Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Director General
Attention: Draft NSW Biodiversity Strategy 2010-2015 Comments
Department of Environment, Climate Change and Water
PO Box A290
Sydney South  NSW  1232


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:

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:

In relation to the particular objectives, we:

Whole of landscape planning

Improve partnerships

Effectively managing threats

Sustainable production environments

Measuring success

Other issues: impact of carbon sequestration projects on biodiversity


Faithfully yours




Geoff Robertson



8 February 2011