Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Crown Lands Review Steering Committee
Catchments and Lands Division
Department of Primary Industries
PO Box 2185
Dangar NSW 2309
Dear Mr Carapiet
Travelling Stock Reserves and the Crown Lands Review
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 has a number of members in south eastern New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public. FOG has an ongoing interest in the conservation and management of our endangered native grassy ecosystems and over the years has visited a number of travelling stock reserves and routes (TSRs) with significant ecological diversity and habitat values.
FOG is writing to you as it understands that, following the February 2012 Report On The Review Of The NSW Livestock Health And Pest Authority (LHPA) Model prepared by Terry Ryan (Ryan Review) for the NSW Minister for Primary Industries, future management of TSRs is being considered as part of the Crown Lands Review. This follows on from FOG’s September and November 2011 submissions to the Review of the Livestock Health and Pest Authorities (LPHAs). The purpose of this letter is to:
- Draw to your attention the important public environmental benefits of TSRs that we believe should be taken into account in any decisions relating to their future;
- Express our concerns over the current uncertain future of TSRs as a result of the Ryan Review and our concerns about the adequacy of the Review’s analysis, findings and recommendations in accounting for their public environmental benefits; and
- Seek further information on the Local Land Services Scheme and Crown Lands Review processes that have emerged since and on how they tie into the future of TSRs in NSW.
Public Environmental Benefits of TSRs
TSRs currently provide and can continue to provide major public environmental benefits through their conservation of unique parts of NSW’s natural heritage. These benefits are also of national significance. This is in addition to other public benefits of TSRs, i.e. agricultural, ecosystems services, cultural, historical, and recreational.
It is well documented and well recognised that TSRs often contain the best examples and largest remaining repositories of native grasslands, grassy woodlands, and other grassy ecosystems that were once widespread across NSW rural landscapes. It is also well recognised that the variety, extent and condition of grassy ecosystems commonly found in TSRs are poorly represented in the formal NSW and national reserve systems. Many TSRs contain important remnants of NSW and Commonwealth listed threatened vegetation communities. In our region examples of these communities include Natural Temperate Grassland, Box-Gum Woodland, and Snow Gum Woodland. They also support many NSW and Commonwealth listed critically threatened native plant and animal species, such as the Grassland Earless Dragon (possibly the most threatened of Australia’s reptile species).
Another important role TSRs play is to create connectivity and habitat corridors across the landscape, forming a network that connects with stock routes and corridors in other States. These interstate connections are important for biodiversity and ecological health overall. The way in which the TSR network is managed will have effects well beyond NSW borders
Concerns with the Ryan Review
FOG’s principal concern relates to Recommendation 8 of the Ryan Review which states “Devolve management responsibility for all the public lands currently dedicated as travelling stock reserves and routes to the DPI Division of Catchments and Lands. The LHPA be required to make the public benefit case at the local level for the LHPA to retain management of any individual area of Crown Land for livestock purposes.”
The TSR network is a major public asset, comprising some 600,000 - 700,000 hectares in the eastern part of NSW and 1.7 million hectares in total including Western Division lands. FOG would have expected that comprehensive assessments of the various environmental and other (economic and social) values of TSRs using a multidisciplinary team would have been justified, not the least in recognition of and out of respect for the roles that TSRs have played since the early 1800s in preserving NSW’s natural and human heritage, and in their contribution to NSW’s (and Australia’s) economic and social development. The Ryan Review does not appear to acknowledge in full the historical significance and debt owed to the TSR network and its management agencies for the various public benefits they have provided.
Whether by design or accident, the environmental values of the TSR network are testimony to the effectiveness of the former Pasture Protection Board and Rural Lands Protection Board systems and the LHPA system in managing TSRs for agricultural purposes on behalf of rural landholders whilst simultaneously providing a range of other public benefits. However, we acknowledge that with any system of management there is always scope for ongoing improvement, and that the cost of maintaining TSRs has not been spread evenly across the community. In this regard, FOG was disappointed to see no suggestion in the Ryan review of the possibility of LHPAs receiving additional funding from a range of government and private sources to manage TSRs for their broader values to the NSW public. As well, there are a number of other mechanisms that could be used to protect and manage TSRs, including selling off sites subject to the application of ‘voluntary’ conservation covenants, retention of larger ones as nature reserves or addition to adjoining existing reserves, and encouraging Bush Heritage and other similar groups to buy them (and resell if that is their policy).
FOG is concerned that transfer of TSRs to the DPI Division of Catchments and Lands with possible retention by LPHAs has the potential to fragment further the TSR network and lead to further loss of corporate knowledge, management expertise and skills from the LHPA system. The Ryan Review has not suggested any safeguards and mechanisms to ensure that the environmental values and benefits of TSRs are maintained or enhanced during and after handover to the DPI. Conversely we are not aware of any NSW Government policy guidance on what will happen to TSRs that revert to the DPI, and are not aware of any Government guarantee that will prevent them being sold off. Break-up of the TSR network amongst a range of different users and owners is likely to irreversibly damage its environmental values and integrity, and will exacerbate threats to native biodiversity in NSW.
A further concern is with Travelling Stock Routes, rather than the Reserves themselves. These are wide corridors alongside roads, often many kilometres long and relatively narrow, but some may be as much as a kilometre wide in places. Many of these retain significant values which are often different from the fenced-in Reserves. Protection of these Route areas should be ensured where they have values such as very old trees, a particular cohort of species, or connectivity values.
Given that we believe that the public environmental benefits of high conservation value TSRs are of both State and national significance FOG is advocating that:
- There needs to be proper recognition of the very important ecological significance of many of the TSRs (reserves and routes), with conservation values obtained and documented either from existing surveys or by commissioning new work;
- Full consideration should be given of the different ways that could be applied to protect the areas, which would need to be worked out on a site by site basis;
- Management should be by a single, well-funded agency with proven rural land management expertise, conservation management expertise and retention of local on-ground staff. This is broadly in line with the Ryan Review Recommendation 11. Retention of TSRs under the management of the new Local Land Services may be appropriate, or some other arrangement whereby the expertise of the former regional LHPA staff would be retained for this purpose.
- Proper management plans based on sound conservation objectivities should be developed where these do not already exist, and implementation of those management plans should be adequately and continuously resourced. Consultation with stakeholders would be required to develop a consistent, state wide management framework for TSRs.
- Management should also include grazing regimes compatible with maintaining conservation of biodiversity, and integrated pest/weed management programs across tenures in partnership with other land managers.
- Conservation and management of TSRs needs to be broadened to protect and promote connectivity values and to include Travelling Stock Routes as well as the Reserves. As well, to maintain connectivity, safeguards need to be in place to ensure that the network is not fragmented between land management agencies, nor parts sold off. TSR managers should also work with managers of other non-TSR vegetation to ensure landscape connectivity is maintained and improved, for example, in relation to Council roadside reserves. Therefore local partnerships should be promoted, for example with the Office of Environment and Heritage, local Councils, Great Eastern Ranges, Slopes to Summit, and Kosciuszko to Coast.
Local Land Services and Crown Lands review
We are aware of the Local Lands Services restructure of DPI, CMAs and LHPAs, and the broader review of Crown Lands you are conducting. We would appreciate some more information on the Crown Lands Review process, particularly in relation to how it will assess, maintain and enhance the public environmental benefits of TSRs. Could FOG be advised of the timing and notification place of public consultation for the Crown Lands Review?
We look forward to your response to the above.
John Fitz Gerald
22 January 2013