Friends of Grasslands

supporting native grassy ecosystems

PO Box 987

Civic Square ACT 2608

Threatened Species Conservation Regulation Review
Conservation Policy and Strategy Section
Department of Environment, Climate Change and Water
PO Box A290
South Sydney NSW 1232
tscregulation.review@environment.nsw.gov

Dear Sir/Madam

Threatened Species Conservation Regulation

Friends of Grasslands (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.

In the Regulatory Impact Statement three options are canvassed for the staged repeal of the Threatened Species Conservation Regulation 2002. Option 1 is not acceptable to FOG, as no additional species could be listed as threatened. While it is preferable that no further listings would be needed, the reality is that biodiversity continues to decline and unfortunately further listings will need the be made in the future.

FOG also does not support option 3 adopting the Environment Protection and Biodiversity Conservation Regulation 2000 listing criteria, particularly as these criteria do not require consideration of whether the limited geographic distribution of a species makes it vulnerable to the effects of human activities. With the grassy ecosystems of south-eastern New South Wales and the vulnerable species that live within them, human impact on their limited distribution is of major concern and is continuing to impact on them. A case in point is the proposed Murrumbidgee to Googong water transfer project, which has the potential to impact on Swainsona recta habitat. Without listing as an endangered species which has resulted in design and mitigation measures to minimise the impact on Swainsona recta habitat along the pipeline route, further populations of this species might have been lost after commencement of this project.

FOG supports option 2, i.e. that this regulation be remade as Threatened Species Conservation Regulation 2010, and also supports the draft 2010 Regulation. While recognizing that option 2 may lead to higher costs for both government and property owners, FOG considers this the best option to aid in protection of all of our threatened species and ecosystems. From a grassland perspective, loss and fragmentation of species and ecosystems continues, but at a slower rate than it would without such legislation. It is important that the legislation be as complete and as protective as possible, an aim that is best met by option 2.

Sincerely yours

Geoff Robertson

President

28 June 2010