Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Paul Nicholls

Lachlan CMA

PO Box 726

Forbes NSW 2871




Dear Paul


Policy for management techniques – Clause 28 of the Native Vegetation Regulation 2005


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.


FOG has concerns with the above policy for the following reasons:


1.      Any disturbance to the soil, including addition of fertiliser and ploughing is very likely to result in an increase in the weed germination in a site, and the reduction in competitive ability of native herbaceous species, likely to reduce the native diversity over time.


2.      FOG notes that the policy relates to groundcover that is below 90% of benchmark native species richness for the vegetation type, and that up to 500 ha can be cleared. In FOG’s view, the 90% benchmark is far too high. There are a number of high quality conservation areas, some containing endangered or vulnerable species, that for a month or two of the year would fall below such a benchmark but are still of high enough quality to be worth conserving and maintaining as native grasslands.


3.      It is very difficult to identify accurately native and exotic herbaceous species. Some native and exotic species are difficult to tell apart (except at particular times of year), and mistakes in identification may result in an area being cleared although it is above the threshold.


4.      Many grassland sites are variable in species abundance and diversity across the landscape. Within an area of 500 ha it is extremely likely that some areas will be lower, some higher and some areas at the benchmark. This variability needs to be taken into account in determining the amount to be cleared.


FOG recognises that the policy to plant into native pasture without destroying the native component has its merits. However, it recommends that a significantly lower benchmark, for example 50%, be used.


Sincerely yours




Naarilla Hirsch

for Geoff Robertson



9 November 2009