Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Native Vegetation Framework Review Secretariat

Biodiversity Conservation Branch

Department of the Environment, Water, Heritage and the Arts

GPO Box 787





Dear Sir/Madam


Native Vegetation Framework Review


Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy (NTG) 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. While FOG focuses on only some of the ecosystems of concern under the Native Vegetation Framework, these ecosystems are some of the most disturbed in Australia, with less than 1% of lowland temperate grassland remaining. Within this context FOG would like to provide some comments on the Framework.


Overall, FOG supports the vision and goals of the Framework. However, while the Framework contains data on the different vegetation formations and acknowledges that some communities such as temperate grasslands and grassy woodlands have been badly affected by high levels of clearing in the past, it does not appear to contain any strategies specifically targeting these and other endangered, threatened and/or rapidly declining native vegetation communities.


In relation to goal 1, our concern is that setting a national target for all native vegetation types can obscure the picture for individual vegetation types. For example, reaching an overall target of a 10% increase in native vegetation will still represent a loss in our terms if there is a decrease in NTG ecosystems over the same period. FOG also supports the use of targets relating to increased connectivity of native ecosystems, as well as overall target increases.


Under goal 2, another objective could be added along the lines of “An increase in the extent and condition of endangered, threatened and/or rapidly declining native vegetation communities”.


The Australian government manages some areas of native vegetation (e.g. areas of NTG managed by the National Capital Authority in the ACT). For this reason, FOG believes that the Australian government should be listed in the “Responsibility” column in the table in 3.2 Actions, for actions 8, 9 and 13.


FOG notes both on page 24 of the Framework and in Action 13 that “Decision-making hierarchies should be applied to native vegetation management where the first aim is to avoid loss; and …. if vegetation loss is unavoidable, impacts should be managed to maintain ecosystem functions including, where feasible, the use of offsets.” In FOG’s view, given the parlous state of some vegetation types such as NTG ecosystems, offsets should be mandatory. As well, there needs to be overall agreement about what constitutes a reasonable offset. FOG advocates that an area be considered a suitable offset if it is “like for like”. For example, rehabilitation of a poor quality offset area cannot be considered a legitimate offset until such time as rehabilitation upgrades this area to a condition equal to or better than that of the lost area. The definition of an offset as “measures taken to compensate for proposals where the environmental impacts cannot be reduced adequately through avoidance or mitigation” in the Glossary is itself inadequate and should include reference to gains in the quality and quantity of native vegetation commensurate with the native vegetation lost, and also to tenure of the offset being secure and its future management ongoing.


Sincerely yours





Geoff Robertson



7 April 2010