivering biodiversity offset investment within Noosa where Council has generated
the offset, supporting local conservation outcomes, and providing a transparent and accountable
framework for managing unavoidable environmental impacts, while recognising there may be some
costs and community concerns associated with the implementation of biodiversity offset programs.
Below is a summary table of key benefits and challenges:
Potential Benefits (Pros) Comment
Greater retention of funding and The policy prioritises delivery of offsets locally,
environmental investment within Noosa meaning offset funding can be directed into
Shire. habitat restoration, environmental management
and conservation projects within Noosa rather
than outside the local government area.
Retention and enhancement of biodiversity Local delivery ensures offset outcomes directly
values within the shire. contribute to Noosa's biodiversity, ecological
connectivity and environmental resilience rather
than benefiting other regions.
Supports Council's Environment Strategy Includes no net loss of ecosystem values,
targets. improved habitat connectivity and protection of
threatened species.
Creates local employment opportunities. Retention of Council’s funds in the Shire and the
attraction of third party offset funding into the
Shire for restoration, revegetation, ecological
monitoring, bush regeneration and environmental
consulting work is likely to support local
contractors and environmental service providers.
Provides a transparent and consistent Council Departments, Project Officers,
decision-making framework. Community members and stakeholders can
better understand how offset decisions are made
within Council and how funds are managed.
Increases Council's ability to attract third- State agencies and approved proponents may
party offset investment. invest in local conservation projects through
Council-managed offset sites due to clear and
consistent policy.
Supports future conservation land Land-use compensation payments associated
acquisition. with third-party offsets may contribute to
acquisition and protection of strategically
important conservation land.
Strengthens Noosa's reputation as an The framework reflects emerging best practice
environmental leader. and demonstrates a commitment to measurable
biodiversity outcomes and nature-positive
principles.
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Potential Challenges (Cons) Comment
Potential variance in Offset costs compared While costs are expected to be broadly
to State calculated Financial Contributions comparable, some projects may incur additional
Offsetting options. or reduced costs comparable to the State Offset
Cost Calculator. This will depend on site
conditions, the availability of land and the offset
requirements. The draft Policy addresses any
untenable cost variances through extenuating
circumstance exemptions that may allow for the
use of State Financial Contributions Offsetting
option, enabling the offset funds to be made and
delivered outside the shire by the State instead
of Council.
Requirements for consideration Where offsets are required, additional planning,
in infrastructure budgets. monitoring and management costs must be
incorporated into project budgets from the outset.
This requirement already exists.
What this framework requires is that
Environment Services as the delivery agent for
Offsets within Council, to be involved during
project design to ensure that offset requirements
produce the highest environmental outcomes,
are delivered in the best location and that
Offsetting does not hold the delivery of capital
works projects up.
Land availability constraints. Suitable offset receiving sites within Noosa may
become increasingly limited over time, creating
challenges for future offset delivery. The draft
Policy addresses this through assessment of
extenuating circumstances that may cause an
offset to be delivered outside the shire.
Potential perception that offsetting Some community members may oppose offsets
legitimises environmental impacts. on principle and prefer all impacts be avoided,
regardless of offset outcomes. This is a common
concern associated with offset programs.
Offsets will continue to be legislatively required
of Council projects and this Framework will
provide greater confidence in their careful and
considered delivery.
Time lag between impact and ecological While impacts occur immediately, newly
benefit. established offset sites may take years to deliver
equivalent habitat values. This is an inherent
characteristic with biodiversity offsets globally.
As such it is imperative that ES is involved in
Offset design to enable the best investment with
quickest and most effective outcomes is selected
and developed.
Additional administrative responsibilities for Ongoing monitoring, reporting, governance and
Council. management of offset sites will require staff
resources and oversight. Our Framework
proposes that these costs are factored into the
project budget that generates the offset initially,
or is factored into the contract costs for Third
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ORDINARY MEETING 17 SEPTEMBER 2026
Party offsets delivered on Council land. As such
the administration burden is low.
Long-term land commitments. The lands included for Offsetting will be wholly
encompassed within Council’s reserve network,
land specifically acquired and deemed highest
use for offsets and/or land within Protected
tenure such as Nature Refuges and Voluntary
Conservation Agreement areas.
Delivery risk. As with any ecological restoration program, there
is a risk some offset sites may not initially
perform as expected and require adaptive
management or additional investment. As noted
above, this is an inherent risk regardless of
where/how the offsets are being delivered. The
risks are lower when specialist ecological advice
provided by the ES team is considered early in
Offset design and site selection.
POLICY NEED WITHIN AN EXISTING COMPLIANCE FRAMEWORK
Biodiversity offsets are already required under a range of Commonwealth and State legislative
frameworks and are increasingly associated with Council infrastructure projects and third-party
development proposals. While Council currently is involved in biodiversity offset arrangements
where required, there is no overarching policy or governance framework that establishes consistent
principles, decision-making criteria and delivery expectations for offset proposals.
In the absence of a formal framework, offset opportunities have historically been considered on a
case-by-case basis, resulting in an ad hoc approach to assessment, negotiation and implementation.
While this approach has enabled Council to respond to individual proposals, it does not provide clear
guidance on how offsets should align with Council's broader environmental objectives, nor does it
ensure consistent outcomes for the community.
The proposed Biodiversity Offsets Framework establishes a transparent and consistent approach to
offset management across the organisation. It provides clear principles for decision-making, defines
governance and accountability arrangements, and ensures biodiversity offsets contribute to broader
strategic outcomes, including Council's commitment to achieving no net loss of ecosystem values
and improving ecological resilience across the Shire.
Importantly, the framework creates an opportunity to maximise community benefit from offset
investments. Without a policy, offset funding and environmental investment may be directed outside
the Shire or toward isolated projects that do not contribute to broader conservation priorities. The
proposed framework provides a mechanism to strategically direct offset investment toward locally
identified environmental priorities, helping retain environmental, economic and community benefits
within Noosa wherever practicable.
The framework also reduces legal, financial and reputational risks by ensuring offsets are managed
consistently, transparently and in accordance with contemporary best practice. This provides greater
certainty for Council, the community, and external agencies seeking to partner with Council in the
delivery of biodiversity offsets.
INCLUSION STATEMENT
The Biodiversity Offsets Framework applies to biodiversity offset requirements generated by Noosa
Council activities and to offset proposals from third-party agencies seeking to deliver biodiversity
offsets within Noosa Shire. This includes agencies undertaking projects within the Shire that
generate offset obligations, as well as agencies undertaking projects outside Noosa that are seeking
to compensate for biodiversity impacts through offset delivery within the Shire
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ORDINARY MEETING 17 SEPTEMBER 2026 The framework applies to biodiversity offset requirements arising under existing Commonwealth and State legislation where a project results in a significant residual impact on biodiversity values. The specific triggers, exemptions and assessment thresholds are established through the relevant legislative frameworks and associated policies and are therefore not reproduced in detail within this report. These legislative requirements principally relate to impacts on Matters of National Environmental Significance (MNES) protected under the Environment Protection and Biodiversity Conservation Act 1999 and Matters of State Environmental Significance (MSES) protected under Queensland legislation, including the Environmental Offsets Act 2014, Nature Conservation Act 1992 and associated regulatory frameworks. The framework does not currently apply to Matters of Local Environmental Significance (MLES). While these values are recognised through Council's planning framework and are important contributors to the environmental health and ecological connectivity of the Shire, there is currently no legislative requirement for Council to offset impacts to these values. The draft policy and guideline do, however, recognise the potential future application of voluntary offsetting for some locally significant biodiversity impacts. This would enable Council to consider a broader "no net loss" approach for environmental values that are not currently captured by State or Commonwealth offset legislation. Examples may include vegetation clearing associated with road upgrades, infrastructure projects within existing corridors, or impacts to locally significant vegetation communities and habitat values that do not trigger legislative offset requirements. Any future expansion of the policy to include voluntary offsetting of MLES would be subject to further Council consideration, including assessment of financial and operational implications. Link to Corporate Plan Theme No 1 - Environment Objective 1.1 - Maintain and improve water quality and the health of waterways, wetlands, and catchments. Objective 1.5 - Deliver expanded vegetation networks, rehabilitation and habitat across the Shire and advocate to the state and federal governments to assist funding environmental action. Objective 1.6 - Partner with community to improve the health and water quality management of Noosa and Mary Rivers and coastal areas through whole of catchment management to protect environmental values while enabling sustainable public access, recreation, and commercial use. Objective 1.7 - Deliver and partner with State and Federal Governments to protect threatened and vulnerable species identified in the Environment Strategy Key Actions: • Delivery of annual Capital Infrastructure Program. Performance Measure: • There is no net loss of ecosystem values across the shire and the condition of Council’s priority bushland reserves are enhanced. Previous Council Consideration Planning & Environment Committee Meeting Minutes 6 September 2022 TRANSPORT AND MAIN ROADS ENVIRONMENTAL OFFSETS Committee Recommendation Moved: Cr Stockwell
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ORDINARY MEETING 17 SEPTEMBER 2026 Seconded: Cr Stewart That Council note the report by the Acting Principal Environment Officer to the Planning & Environment Committee Meeting dated 6 September 2022 and request the Chief Executive Officer: A. Continue negotiations with Transport and Main Roads Department about opportunities for use of suitable land as environmental offset receiving sites and update Council on the outcomes; and B. Bring forward a report on Council’s Environment Offset Policy and associated guideline, after initial consultation has concluded. Carried unanimously. Finance Implementation of the framework requires the allocation and management of resources to support offset delivery over the full lifecycle of projects. This includes planning, establishment, monitoring, maintenance and long-term management costs. Much of this is incorporated into existing roles. For Council projects, these costs are incorporated into project budgets at the design stage. For third- party projects, financial contributions will be secured through agreements and quarantined to ensure funds are available to deliver the required conservation outcomes. The costs required for biodiversity offsetting are already required to be included in council project budgets and no additional resource will be required with the adoption of this policy. The framework also enables the collection of land-use compensation payments from third parties where there is a costs associated with Council land being used as an offset receiving site, this cost is paid by the third party, this contribution can further support future land acquisition and conservation initiatives. Inclusion of Additional Council Biodiversity Offsetting An initial request sought to consider including relevant Council projects involving vegetation clearing, that are currently exempt from State or Commonwealth legislation, in the Strategic Offsets Policy and Guideline. The matter was discussed at the Executive Leadership Team meeting on 17th June 2026, where it was recommended that inclusion be deferred until the associated costs and implications are better understood. As no register of these impacts currently exists, the potential cost to Council remains uncertain. Risk & Opportunities The adoption of the Biodiversity Offsets Framework presents a balanced risk profile. On one hand, it significantly reduces legal, financial and reputational risks by providing a transparent, consistent and well-governed approach to offsetting. On the other hand, there remain some inherent risks associated with biodiversity offsets, particularly the potential for delayed ecological outcomes and the possibility that offsets may not fully replicate impacted values. These risks are mitigated through strong governance mechanisms, including rigorous planning requirements, long-term monitoring, adaptive management and the use of advanced offsets to reduce time lags between impact and ecological benefit. Financial risks are further reduced through secured and quarantined funding arrangements. There is also some reputational risk associated with community perceptions of offsetting; however, this is addressed through the framework’s emphasis on transparency, accountability and a clear commitment to achieving a net gain in biodiversity outcomes. The risk assessment below indicates residual risk for the adoption of the Biodiversity Offsets Framework:
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Risk Category Risk Consequence Control Residual
Risk
Health and Safety Limited direct risk Minimal Direct Standard Low
Impact operational
procedures
Legal and Non-compliance with Incomplete offset Alignment with Low
Compliance State/Commonwealth delivery - legislative
offset requirements Regulatory frameworks and
penalties or project formal
delays agreements
Inclusion of
extenuating
Impacts ability to
circumstances
Land availability deliver legally
clause that Low
constraints required offsets
provides for offset
within the shire
delivery outside the
shire
Environment Offsets fail to deliver Net loss of Strong policy Low
genuine biodiversity biodiversity values principles,
outcomes monitoring, and
adaptive
management
Time lag between Delayed ecological Advanced offsets Low
impact and offset benefit and long-term
maturity management
commitments
Cyber Security Nil Nil N/a Low
Financial Insufficient funding for Incomplete offset Quarantined Low
Management long-term management delivery funding and whole-
of-life costing
developed prior to
acceptance with
contingencies
considered.
Reputation/Public Perception that offsets Community Clear mitigation Medium
Trust legitimise concern and hierarchy and
environmental harm reduced trust transparent
reporting
Poor performance of Loss of confidence Utilising strong Low
offsets in Council expertise in project
environmental development and
leadership management.
Monitoring,
reporting and
governance
oversight.
Inconsistent application Stakeholder Standardised Low
of offsets dissatisfaction framework and
processes
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ORDINARY MEETING 17 SEPTEMBER 2026
People and Culture Internal capability gaps Implementation Defined roles and Low
challenges responsibilities,
governance
structure. Existing
Position and
Project
Management costs
built into Project
Costs or Third-
Party funding
agreements.
Assets Long-term land Reduced Strategic land-use Low
commitment for offsets alternative land use planning and
options compensation
mechanisms. Offset
placement in
appropriate areas.
Service Delivery Increased project Delays to Early planning and Low
complexity infrastructure integration into
delivery project design
Economy Increased cost of Potential impacts Clear processes Low
development on project feasibility and shared
responsibility with
proponents
Human Rights
Human Rights Compatibility Statement
In developing this Report, the subject matter has been considered in accordance with the
requirements of the Queensland Human Rights Act 2019. It is considered that the subject matter
does not conflict with any human rights and supports a human rights approach to decision making
by Council. Council representatives will endeavour to act and make decisions under this report in a
manner that is compatible with human rights. This report should be read in conjunction with
Council’s Human Rights Policy.
Consultation
External Consultation - Community & Stakeholder
Nil
Internal Consultation
Departments consulted:
Office of the CEO, Mayor & Community Services Corporate Services
Councillors
x Mayor & Councillors x Director x Director
x Chief Executive Officer Community Connection Financial Services
Executive Officers Sport & Active Lifestyles Revenue Services
Community Engagement Arts & Culture ICT
x Governance Customer Experience Procurement
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People & Culture
Strategy & Environment Development & Regulation Infrastructure Services
x Director x Director x Director
x Strategy & Sustainability x Development Assessment x Civil and Asset operations
Economic Development & Infrastructure Planning, Design
Local Laws x
Destination Management and Delivery
x Environmental Services Environmental Health x Waste
Innovation & Digital Hub Building & Plumbing Building & Facilities
Commercial Property x Property / Permits Disaster Management
Fleet