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Accredited assessor compliance audit



The department conducted a compliance audit of accredited assessors as part of our commitment to continuous improvement and providing assurance during 2020–21.

Audits are carried out under the Biodiversity Conservation Act 2016 (NSW) in accordance with section 20 of the Accreditation Scheme for the Application of the Biodiversity Assessment Method Order 2017 (Accreditation Scheme Order 2017), which allows auditing of: 

  • compliance by an accredited person with the conditions of their accreditation
  • biodiversity assessment reports prepared by an accredited person
  • the application of the Biodiversity Assessment Method by an accredited person.

View the 

Read the compliance audit report

Audit objectives and scope 

Audits are one of the tools used to ensure assessment quality. This audit is one of a range of measures under the Biodiversity Offsets Scheme that provide an overall framework to manage quality and assurance of assessments undertaken by accredited assessors.

The focus of the audit was Biodiversity Development Assessment Reports (BDAR) undertaken by accredited assessors in relation to council development applications under Part 4 of the Environmental Planning and Assessment Act 1979 (NSW). 

These types of assessments are the most frequently undertaken in the scheme, giving the department a rich source of information to consider in the audit. 

Given the scheme had been in operation for less than 3 years when the audit commenced in February 2020, the department sought to assess compliance and identify opportunities for education and ongoing scheme improvement and areas to target for future audits. 

The objectives of the audit were to:

  • evaluate accredited assessor compliance with select accreditation conditions, including applying aspects of the Biodiversity Assessment Method
  • support accredited assessors to comply and deter non-compliance, to improve biodiversity assessment and report quality
  • gather strategic intelligence to assist the department to better understand the practical operation of this area of the scheme.

The audit scope included the review of selected accreditation conditions and sections of the Biodiversity Conservation Act:

  • selected accreditation conditions
    • application of the Biodiversity Assessment Method and operational manuals
    • code of conduct
    • record keeping
  • relevant sections of the Biodiversity Conservation Act  
    • accredited assessor qualifications and experience and BDAR team details (s 6.8)
    • BDAR certification and currency requirements (s 6.15).

Audit findings

At the commencement of the audit in February 2020, there were:

  • 370 accredited assessors on the public register
  • 297 accredited assessors within a private consultancy (ecological or other) 
  • 73 accredited assessors within government agencies (state government, local government or other government departments).

A representative sample of BDARs was selected for the audit. To be eligible for selection, BDARs had to be certified by an accredited assessor and submitted to the council but not yet determined. 

A total of 13 BDARs from the same number of accredited assessors were formally audited. The BDARs used in the audit were:

  • typically assessing small (less than 5 hectares) development sites
  • undertaken by accredited assessors new to the scheme, usually in small teams of 2 or more assessors. 

The department considers these arrangements to be common.

The audit identified a range of non-compliance issues in each of the audited BDARs as developed by the accredited assessors. Key areas of improvement identified from the audit included:

  • BDAR currency and ensuring Biodiversity Assessment Method Calculator (BAM-C) is finalised (that is, saved as read only) before submission 
  • quality assurance, particularly consistency between BDAR/BAM-C data and technical review of BDAR content (minimum Biodiversity Assessment Method requirements)
  • inclusion of information on the entry point into the Biodiversity Offsets Scheme 
  • consistent application of the Biodiversity Assessment Method and use of systems such as the Biodiversity Offsets and Agreements Management System and BAM-C 
  • adequate proposal details, including detailed site plans showing area of on-ground impact (construction and operational) consistent with development application documentation
  • adequate justification for outcomes of steps undertaken to assess threatened species in accordance with the Biodiversity Assessment Method and detailed targeted survey information for threatened species assessments
  • demonstration of adequate consideration of avoidance (including mapped avoided areas), indirect impacts, and impacts to threatened species recorded on site and their habitats.

Audit recommendations 

The audit identified 32 recommendations centred around 6 key recommendation themes:

  1. audited BDARs and accredited assessor non-compliances
  2. Biodiversity Assessment Method 
  3. systems and processes
  4. accredited assessors support
  5. complaints and feedback management
  6. local government support.

The preliminary audit findings and feedback from key stakeholders were considered while the audit was still in progress. At the completion of the audit, of the 32 recommendations, 12 had been implemented, 14 had been partially implemented, and 6 had commenced. 

Response to the audit 

The department is implementing the outcomes of the audit and considering additional measures to improve the scheme, including:

  1. a specific audit program for the scheme to uncover systemic quality or integrity issues within the work undertaken by the accredited assessors
  2. robust and fair processes for assessor compliance, including formalising a fair and transparent process for removing accreditation based on evidence and formal review
  3. potential establishment of a dedicated audit team to conduct further auditing under the plan and take follow-up action.

This will complement existing work already underway to improve quality, including enhanced training, guidelines and templates.