Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Pamela Mathie

Project Manager           

Office of the Commissioner for Sustainability and the Environment

PO Box 356



Dear Ms Mathie


I refer to your email to me of 10 April, in response to the Friends of Grasslands (FoG) submission to the Commissioner's grassland management inquiry of 25 January 2008 (which I submitted as the former FoG President).


Information answering your further questions is provided in the attachments.


If you require further clarification, please contact FoG again.


Yours sincerely






(Mr) Kim Pullen

Acting President

28 April 2008




1. A proposed Territory Plan mapped 'conservation layer' and 'connectivity layer'.


FoG suggested this most recently as a policy suggestion in response to the restructured Territory Plan consultation in 2007, and an extract from that response (of 1 June 2007 to ACTPLA) follows


'Across various of the land use zones ... the zone objectives provide for biodiversity conservation to some extent, including ecological function in at least one case.  FoG suggests that a 'conservation' overlay would be appropriate to identify habitats across the landscape in various zones - including all lands, whether public or private - that are recognised as valuable and/or managed for conservation, and seek to connect them.  Such connection improves the long term conservation outcomes for habitats and the species that use them.


FoG has already raised this matter in discussion with TaMS/PCLB (most recently in a meeting in March 2007).  Although FoG is advised that connectivity is covered at a policy level in the TP (perhaps a reference to the zone objectives), FoG's view is that an overlay would visually recognise significant values and should be unambiguous in its intent. 


This matter is appropriate for Flora and Fauna Committee consideration.  FoG suggests a two stage approach:

FoG notes that the 'Canberra spatial plan' refers to maintaining connectivity between nature reserves (at least), and also to wildlife corridors.


2. Proposed 'red lights' in approval protocols, i.e. no development/works should occur) for threatened species/communities (similar to the planning approvals approach in New South Wales).


Information on the NSW approach can be found on the web, e.g. at which includes the Environmental Outcomes Assessment Methodology [EOAM] under the legislation. The approach is complex, but essentially broadscale clearing ('clearing of any remnant native vegetation or protected regrowth') is not allowed unless such clearing will 'improve or maintain environmental outcomes'; for example, suggest you look at 2.1 and 2.2 (re 'improve or maintain'), 2.3 (offsets), and section 5 (biodiversity assessment, including 5.2.5 Threatened Ecological Communities). Please note also, re above, that the EOAM includes a way to value connectivity (see table 5.2).


The complete NSW Native Vegetation Act 2003 is at

and its regulations at


The EOAM uses 'BioMetric' a tool 'to assess losses of biodiversity from proposed clearing '. The 'red light' comment referred to the fact that 'clearing of native vegetation is not permitted in vegetation types or landscapes that are already overcleared or listed as threatened at the national, regional or landscape scales ...'.


3. References to the lack of 'ACT native vegetation legislation, as exists in other jurisdictions' and 'the principle of "no net loss" ... an important principle that ought to be considered, but use of any "offsetting" provisions preceded with cautiously'.


This refers to the fact that various Australian jurisdictions have enacted/updated native vegetation protection legislation in recent years including NSW (as above) and Victoria.


Regarding the NSW approach, FoG is concerned whether there is sufficient protection for threatened species provided in the EOAM approach.


For info about the approach in Vic, suggest you start with Victoria's Native Vegetation Management: a Framework for Action at and check out various aspects including 'habitat hectare' assessment and offset provisions.


Although the legislative approaches in other states may appear complex, this is the nature of native vegetation protection, and how others have gone about it, and the pitfalls (including practical and political) they've stumbled into/out of are worth considering. For example, in Qld it seems that the definition of vegetation does not included at least some types of grassland. It will be worth talking to relevant officers in other states to get a clear picture of the status of legislation, the reasoning behind approaches taken and, in some cases, evaluation of implementation.


FoG's caution about 'offsets' stems from the definition of 'no net loss'; as sometimes a 'gain' can be claimed for simply formally protecting and agreeing to manage an area of 'equivalent' vegetation - while the area subject to a proposal is lost or degraded by development. Any loss - where there are values of threatened species or threatened ecological communities at stake, at least - is loss.


4. NSW DECC led Southern Tablelands Grassy Ecosystems Conservation Management Network. I have also attached some information on the ST GE CMN provided by Mary Appleby, its Facilitator.