Environmental Defenders Office (EDO) welcomes the opportunity to comment on the Exposure
draft of the National Environmental Standard for Environmental Offsets (Exposure Offsets
Standard) and accompanying Updated Draft Policy Position Paper: National Environmental
Standard for Environmental Offsets (Offsets Policy Paper).

The Exposure Offsets Standard is intended to be made a National Environmental Standard under new provisions in the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act).

EDO remains concerned that the Exposure Offsets Standard, and broader offsets framework under
the reformed EPBC Act, lacks integrity and will not lead to improved environmental outcomes. It
will simply allow ‘business-as-usual’ to continue under the guise of compensating for impacts. In
doing so it will further entrench environmental decline.