Environment & Energy

New South Wales is still clearing native vegetation faster than nature can restore it, and the statutory review of the Biodiversity Conservation Act found the current framework is not meeting its objectives. The state's own biodiversity offsets scheme has been criticised by the Auditor-General and by parliamentary committees for promising environmental gains it cannot demonstrate. But the underlying data is more mixed than the shorthand allows — and the mix matters, because it changes what you would actually do about it.

What the clearing data actually shows

The 2024 NSW vegetation clearing report, produced from the Statewide Landcover and Trees Study, records 24,103 hectares of native woody vegetation cleared in 2024 — 19 per cent below the 2018–2024 average of 29,800 hectares, continuing a declining trend since the Land Management Framework began in 2018 (NSW DCCEEW, 2026a). That is a genuine improvement and we should say so plainly rather than pretend nothing has changed since 2016.

The same report records at least 57,190 hectares of native non-woody vegetation cleared — native grasslands, wetlands and shrublands — which is 13 per cent above the 2018–2024 average of 50,700 hectares (NSW DCCEEW, 2026a). Cumulatively since the framework began, 208,700 hectares of woody and 355,000 hectares of non-woody native vegetation have been cleared (NSW DCCEEW, 2026a). Woody clearing is falling. Non-woody clearing is rising. A debate conducted only about trees will miss more than half of what is being lost, and the grassy ecosystems disappearing fastest are among the most poorly reserved in the state.

The harder number is the one nobody can explain. Of the clearing detected in 2024, 71,220 hectares was attributed to agriculture, 7,268 hectares to infrastructure and 2,805 hectares to native forestry harvesting — but 49,146 hectares, 60 per cent of the total, could not be matched to any approval or exemption at all (NSW DCCEEW, 2026a). We will not call that unlawful clearing, because it is not a finding of illegality; "unallocated" is a data-matching category, and a good deal of it will turn out to be lawful activity the reporting system simply cannot reconcile. It is still an accountability failure. A regulator that cannot account for three-fifths of the clearing it detects cannot tell the public whether its own rules are working. The data also lags by roughly 18 months, so 2024 is the most recent year available — which is a further argument for faster, better-matched reporting rather than for more adjectives.

A scheme that was audited, then reviewed, then only half-commenced

The Auditor-General's 2022 performance audit of the Biodiversity Offsets Scheme did not hedge. It found the then Department of Planning and Environment "has not effectively designed core elements of the Scheme" and had no clear strategic plan for implementing it (Audit Office of New South Wales, 2022). The specifics are worse than the adjectives usually used about them: 96 per cent of developer demand for species credits was unmet; 97 per cent of species credits had never been traded at all; only 60 per cent of 226 Biodiversity Stewardship sites were under active management; $90 million in developer obligations had been paid into the Biodiversity Conservation Fund; and only 20 per cent of developer obligations transferred to the Biodiversity Conservation Trust had been acquitted (Audit Office of New South Wales, 2022). The audit made 11 recommendations. It is fair to note that the audited entity has since been restructured, with responsibilities split between the environment and planning departments, and that the audit predates the 2024 amending Act — so it should be read as the baseline the reforms are meant to answer, not as a description of the scheme today.

The independent statutory review of the Biodiversity Conservation Act 2016, led by Dr Ken Henry AC and tabled in the NSW Parliament in August 2023, went further than the offsets machinery. It found the Act was not meeting its primary purpose of maintaining a healthy, productive and resilient environment and was never likely to do so, that biodiversity was not being conserved at either bioregional or state scale, and that only around half of the state's threatened species could be expected to survive the next hundred years; it recommended refocusing the Act toward a nature positive framework with stronger ecosystem-level protections (NSW Department of Planning and Environment, 2023). That is a structural finding, not a performance one — the distinction being that a scheme which is merely underperforming can be administered better, while a scheme that cannot succeed as designed has to be redesigned.

The Government's response, the Plan for Nature released in July 2024, accepted 49 of the 58 recommendations, while declining to give the Biodiversity Conservation Act primacy over planning law and ruling out mapping "no-go" zones (NSW DCCEEW, 2026b). The Biodiversity Conservation Amendment (Biodiversity Offsets Scheme) Act 2024 passed in November 2024 and commenced on 7 March 2025. It embeds the avoid–minimise–offset hierarchy, requires the scheme to transition toward net positive biodiversity outcomes guided by a net positive strategy, and reduces reliance on the Biodiversity Conservation Fund by allowing regulations to specify circumstances in which the fund cannot be used (NSW DCCEEW, 2026b). Supporting amendments to the Biodiversity Conservation Regulation 2017 were on public consultation from 5 June to 17 July 2026.

So the honest question in 2026 is not whether to reform the offsets scheme. It is whether the reform already legislated ever fully starts. One set of provisions did not commence with the rest: the provisions on assessing genuine measures to avoid and minimise biodiversity impacts remain uncommenced (NSW DCCEEW, 2026b). That is a fact about commencement rather than an accusation — but it is precisely the element that makes offsetting a last resort instead of a first convenience. An avoid–minimise–offset hierarchy with the avoid-and-minimise test switched off is an offset scheme with a longer name.

What the koala inquiry actually found

The koala has become the emblem of what is at stake, and the 2020 parliamentary inquiry's warning has a precise form worth quoting. Portfolio Committee No. 7 of the Legislative Council found, at Finding 2, "that, given the scale of loss to koala populations across New South Wales as a result of the 2019-2020 bushfires and without urgent government intervention to protect habitat and address all other threats, the koala will become extinct in New South Wales before 2050" (Legislative Council Portfolio Committee No. 7, 2020). That was a committee finding rather than a government or scientific determination, and it was one of 16 findings accompanied by 42 recommendations.

Three of the committee's other findings are more useful to policy than the headline. Finding 1 was that "the current estimated number of 36,000 koalas in New South Wales is outdated and unreliable" — meaning the state has been managing a species it cannot count. Finding 3 was "that logging in public native forests in New South Wales has had cumulative impacts on koalas over many years because it has reduced the maturity, size and availability of preferred feed and roost trees". Finding 10 was that "an estimated 24 per cent of koala habitat on public land has been severely impacted across the State, but in some parts there has been a devastating loss of up to 81 per cent" (Legislative Council Portfolio Committee No. 7, 2020). Taken together they describe a problem of habitat quality and continuity, not merely of numbers — which is why a reserve boundary on its own is not the answer.

The Great Koala National Park, and the condition attached to it

The Government has committed to establishing the Great Koala National Park on the Mid North Coast — a commitment we support and would hold it to delivering in full, with secure long-term funding, honest treatment of the state forests involved, and real transition support for affected timber workers and their towns. The September 2025 ministerial release commits to adding 176,000 hectares of state forest to create a reserve of about 476,000 hectares once joined with existing national parks, which the Government says will protect more than 12,000 koalas and 36,000 greater gliders along with habitat for over 100 other threatened species (NSW Government, 2025). It provides $60 million to the National Parks and Wildlife Service to establish the park and $6 million for community and small business support on the Mid North Coast, and applied a moratorium on timber harvesting inside the boundary from 8 September 2025, affecting around 300 jobs and 6 of more than 25 mills in the region (NSW Government, 2025).

Two things follow, and both should be said out loud by people who support the park. The first is that the park is not yet reserved: reservation requires a Bill under the National Parks and Wildlife Act 1974, indicatively flagged for late 2026, and an indicative date is not a reservation. The second is the real test. The Government's own release states that final creation of the park depends on the successful registration of a carbon project under the Improved Native Forest Management Method, which was still moving through Commonwealth assessment (NSW Government, 2025). A conservation outcome contingent on a carbon methodology being approved by another government is a conservation outcome with a financing risk attached, and the public is entitled to be told how that risk is being managed rather than discovering it in a footnote.

The $6 million offered for community and small business support also has to be weighed honestly against 300 affected jobs in towns where the mill is often the largest private employer. We support the park. We do not think a transition package is generous merely because it was announced alongside a good decision.

Beyond the park, we would prioritise mapped koala habitat corridors that link core populations across public and private land, stronger enforcement of clearing rules with accurate, published and faster-reported data, and offset arrangements that are the last resort, not the first convenience — starting with commencing the provisions that were meant to make that true.

From Collaroy to Wamberal and along the open coast, storm erosion is already eating into beaches, dunes and homes — and sea levels are rising. Pretending otherwise helps nobody, least of all coastal property owners.

The framework exists; the Auditor-General says it is not being implemented

New South Wales does not lack a coastal management framework. It lacks delivery of one, and in September 2025 the Auditor-General said so directly: "the coastal management framework is not being effectively implemented to manage the NSW coastal environment" (Audit Office of New South Wales, 2025). As at April 2025 — seven years after the framework took effect — only 17 coastal management programs, covering 16 of the state's 55 coastal councils, had been certified by the Minister, against the environment department's own target of 20 certified programs by June 2025 (Audit Office of New South Wales, 2025). Two-thirds of coastal councils are therefore operating without a certified program at all.

The audit also identified where the pressure points sit. In July 2025 the department estimated the total cost of all actions within those 17 certified programs at around $341.6 million — the cost of coastal work already committed to, before the other 39 councils are counted (Audit Office of New South Wales, 2025). The audit found that the environment and planning departments "have identified risks to delivering policy objectives for managing areas at risk from coastal hazards due to incomplete mapping of the coastal vulnerability area"; that the department had itself identified insufficient funding in the Coastal and Estuary Grants Program as a key risk; and that the councils examined — City of Coffs Harbour, Shoalhaven City and Northern Beaches — faced difficulty integrating coastal management actions into their planning because of uncertainty about long-term funding (Audit Office of New South Wales, 2025).

That is a specific diagnosis and it deserves a specific response. The audit examined framework implementation, mapping and funding; it did not make findings about planned retreat or managed relocation, and we do not claim it did.

We support honest, completed coastal vulnerability mapping for the whole NSW coast; proper funding and technical support so councils can complete and implement coastal management programs on a horizon longer than a grant round; clear disclosure of known hazards to property buyers; and evidence-based responses — dune restoration and beach nourishment where they work, planned adjustment where they will not. The worst outcome is the current drift: decisions deferred until an east coast low makes them for us, at which point the state pays for the emergency it declined to pay to prevent.

The same pressure, upstream: the Hawkesbury–Nepean

Coastal pressure is not only erosion. Western Sydney's growth is arriving in the Hawkesbury–Nepean's estuarine reaches as nutrients. The Environment Protection Authority's July 2025 nutrient management framework states that under business as usual, "total nitrogen loads discharged from the 18 treatment plants in the river's catchment are projected to increase by approximately 50% by 2028", and that "the current nutrient load caps in environment protection licences for these 18 plants are not suitable for managing this risk" (NSW EPA, 2025).

Phase 1 of the framework began on 1 July 2025 and runs to 30 June 2030, deliberately aligned to IPART's pricing determination periods. It applies to 15 plants operated by Sydney Water, two by Hawkesbury City Council and one by Veolia, capping total nitrogen and total phosphorus loads across six subzones — Yarramundi 1 and 2, Sackville 1, 2 and 3, and Berowra Creek — at 2007–2018 average levels plus 10 per cent, less the reduction achieved by the Winmalee plant upgrade, with trading and offsets permitted between plants (NSW EPA, 2025). We support this as a serious piece of regulation that starts from a load cap rather than a concentration limit, and we would defend the trading provisions as the cheapest way to hit a catchment-wide number.

Two honesty clauses belong with it. First, the framework regulates sewage treatment plants only, and the EPA notes that diffuse sources — urban, grazing, cropping and intensive agricultural runoff — contribute the majority of the total nutrient load reaching the lower catchment. It is not a whole-of-catchment fix and should not be sold as one. Second, the EPA states that current scientific knowledge does not yet allow an estimate of the load reductions actually required for a sustainable river, with Phase 2 from 1 July 2030 intended to close that gap (NSW EPA, 2025). A cap set at historical levels plus ten per cent is a holding position while the science is done. Holding positions are defensible; permanent holding positions are not, and we would want the Phase 2 science funded and published on time rather than discovered to be late in 2030.

Greater Sydney is running short of landfill capacity. The Environment Protection Authority states plainly that "Greater Sydney is running out of ways to safely manage 'residual' (red bin) waste and is predicted to run out of landfill capacity by 2030 or earlier" (NSW EPA, 2026b). That is not a problem you can landfill your way out of.

Return and Earn is the state's most successful environmental program, and it is about to get bigger

New South Wales has already proven the alternative works. In January 2026 the EPA announced that 15 billion containers had been returned through Return and Earn since the scheme launched in December 2017, with $1.5 billion paid out in refunds — the tally having risen from 14 billion to 15 billion in under six months, with around nine million containers returned per day over summer (NSW EPA, 2026a). More than $91.5 million in container refund donations and host fees has gone to charities and community groups since 2017 (NSW EPA, 2026a). Very few state programs can show participation numbers like that, and the reason is not mysterious: the incentive is immediate, legible and paid at the point of effort.

From mid-2027 the scheme is legislated to expand to accept wine and spirit bottles and larger drink containers. The EPA estimates this will divert about 27,000 tonnes of material from NSW landfills annually and make an additional 362 million containers a year eligible for the 10 cent refund (NSW EPA, 2026a). Those are estimates of the effect of a future expansion rather than measured outcomes, and we would want them reported against after the fact — because a scheme with this much credibility can afford to publish whether its own projections held.

FOGO has dates, and the deadline behind it is a landfill deadline

Food and garden organics collection is not an aspiration in New South Wales; it is legislated with dates attached. Parliament has legislated to mandate FOGO collection services for households by 1 July 2030, and for businesses and institutions in stages from 1 July 2026, with the largest waste generators first and thresholds staggered through to 2030; large supermarkets will additionally be required to record food donations across six categories (NSW EPA, 2026b). The rationale is the landfill wall described above, set against the state's commitment under the Waste and Sustainable Materials Strategy 2041 to halve the organic waste going to landfill by 2030. EPA analysis found that applying the household mandates statewide may divert almost 950,000 tonnes of FOGO waste each year from landfill (NSW EPA, 2026b) — a modelled figure, not an observed one.

The risk in a mandate with a date is that the date arrives before the capacity does. Councils need processing capacity, contamination management and kerbside education funded on the same timetable as the obligation, and the businesses captured from July 2026 need to know which threshold applies to them well before it does. We would keep the momentum practical: complete the FOGO rollout with real support for councils rather than an unfunded obligation, set recycled-content targets in government purchasing so collected materials have a market to go to, back resource-recovery and remanufacturing industries as a genuine regional jobs opportunity, and push product stewardship so the cost of dealing with packaging and e-waste sits with the producers who design it.

The through-line connecting Return and Earn and FOGO is worth naming, because it is the strongest argument in this section: New South Wales gets good waste outcomes when the obligation is clear, the date is fixed, and someone is paid for doing the right thing. It gets poor ones when material is collected and then has nowhere to go.

Western Sydney summers are already dangerous. Penrith recorded about 48.9 degrees in January 2020 — reported that day as among the hottest places on Earth — and heatwaves are consistently reported as Australia's deadliest natural hazard. Yet the suburbs growing fastest are often those with the least shade.

The state's own index shows how unevenly this falls

This is no longer an impression. The planning department's August 2025 data pack, drawing on the 2022 Heat Vulnerability Index for the Greater Sydney Region, gives the share of statistical area level 1 units in each local government area scoring 5, the highest heat vulnerability rating: Fairfield 71 per cent, Penrith 49 per cent, Liverpool 32 per cent, Cumberland 31 per cent, Blacktown 29 per cent, Canterbury-Bankstown 21 per cent and Campbelltown 19 per cent (NSW DPHI, 2025).

At the other end of the city the same index records Ku-ring-gai with 81 per cent of its SA1s at score 1, the lowest rating, and none at all at score 5; Woollahra, Mosman, Lane Cove, Hunters Hill and the Blue Mountains each record zero per cent at score 5 (NSW DPHI, 2025). In seven of Sydney's fastest-growing western and south-western councils, between a fifth and seven-tenths of neighbourhoods are rated most vulnerable. In five established councils, none are.

Two qualifications matter and we state them. The index combines exposure, sensitivity and adaptive capacity — it measures vulnerability, not temperature, and a score of 5 is not a thermometer reading. And the planning department itself notes that the LGA-level distribution is indicative only. Neither qualification disturbs the pattern, which is that heat vulnerability in Sydney maps almost exactly onto income, tree cover and housing age.

Canopy is moving, slowly, and in the right places

The same department records Greater Sydney tree canopy — vegetation over three metres — at 21.9 per cent in 2024–25, 21.7 per cent in 2022–23 and 21 per cent in 2019, with the greatest recent gains in western Sydney local government areas (NSW DPHI, 2025). That is genuine progress and it is happening where it is most needed, which is worth acknowledging rather than dismissing. It is also slow: 0.9 percentage points over roughly five years, against a canopy deficit in the western suburbs measured in decades of growth. A tree planted in a new release area in 2026 provides meaningful shade in the 2040s. This is precisely the kind of policy where delay is not neutral.

We would treat urban heat as core infrastructure policy rather than as landscaping: enforceable tree-canopy targets in new release areas and along streets, dark-roof restrictions and cool-building standards in growth precincts, water kept in the landscape, and shade at the places people actually wait — bus stops, school gates, playgrounds and car parks. The existing canopy programs for Greater Sydney point the right way and are measurably working; the test is pace, and pace must be measured and published, suburb by suburb, against the vulnerability index the Government already publishes.

1. Buy abatement by the tonne, not by the technology

Require every New South Wales climate and energy program to publish an estimated cost per tonne of CO2-e abated, on a consistent method, updated as technology costs move — and use that number, rather than a technology's popularity, to decide what is funded, expanded or wound up. The spread is not marginal. The NSW Productivity and Equality Commission reports that each intervention carries "a different, but measurable, cost of abatement per tonne of CO2-e, even though these costs may not be explicitly set out": tradeable certificates under state energy efficiency schemes carry an estimated implicit carbon price of $41 per tonne of CO2-e, while the original NSW Electric Vehicle Strategy implied a carbon price of between $271 and $4,914 per tonne of CO2-e (NSW Productivity and Equality Commission, 2024). Two of that Commission's own principles for navigating a world without a broad-based carbon price belong in program design: that interventions "should be technologically agnostic and competitively neutral", and that policy overlaps "should be avoided, except where policies are clearly complementary" (NSW Productivity and Equality Commission, 2024). Much of the machinery already exists — the NSW Government Guide to Cost-Benefit Analysis requires a cost-benefit analysis for every capital, recurrent and ICT proposal with an estimated total cost higher than $10 million (NSW Productivity and Equality Commission, 2024) — so what is missing is publication, and the willingness to act on an unflattering answer. Nationally, the Productivity Commission puts the same test first: "Focus on reducing emissions, not how they are reduced." Modelling prepared for its December 2025 inquiry found the National Electricity Market could reach the renewable penetration implied by current state targets at 4 per cent less total cost over the period 2026 to 2040 by removing targets for specific technologies — around $4 billion — and at 8 per cent less by removing technology- and state-specific targets together (Productivity Commission, 2025). This is in genuine tension with section 3, and we should say so rather than dress it up: the Renewable Energy Zones are a state-directed, technology-specific build, and this direction is an argument for testing them honestly, not for abandoning them. Our answer is that the build should be able to show its work — published costs, published benefits, and the "off-ramps" the Productivity Commission recommends for technology-specific support, so that a program which stops earning its place can be ended without a fight.

2. Say out loud what reliability costs, and never charge households twice for the same megawatt

For every firming, storage or capacity intervention the state makes, publish which reliability obligation it is meeting, what it is expected to cost, and who ultimately pays — and require an explicit finding that New South Wales is not buying capacity a Commonwealth scheme has already underwritten. The state currently sits beneath three stacked reliability commitments: the National Electricity Rules standard requiring that at least 99.998 per cent of forecast consumer demand is met each year, a stricter interim reliability measure of 0.0006 per cent of expected unserved energy running to 30 June 2028, and the NSW Energy Security Target legislated in 2020 (NSW Productivity and Equality Commission, 2024). None of it is free. "Very high reliability comes with additional costs", the Commission notes, and the generation, firming and network capacity needed to meet a standard with confidence "carries capital and operating costs, which are ultimately borne by customers" — so "the higher the desired level of reliability, the higher the costs for electricity faced by consumers" (NSW Productivity and Equality Commission, 2024). The duplication risk is not hypothetical: the NSW firming tender that awarded 1,075 MW of firm capacity in September 2023 was "later supported by the Commonwealth as the first phase of its new Capacity Investment Scheme", and the same Commission warns of "the costs of complying with multiple state and Commonwealth policies, particularly for maintaining very high system reliability" (NSW Productivity and Equality Commission, 2024). The Productivity Commission is blunter: "An activity should not face multiple incentives to reduce emissions. Overlapping incentives create the risk that emitters will choose options because they are strongly incentivised to do so, even if they are more costly than necessary for consumers or taxpayers" — and where a scheme does back a higher-cost technology, its view is that "any additional costs should be funded through government budgets rather than by consumers" (Productivity Commission, 2025). Two qualifications belong in the same breath. This is an argument about transparency, not about running the system thinner: cheap unreliability is no saving, and the task is real — AEMO's 2025 Electricity Statement of Opportunities reports that the reliability gaps once forecast for New South Wales after Eraring's advised retirement in 2027-28 are no longer forecast, but that "system security and operability challenges remain" (Australian Energy Market Operator, 2025a). AEMO's October 2025 update to that report, issued after Queensland's Gladstone Power Station was advised for potential closure in 2029, moves the state's exposure earlier: on committed and anticipated developments alone, New South Wales needs 245 MW of additional firm capacity to hold the 0.002 per cent reliability standard in 2031-32, rising to 5,460 MW by 2033-34 (Australian Energy Market Operator, 2025b). And it has to be weighed against the benefit-sharing commitments in section 3, which we stand by: those payments are a real cost that lands somewhere, in bills or in the budget, and we would rather defend them openly as the price of building the transition decently than pretend they cost nothing.

3. Commence the avoid-and-minimise provisions, and report the offsets scheme against numbers rather than adjectives

The Biodiversity Conservation Amendment (Biodiversity Offsets Scheme) Act 2024 commenced on 7 March 2025 with one conspicuous exception: the provisions on assessing genuine measures to avoid and minimise biodiversity impacts remain uncommenced (NSW DCCEEW, 2026b). We would have those provisions commenced with a published date, and we would have the reformed scheme report annually against the specific failures the Auditor-General measured — the proportion of species credit demand actually met, the proportion of credits ever traded, the proportion of stewardship sites under active management, and the proportion of developer obligations transferred to the Biodiversity Conservation Trust that have been acquitted (Audit Office of New South Wales, 2022). The point of naming those four metrics is that they were measurable in 2022 and can therefore be measured again. A "net positive" strategy that cannot be checked against the numbers which exposed the old scheme is a rebrand. We also acknowledge what the Government declined: it ruled out giving the Biodiversity Conservation Act primacy over planning law and ruled out mapping no-go zones (NSW DCCEEW, 2026b). Those are legitimate choices to argue about — but they mean the avoid-and-minimise test is carrying more weight than it was originally designed to carry, and it is the part that is not switched on.

4. Publish the Great Koala National Park's critical path, including the carbon condition

We support the park. Supporting something is not the same as assuming it will happen. The Government's own release makes final creation of the park dependent on the successful registration of a carbon project under the Improved Native Forest Management Method, then still moving through Commonwealth assessment, and reservation itself requires a Bill under the National Parks and Wildlife Act 1974 (NSW Government, 2025). We would have the Government publish, and keep updated, the status of the carbon project registration, the timing of the reservation Bill, and what happens to the harvesting moratorium if the carbon project is not registered. We would also have the $6 million in community and small business support reported against the roughly 300 affected jobs and the 6 of more than 25 regional mills involved (NSW Government, 2025), because a transition package is judged on whether people landed somewhere, not on whether it was announced. And we would fund the counting: the 2020 committee found the then-standing estimate of 36,000 koalas "outdated and unreliable" (Legislative Council Portfolio Committee No. 7, 2020), and a park whose success cannot be measured is a park whose success can be asserted indefinitely.

5. Fund coastal management programs to completion, and finish the vulnerability mapping

Seven years after the coastal management framework took effect, only 17 coastal management programs covering 16 of 55 coastal councils had been certified as at April 2025, against the department's own target of 20 by June 2025 (Audit Office of New South Wales, 2025). We would treat that as a resourcing and mapping failure rather than a council failure, because that is what the Auditor-General found: incomplete mapping of the coastal vulnerability area, insufficient funding identified in the Coastal and Estuary Grants Program, and audited councils unable to integrate coastal actions into their planning because they could not rely on long-term funding (Audit Office of New South Wales, 2025). Three things follow. Complete the coastal vulnerability area mapping and publish it, because a hazard that is not mapped cannot be disclosed to a buyer or planned around by a council. Put the Coastal and Estuary Grants Program on a multi-year footing, so that a twenty-year coastal program is not funded a year at a time. And publish the true cost: the department's own estimate of around $341.6 million for the actions in the 17 certified programs (Audit Office of New South Wales, 2025) is a partial figure covering under a third of coastal councils, and the state should say what the whole coast costs before an east coast low says it instead.

6. Report the energy transition against the closure calendar, in public, twice a year

New South Wales already publishes a monitor that names the years the gaps fall in — a 274 MW breach in 2027-28 on Eraring's assumed closure, sufficiency from 2029-30 to 2032-33 once HumeLink and the Hunter Transmission Project are commissioned, then a much larger breach from 2033-34 continuing into 2034-35 as Bayswater and Vales Point close (NSW DCCEEW, 2025). What it does not do is track delivery against those dates in a form a member of the public can follow. We would have a single published ledger, updated twice a year, setting out for each replacement project its approval status, its financial close, its expected energisation date and how far that date has moved — for Central-West Orana against its 2028 energisation and 2030 completion (EnergyCo, 2026), for New England against whatever approval date it actually achieves rather than the indicative one, and for system strength and inertia procurement against AEMO's finding that the fix is scheduled about a year after Eraring's originally announced exit (Australian Energy Market Operator, 2025c). The Eraring extension to 30 April 2029 (Origin Energy, 2026) bought the state roughly twenty months. A published ledger is how the public finds out whether they were used.

7. Close the clearing accountability gap before arguing about the clearing numbers

Sixty per cent of the native vegetation clearing detected in New South Wales in 2024 — 49,146 hectares — could not be matched to an approval or exemption (NSW DCCEEW, 2026a). That is not a finding of illegality and should never be reported as one. It is a finding that the state's clearing regulation cannot presently explain most of what its own satellites see. We would have the department publish an annual reconciliation of unallocated clearing by category and cause, shorten the roughly 18-month reporting lag, and extend the same monitoring rigour to non-woody vegetation, where clearing is running 13 per cent above the 2018–2024 average even as woody clearing runs 19 per cent below it (NSW DCCEEW, 2026a). The honest version of this argument helps our case rather than hurting it: woody clearing is genuinely declining, and saying so is what earns the right to be believed about the grasslands.

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NSW Department of Climate Change, Energy, the Environment and Water (NSW DCCEEW). (2026a). 2024 NSW vegetation clearing report (Statewide Landcover and Trees Study). Sydney: NSW Government. https://www.environment.nsw.gov.au

NSW Department of Climate Change, Energy, the Environment and Water (NSW DCCEEW). (2026b). Biodiversity Offsets Scheme reforms. Environment and Heritage. Sydney: NSW Government. https://www.environment.nsw.gov.au

NSW Department of Planning and Environment. (2023). Independent Review of the Biodiversity Conservation Act 2016: Final Report (Dr Ken Henry AC). Tabled 24 August 2023. Sydney: NSW Government. https://www.nsw.gov.au

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