Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
phone: 02 62. . . . . . or 62 . . . . . .
Landscapes and Ecosystems Conservation Branch
Department of Environment, Climate Change and Water
PO Box A290
SYDNEY SOUTH NSW 1232
Dear Mr Grosskopf
NSW Native Vegetation Act 2003 review
Friends of Grasslands (FOG) considers that the objectives of the Native Vegetation Act are still highly valid (question 1). Protecting and restoring the viability and conservation values of native vegetation is a long term task, particularly in the case of native grasslands which have undergone extensive clearance and degradation. The added impact of climate change places areas of high conservation native vegetation further at risk.
In response to question 3, FOG suggests adding to the Act an additional objective: to build ecosystem resilience. While the exact magnitude and pace of climate change impacts is unknown, it is clear that impacts will be profound. Native ecosystems will need to be resilient to survive these impacts without the loss of many species and ecosystems. Such resilience might be able to be achieved by improving the extent and connectivity of existing remnant patches as well as their condition; through regional planning that allows for movement of plants and animals across environmental gradients; and through addressing stressors on native vegetation such as altered fire regimes and invasion by weeds and pests.
In response to question 4, FOG considers that urban areas should be included under the Act. Protection and restoration of native vegetation within urban areas is just as pressing as that on rural land, perhaps more so as vegetation in the close vicinity of urban areas is usually subject to relatively high levels of disturbance. Urban expansion should be planned to conserve and enhance the remaining native vegetation of a greenfield area. This is currently not the case, and many of our most threatened vegetation communities and vulnerable species are at risk from urban expansion.
As well, exemptions for driveways, fences and house sites should not apply to new rural residential developments (question 5). The exemptions allow for agricultural activity but should not be applicable to large suburban blocks (which is what many rural residential have become). Where block sizes are less than 10ha, rural exemptions can be used to virtually destroy all native vegetation on the site.
Enforcement has correctly been directed towards addressing illegal clearing (question 8). However the long term success of incentive and offset measures will require active auditing and compliance enforcement. There should be a stated target that at least 10% of all incentive and offset agreements will be audited each year and that this auditing will involve site inspection. The level of auditing and inspection of incentive and offset areas is not reported in the review and the experience of FOG is that the compliance resources that have been dedicated to this task are below what is required.
In cases where some native vegetation is cleared for infrastructure development (such as gas pipelines and electricity infrastructure) but the area is to be rehabilitated following project completion, mitigation and rehabilitation requirements should be included in project contracts. In addition, contracts should contain a requirement for a 10 or 20 year bond which could be used to cover government expenses in rectifying any weed problems that occur in high quality native vegetation areas post-construction, or returned to the developer at the expiration of the bond period if rehabilitation is satisfactory.
FOG is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and other on-ground work. FOG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.
22 September 2009