Director General
Attention: Draft NSW Biodiversity Strategy 2010-2015 Comments
Department of Environment, Climate Change and Water
PO Box A290
Sydney South  NSW  1232
email: biodiversity.strategy@environment.nsw.gov.au

 

Dear Sir/Madam

 

Draft NSW Biodiversity Strategy 2010-2015

 

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 welcomes the draft NSW Biodiversity Strategy 2010-2015 and its signing off by two ministers, since we believe that biodiversity policy and programs should be on a whole-of-government basis. While FOG supports setting state-based objectives, we believe that there ought to be a strategy that aims to achieve a more nationally coordinated strategy that integrates biodiversity and other policies and addresses funding. FOG also supports setting regional objectives below the state-based objectives. FOG has been involved in Kosciuszko to Coast (K2C), one initiative established with a view to achieve the types of objectives articulated in the draft strategy. While there needs to be national and state-wide objectives, in most cases these can only be implemented at a regional level.

 

FOG supports many of the concepts and objectives of the strategy but considers that it needs strengthening in number of places. The comments below provide details of these views, by each section of the document.

 

Executive summary

 

We support the executive statement that “Biodiversity is important both for its intrinsic value and the ecosystem services it provides to society. Healthy ecosystems are critical to the wellbeing of current and future generations.” We agree that significant achievements have been made but ongoing work is required. We support the objectives that have been set out and the recognition that policy should be based on well-established science and that any ongoing framework needs to be a partnership between government, landowners, industry, government and the community.

 

However we believe that certain objectives are missing. These include:

• The ongoing resourcing of biodiversity management. It is disappointing that there is no commitment to or discussion on the ongoing funding of biodiversity work. Biodiversity programs have been subject to constant changes in direction and the quantum of funding available.
• The skilling and training of people who may be employed on biodiversity matters in industry, government and not for profit community groups, or who are self employed as landowners or in other capacities, conservation volunteers, and students.
• The recognition of the importance of Department of Environment, Climate Change and Water NSW (DECCW) in delivering programs, such as its skilled staff and generally client-friendly culture, and more generally the requirement to sustain the department in the longer term.
• The need for the NSW government to work with other jurisdictions to bring about a coherent framework for biodiversity across Australia and to avoid where possible duplication of effort and regulatory environment.
• A commitment to the ongoing support, in a practical sense, to the Greater Eastern Ranges Initiative, and the partnerships that make up that initiative, including K2C.
• The lack of a statement to deal with the future of travelling stock reserves, whose future remains in limbo.

Key concepts and Purpose of strategy

 

We agree with the emphasis on using a broad vegetation formation as part of the framework, and broadly support the stated purpose and the alignment with the national strategy.

 

Contributors to biodiversity in NSW

 

We support the emphasis in the statements here. In relation to the stated support of the Greater Eastern Ranges Initiative, we are disappointed that there is no mention in the strategy about how this support is to be made a reality on an ongoing basis, a particular concern as there are no plans for continuation of the Initiative after June 2011.

 

Aboriginal people and the environment

 

We support the statements made here, although they fall far short of what could be said. Those of us who have some inkling of understanding of Aboriginal culture realise that the sharing of this cultural heritage with the wider community will greatly add to our understanding of biodiversity and its management. That is, the involvement of Aboriginal communities in management of Country provides benefits to the whole community and not just the Aboriginal communities themselves.

 

Achievements and ongoing programs

 

As well as the substantial achievements listed, we believe that the list should also include the knowledge base and client-friendly culture that has been developed within the Department, since this needs to be sustained into the future.

 

Need for action

 

We generally agree with the statements made here. However, we believe that the list of threats to biodiversity should include the lack of knowledge of and commitment to biodiversity. A flow-on from this is the lack of integration of biodiversity outcomes with economic and social outcomes. While planning processes in NSW have improved, biodiversity constantly is being assaulted through lack of knowledge and political commitment.

 

Thinking beyond the local area

 

We support the statements made here and the reference to Great Eastern Ranges Initiative. However, as mentioned earlier, nothing in the strategy guarantees the continuation of this Initiative.

 

Importance of science

 

We believe that evidence-based science should underpin biodiversity management. However, for many management actions the science is yet to be established and therefore other principles and criteria may need to be brought into the equation. There are many examples we could quote here, but one might be the failure or slowness to list communities or species because insufficient is known them.

 

Smarter biodiversity investment

 

We agree that, with limited resources, smart choices need to be made. We agree with the general framework being developed and the targets and objectives but have several qualifications:

• There is no strategy about how to acquire the resources to achieve the outcomes mentioned. There cannot be smart investment in biodiversity if there are insufficient resources to fund the investment adequately.
• While there is an emphasis on state-wide strategies, most actions are achieved on a regional or local basis. There needs to be more thought given to how the framework is implemented region by region and locality by locality.
• We have been constantly faced by changes in government ‘fads’ which come and go. What is the guarantee that the current approach will be sustained?
• There is nothing in the strategy about how to build up the knowledge base amongst stakeholders that will made investments effective.
• The map on page 7 is difficult to read.

In relation to the particular objectives, we:

• Objective 1: - Support. There has been a growing acceptance of the need for direct public support of conservation on private land. This of course is already being done to some degree through existing programs which do give greater priority to more endangered vegetation formations.
• Objective 2: - Support. Obviously the conservation assets on public land need to be classified according to their value as determined by the framework and relatively greater effort needs to be given to managing rarer ecological communities. However, we are concerned that the future of travelling stock reserves continues to be left in limbo by this document, particularly as some of these reserves are important remnants of native grasslands and grassy woodlands. We are also concerned that there is nothing in the document about how conservation management is implemented. There should be a strong focus on having highly qualified bush management teams take on this task.
• Objective 3. Support in principle.
• Objective 4. Support in principle.
• Objective 5. Support in principle.
  • Market based instruments can be a useful tool but rely on there being good information and easy access to the market by those with conservation assets to offer.
  • Consideration should also be given to equity issues – too much emphasis is given to creating new biodiversity assets (revegetation) to the exclusion of good management of existing remnant vegetation.
  • In respect of biobanking, there is some criticism of this as a tool. There is also an argument that, for a range of different reasons, bartering biodiversity is not a successful strategy for long term conservation and “no net loss”.
  • In general, applications for grants under various schemes currently go through an assessment process in which bidders apply for funds. Such schemes work best when, for example, staff in CMAs seek out suitable applicants and assist them to prepare their applications.

Whole of landscape planning

• Objective 6. Support in principle. We have been committed to this concept and have practiced its implementation for many years now.

Improve partnerships

• Objective 7. Support.
  • We support formal agreements with Aboriginal organisations and increased employment of Aboriginal people. We would also support Aboriginal heritage programs that promote increased understanding of Aboriginal heritage among indigenous and non-indigenous programs. 
  • We also believe that understanding of Aboriginal heritage will greatly improve our understanding of biodiversity.
  • We strongly support the concept of partnerships such as the Great Eastern Ranges Initiatives and K2C. However, these initiatives need financial support now, and again the strategy is disappointing in that it doesn’t address this issue.
  • We suggest that working with other jurisdictions on biodiversity and conservation strategies would be of value. For example, research on threatened species conservation in one jurisdiction benefits all, and cross-border conservation corridors improve the conservation value of the areas in both jurisdictions. As well, there may be opportunities to integrate the each jurisdiction’s various biodiversity objectives and the funding of these.

Effectively managing threats

• Objective 8 – reserve and marine management. Support in principle. However we believe that a lot is unsaid about the practical realities of achieving this.
• Objective 9 – protect and restore aquatic systems. Support.
• Objective 10 - effectively manage and control threats through cooperative partnerships with key stakeholders. Support in principle. However the reality is that many threats continue to get worse and are beyond effective management.
  • There is also a need to be proactive as well as reactive, e.g. by identifying potentially invasive weeds (where it is possible to predict a plant’s likely invasiveness from its biology) and preventing their spread before they become a major problem. In this regard, we have suggested (under the recent review of the Noxious Weeds Act 1993) that there should be provision for public nominations of species to be listed as weeds to an independent scientific assessment committee, which would then recommend to the Minister whether or not the species should be proscribed. Weeds so listed should be put into categories such as:
    • eradicate – “incursion management”;
    • control – legal obligation on landowners to remove, banned from ownership and sale
    • contain – banned from sale or use by public authorities
    • in commercial use (e.g. olives, pinus) – with the onus on plantation owners to contain the species.

Sustainable production environments

• Objective 11. Support.

Measuring success

• We support measures that that would result in better monitoring and reporting. However we are concerned that this may add to the bureaucratic workload.

Other issues: impact of carbon sequestration projects on biodiversity

• FOG is concerned that carbon farming initiatives may have indirect negative impacts on grassy ecosystems if there is a financial incentive to plant trees to gain incentives for the sequestration of carbon in natural grasslands, which would be at the expense of the natural biodiversity. To the best of FOG’s knowledge, we do not know how much carbon is sequestered in different Australian ecosystems, and in ecosystems in different states of health, including native grasslands. Overseas research suggests that native grasslands are good for sequestration. FOG is also concerned that biochar and other interventions in solid management could impact negatively on native grasslands, both by direct disturbance and by changes in soil chemistry and hydrology.

 

Faithfully yours

 

 

 

Geoff Robertson

President

 

8 February 2011