Director Conservation Incentives and Design Section Department of Sustainability, Environment, Water, Population and Communities GPO Box 787, Canberra ACT 2601 By email to wildlife.corridors@environment.gov.au 20 April 2012 Dear Madam or Sir, Submission on draft National Wildlife Corridors Plan The National Parks Association of NSW and the Nature Conservation Council of NSW strongly support the Australian Government’s focus on and commitment to supporting connectivity conservation initiatives in Australia, and applaud the work of the National Wildlife Corridors Plan Advisory Group in preparing this important document. We believe that wildlife corridors and other connectivity conservation projects are an important means of maintaining our internationally significant biodiversity. The National Parks Association of NSW (NPA) was formed in 1957 to promote the concept of a network of national parks in NSW under specialist national parks and wildlife legislation and managed by a professional agency. Today NPA continues to build on this work through a network of 18 branches and over 5,000 members and supporters. NPA is a strong advocate for the importance of the National Reserve System as a foundation for protecting and reestablishing connectivity in the Australian landscape. NPA also recognises the importance of other tenures and initiatives for connectivity conservation. In particular, NPA is a lead partner in the Great Eastern Ranges Initiative and also has a long-running campaign to protect the NSW Travelling Stock Route Network, which has extremely important connectivity values. NPA has also been involved in advocating for various linkages across the NSW landscape, including linking the escarpment to the north and south coasts of NSW, and linking Barrington Tops to the Warrumbungles along the Liverpool Range. The Nature Conservation Council of NSW (NCC) was founded in 1955, and is a non-profit, non-government organisation representing more than 100 community environment groups across NSW. It is the state’s peak environment organisation and has a strong reputation for leading effective action and influencing the direction of environment protection in NSW. NCC has longstanding interests and involvement in forest and species conservation, native vegetation management, land use planning and fire and biodiversity. NCC has been represented on the Environmental Trust steering subcommittee for the Great Eastern Ranges Initiative and has participated in the Linking Landscapes Collaboration. Our organisations welcome the opportunity to provide feedback on the draft National Wildlife Corridors Plan in the attached submission. Please do no hesitate to contact us for further information or clarification on any point raised in our submission. We look forward to NPA and NCC submission on the draft National Wildlife Corridors Plan Page 2 of 13 working with the Australian government and offering our continuing support and advice to progress connectivity conservation in Australia. Yours sincerely, Kevin Evans Chief Executive Officer National Parks Association of NSW Pepe Clarke Chief Executive Officer Nature Conservation Council of NSW 2 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 3 of 13 General comments on draft National Wildlife Corridors Plan The National Parks Association of NSW (NPA) and the Nature Conservation Council of NSW (NCC) support the Australian Government’s recognition of the importance of connectivity conservation, through their commitment to producing a National Wildlife Corridors Plan. We welcome the national scale of this project and the recognition of the importance of incorporating Indigenous land management and cultural values, and involving rural landholders in connectivity conservation. There are a number of ways in which we feel that the draft National Wildlife Corridors Plan (draft Plan) can be strengthened. Terminology We feel that the use of the term ‘wildlife corridors’, although useful for marketing and community engagement, doesn’t really capture the breadth of initiatives that make up connectivity conservation projects. The ‘corridor concept’ also does not emphasise the nonlinear nature of ecological connectivity and the need for a matrix of different land types to be managed to promote connectivity. Although we are not suggesting that the term ‘corridors’ be dropped completely, it would be useful for this plan, and subsequent discussion of it with the public, to place greater emphasis on the diverse, non-linear nature of connectivity conservation and to make greater use of the internationally accepted term ‘ecological connectivity’. Connectivity thinking beyond the Plan The draft plan provides an important start in thinking about connectivity conservation in Australia. Real, large-scale ecological connectivity, however, will not be achieved by relying purely on voluntary conservation projects and measures. Connectivity thinking and goals must be incorporated into the planning and actions of all levels of government and across all tenures. A number of recent incidents in NSW have highlighted the need for this broad adoption of connectivity thinking. The NSW Annual Report on Native Vegetation for 2009/2010 showed that this period was the worst year on record for clearing of native bushland. This report also showed that in the preceding 5 years, forestry has become the leading cause of clearing of woody vegetation, and the area cleared each year by forestry is rapidly increasing, reaching 42,700ha in 2009-20101. Clearly, land uses such as forestry have huge potential to disrupt connectivity and undermine the efforts made by community groups and the Australian government under this Plan, unless connectivity planning is integrated across all tenures and land managers. 1 NSW Office of Environment and Heritage, 2010. NSW Annual Report on Native Vegetation 2010, Table 5.1, p. 11 3 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 4 of 13 Similarly, the recently-released NSW Strategic Land Use Plans for the Upper Hunter and New England North West, which fail to provide clear, certain protection for important natural areas from mining and gas activities, highlight the potential for weak policies at the state level to undermine the goals of the draft National Wildlife Corridors Plan. It is essential that all levels of Government share the connectivity agenda laid out in this Plan, if the Plan is to succeed in keeping communities engaged and successfully protecting and restoring connectivity. As well as the actions recommended in the draft Plan, there are a range of additional actions and initiatives that would significantly enhance the outcomes of this plan for connectivity conservation. As discussed, there is a need for integration of connectivity planning at all levels of government. This could be facilitated by the Australian government, through the National Wildlife Corridors Council, developing resources and training for regional NRM groups and local councils to increase their knowledge of connectivity principles and how to implement these in their areas. It would also be extremely useful for the Australian government to provide community education programs about connectivity conservation, either directly or by funding NGOs or other appropriate groups to carry them out. These programs could inform participants about the importance of a resilient, connected landscape; the benefits that connectivity conservation projects have within and beyond the project area, through maintenance of ecosystem services etc.; and how they can be involved locally. The development of an integrated fire, pest and weed control program, involving all land managers, would benefit ecological connectivity as well as biodiversity generally, and would support the work being done in connectivity and corridor projects. (See further notes on fire management below.) Relationship between fire management and the draft Plan Fire management in relation to connectivity and corridor projects needs to incorporate both risk mitigation and biodiversity conservation elements. From a risk perspective, it is critical to engage with government fire fighting agencies to ensure that wildlife corridors are not located in areas that place human communities at risk from fire and require either intensive prescribed burning or mechanical treatment to mitigate the risk of bushfire. A representative from a fire fighting agency should be present on the National Wildlife Corridors Council. There should also be alignment with fire management plans and legislation. In NSW, for example, there should be alignment between local Bushfire Risk Management Plans and any proposed wildlife corridor. This is complicated by a lack of consistency in approach to fire management between states and territories in Australia. Section 1.8 of the draft Plan states that ‘Habitat areas that are in good condition are more resilient to disturbances such as wildlife and extreme weather events and provide anchors of connectivity within the landscape’. Conversely, implementing appropriate fire regimes results in more resilient ecosystems that are more readily able to adapt to the impacts of climate 4 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 5 of 13 change. Inappropriate fire regimes are generally those that occur too frequently or infrequently. In many areas of Australia, bushfire has been removed from the system due to habitat fragmentation and fire suppression by fire fighting agencies. This occurs both in remote areas and in areas adjacent to human communities. Fire management plans must therefore incorporate burning for ecological outcomes as well as risk mitigation to human communities. These plans must occur at the landscape scale and across tenures, focusing on mosaic burning and incorporating western science and Indigenous knowledge. While the listing of fire as a threat to biodiversity is not consistent between the states and territories, if the nomination to list ‘fire regimes that cause biodiversity decline’ as a Key Threatening Process under the EPBC Act is successful and a threat abatement plan is produced, it will be easier to consistently manage for fire and biodiversity in a national approach to wildlife corridors. Comments on Part 1: Why do we need a National Wildlife Corridors Plan? Section 1.7: Who will be involved? This section does not mention the importance of involving scientists and research institutions in the design of corridor and connectivity projects. This is a serious oversight. We believe that it is of paramount importance that best-practice science is involved in the development of all corridor projects, and this wording of this section of the draft Plan must reflect the integral role of science. The role of local governments in co-ordinating local, smaller-scale connectivity planning and projects should also be explicitly acknowledged in this section. Section 1.8: Foundation Stones National Reserve System, World Heritage Areas and Wetlands We strongly support the recognition of the National Reserve System (including Indigenous Protected Areas), World Heritage Areas and Wetlands of National and International Importance as vital ‘core areas’ for connectivity conservation in Australia. It should be noted in the plan that connectivity projects complement existing reserve acquisition and management programs. They do not remove the need to continue extending the national reserve system following the principles of comprehensiveness, adequacy and representativeness (CAR), particularly in bioregions that are currently underrepresented. It is important that connectivity thinking and planning is consistently integrated with state and Federal reserve acquisition and planning strategies. It is also critical that funds granted for corridor and connectivity initiatives are additional to existing funds for reserve acquisition and management, rather than being a redirection of this money. 5 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 6 of 13 Private Land Connectivity thinking needs to be built in to all levels of planning and land management as relating to private land conservation. Regional catchment and NRM plans need to contain explicit connectivity plans to help with allocation of funds and provision of assistance and advice to landholders. As previously discussed, provision of training and resources to staff in NRM and catchment groups as well as local councils (who are significant planning authorities) would be extremely useful in integrating connectivity thinking at all levels. Ecological and Cultural Pathways It is disappointing that a number of very important ecological pathways only get a cursory mention in this plan. These deserve further consideration in this section of the plan. Rivers and aquatic linkages Rivers and riparian corridors are mentioned, but more could be made of their importance and the opportunity they present for greatly increased landscape, habitat and ecological connectivity through protection of existing riparian vegetation and restoration of degraded areas. Riparian vegetation is particularly important because it maintains ecological processes such as healthy river flow, and provides migration pathways for a range of species. Even when dry, floodplain linkages from wetlands remain important corridors. River systems are also a good illustration of the fact that a purely vegetation-focussed approach to corridors is insufficient to ensure ecological connectivity. Connectivity initiatives need to be integrated with other areas such as water management. A clear example of this is in the Murray-Darling Basin, where vegetation conservation and restoration will not be enough to protect and restore connectivity unless the Murray-Darling Basing Plan is successful in returning sufficient water to ensure the health of the Basin’s ecosystems. Remnant vegetation outside the reserve system This section also makes little mention of the very significant network of remnant vegetation patches and corridors found outside of the reserve system, such as along travelling stock routes, roadsides, railways and in cemeteries. These remnants should receive more acknowledgement in the draft Plan. They are an extremely valuable resource, as they are often the only remnants of vegetation in otherwise highly cleared areas, but are unfortunately often in a precarious situation in terms of management. Having these areas well managed and preserved should be acknowledged in the Plan as a priority. These vegetation remnants provide an important skeleton in heavily cleared areas on which restoration, private land conservation and other connectivity conservation actions can build. In NSW, the Roadside Environment Committee (REC) does very useful work co6 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 7 of 13 ordinating and promoting improved management of roadsides, railways and other major stretches of land that are important to biodiversity. NCC is represented on this body, which is hosted by Roads and Maritime Services, and also includes representatives from state and local government, catchment management authorities, the rural fire service and other bodies. The REC provides a useful model for managing these areas, which could be adopted by other states. Later in this submission, we will present a case study of the NSW Travelling Stock Route and Reserve (TSR) Network, which comprises a significant part of this network of remnant vegetation. The TSR network clearly highlights both the imminent threats to these areas and the great opportunity they present. TSRs, like rivers, are also an important example of corridors of both ecological and cultural importance. Environmental gradients It would also be useful for the plan to acknowledge the importance of environmental gradients for ecological connectivity. Many natural linkages, including river and migration pathways, span strong environmental gradients (e.g. from temperate to semi-arid areas, or across the Great Eastern Ranges between the coast, highlands and western slopes). It is important that the value of capturing environmental gradients within connectivity programs is recognised. Comments on Part 2: Building a national network of wildlife corridors Wildlife Corridors Act Effectiveness of the legislation We support the concept of the Wildlife Corridors Act presented in the draft Plan. However, we question how effective it will be without some means of protecting the work done by corridor initiatives from future harm. Some form of land use regulation is required to ensure that, for example, restored or privately protected land isn’t subsequently developed or mined, and to ensure that Australia’s remnant native vegetation, the backbone of connectivity projects, doesn’t continue to suffer death by a thousand cuts. The Act should also stipulate that best available science should be explicitly required to define corridors. As discussed in previous sections of this submission, connectivity planning needs to be built into a wide range of Federal and State and Territory legislation and strategies relating to issues such as management of native vegetation and land use planning. The degree to which this integration occurs will have significant impact on the effectiveness of the Wildlife Corridors Act. It would be extremely unfortunate for a project with significant state and federal investment to be compromised as a result of inadequate legislation to protect it from likely threats such as mining and gas exploration and extraction. Situations like this would 7 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 8 of 13 undermine community confidence and discourage future engagement in corridor and connectivity projects. The Australian Government needs an active strategy to encourage states and territories to adopt the National Wildlife Corridors Plan, and connectivity thinking more generally, in a widespread way. The implementation of this Plan should be put urgently on the agenda of the Council of Australian Governments. Community engagement in corridor nomination A clear process for the community-led nomination of National Wildlife Corridors should be included in the proposed Wildlife Corridors Act and any subsequent supporting state legislation. Criteria for listing a corridor and a timeline for assessment of community nominations should be developed and promoted to community groups as a matter of priority, through workshops across regional and metropolitan areas explaining the nomination process. To facilitate community engagement with National Wildlife Corridors, support should be provided for community nominations through workshops across regional and metropolitan areas explaining the nomination process. These workshops will also provide an opportunity to engage the community with the concept of a National Wildlife Corridor list, and thus mitigate the risk of this being seen as a top-down imposition rather than a community opportunity. Incorporating connectivity into the EPBC Act We appreciate that it may not be possible at this stage to incorporate the key concepts of ecological connectivity and connectivity conservation into the Environment Protection and Biodiversity Conservation Act 1999. However, the draft National Wildlife Corridors Plan provides an important opportunity to provide clear definitions of terms, and suggest mechanisms for the incorporation of connectivity concepts into the EPBC Act, to facilitate this occurring at a later date. Developing and supporting existing major and prospective corridor initiatives We support the identification in the draft plan of the Great Eastern Ranges (GER) as an existing major corridor initiative for priority consideration. The draft Plan incorrectly describes GER as operating only in NSW. It should be altered to indicate that GER spans multiple states, operating in NSW, the ACT, Victoria and Queensland through its partnerships and affiliates. For this reason, we also feel that the inclusion of the prospective Noosa to Ballina corridor in the plan is unnecessary, as this is part of the existing GER corridor and one of the GER regional partnerships, the Border Ranges Alliance, is named as being a part of it. We also propose that the Travelling Stock Routes and Reserves (TSR) network should be identified as an additional existing major corridor. As discussed in more detail below, the TSR network presents both a great need and a very important opportunity for connectivity conservation in Australia. 8 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 9 of 13 Strategic investment It is good to see the draft Plan notes that recognised existing corridor projects will be supported. We would like to emphasise that connectivity initiatives are necessarily long-term projects, due to the long time scales over which ecological processes operate, and require long-term financial support. Without a commitment to continued, long-term support funding of major projects, they may not be sustainable and therefore won’t achieve the desired outcomes. Initial investment in a project will only be worthwhile if the project is able to persist beyond the first few years. It will be important to link a wide range of appropriate funding grants of various scales to the Plan by providing a ‘connectivity and corridors’ theme across a range of grants. It is also important that the Australian Government provides additional resources and training to aid applicants (especially from smaller community groups) in their submissions. The process of grant application often proves an intimidating and complex barrier to potential applicants, and unless applicants are well supported, there may not be broad community engagement with this Plan. Working with stakeholders and supporting NRM regional planning We support the idea that corridor development should be embedded in regional NRM planning, as discussed above, although this should encompass a broader understanding of connectivity than simply creating corridors. Funding should not only be directed at the level of regional NRM groups – many of the bigger corridor initiatives are at a larger scale and involve very broad collaboration. In these cases, money is best invested directly through this collaborative framework. Although we agree that Australian Government should “support access to information on corridors design and planning through the Department of Sustainability, Environment, Water, Population and Communities website and other publications”, they should go further than this in providing practical training in connectivity conservation and planning to councils, NRM groups, community groups and others, either directly or by funding appropriate groups to carry out this training and education. Monitoring, evaluation and reporting We strongly support the draft Plan’s recognition of the importance of monitoring, evaluation and reporting (MER). This should not only occur at high levels within government – it needs to occur at all levels and involve all stakeholders. To facilitate this, simple, consistent tools and training need to be developed to allow people at all levels to be involved in MER for connectivity conservation projects. These tools could build on existing resources like the Atlas of Living Australia, which already has a strong relationship with GER and its lead partners. Many community groups, including NPA, have some form of biodiversity survey programs, which may also be an important resource for MER at community levels. 9 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 10 of 13 Comments on Appendix B: Potential National Wildlife Corridors Travelling Stock Routes and Reserves – an additional potential National Wildlife Corridor As discussed above, there is a considerable amount of remnant vegetation that has persisted, essentially accidentally, in various parts of the country, in areas such as stock routes, roadsides, railway corridors and cemeteries. There is both great need and great opportunity associated with remnant vegetation of this type, which should be recognised in any connectivity conservation strategy for Australia Travelling Stock Routes and Reserves (TSRs) in NSW provide an illustration of the pressing need for action to protect these networks, which face growing pressures and are likely to be lost if action isn’t taken soon. The TSR Network also presents an extremely rich opportunity to further connectivity conservation in Australia, and for this reason we propose that this network should be recognised in the plan as an additional Potential National Wildlife Corridor. Introduction to TSRs The travelling stock route and reserves network (TSR network) in New South Wales is an extensive network of public land that was established for droving of sheep and cattle during early European colonisation, often along traditional Aboriginal pathways through the landscape. Due to their management history and retention in public ownership, TSRs have preserved much of their original vegetation. Although the main purpose of the TSR network was originally for droving stock across the countryside, the network is now recognised for its environmental, economic, cultural and social importance. In particular, TSRs form a network of corridors (stock routes) and stepping-stones (stock reserves) of remnant vegetation across the heavily-cleared wheat and sheep belt in central NSW. Queensland has a similarly extensive network of travelling stock routes, and the combined TSR networks of NSW and Queensland, if effectively managed, have the potential to be a globally unique, continental-scale network of publicly owned remnant vegetation, of great importance for connectivity conservation. TSRs- the need In central and eastern NSW, the majority of travelling stock routes are currently managed by Livestock Health and Pest Authorities (LHPAs), which also have major biosecurity responsibilities. There has been a series of reviews of these Authorities over the last few years. The most recent of these, completed in April 2012, has recommended that management of TSRs be devolved from the LHPAs to the Crown, unless the LHPAs make 10 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 11 of 13 strong business case to retain them2. This is similar to the recommendations of a previous (2008) review, which met extreme community concern that this action might lead to the ultimate sell-off and break-up of the network. At a 2011 conference on Travelling Stock Routes that was convened by NPA, a wide range of stakeholders including representatives from federal and state government departments and agencies, recreational user groups, Aboriginal groups, conservation groups and scientific institutions agreed on five key requirements for management of the Travelling Stock Routes Network. These were: 1. An authority with oversight of TSRs that has stable and adequate resourcing for the task. This could build on existing institutional arrangements such as the LHPAs. 2. Accessible data, providing more information than is currently available and in a more coordinated and streamlined format. 3. Representative management that brings together the various values and interests and facilitates networking and information sharing. 4. Educational programs to raise awareness of the wide importance of TSRs and their permitted uses, and help recognise and protect their Aboriginal and droving cultural heritage. 5. An assessment of the economic significance of TSRs using a framework (such as Total Economic Value) that incorporates their full range of economic, social, cultural and environmental values3. We have significant concern that current review is again posing the threat that network will be broken up amongst a range of land managers, leading to inconsistent management and loss of public access, and ultimately that sections of the network may be sold altogether. Break up of the network, either in terms of management or physically, by sale and clearing, would severely diminish its connectivity value. The recommendations of the review were based on the fact that TSRs are now more valuable for their environmental, cultural and social attributes than for their economic benefit to the LHPA ratepayers who currently support them. There is general agreement amongst stakeholders that LHPA ratepayers shouldn’t have to support them financially when they provide such an important range of public benefits, including connectivity, but there is a serious question of where other, consistent funding can be obtained to support them, recognizing their many values. There is considerable time pressure to secure alternative funding as soon as possible, before network is broken up too much. 2 Ryan T, 2012. Report on the Review of the NSW Livestock Health and Pest Authority (LHPA) Model. A review commissioned by the Minister for Primary Industries. 3 NPA NSW (2011) NSW Travelling Stock Routes and Reserves Conference, 28 th July, 2011. Discussion group priorities and proceedings. Available from http://www.npansw.org.au/index.php?option=com_content&view=article&id=728:the-2011-nsw-travellingstock-routes-and-reserves-conference&catid=101:travelling-stock-routes&Itemid=461#Discussion 11 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 12 of 13 TSRs- the opportunity Listing the TSR network in NSW (ideally in conjunction with the Stock Route Network in Queensland) as a potential National Wildlife Corridor would help to prioritise the TSR network for Australian government funding. This would be an important source of support for the preservation of the network. Although criteria were not provided in plan for establishing ‘nationally significant corridors’, the TSR network ties in extremely well with the six key objectives stated in the Plan. 1. Protect, maintain and restore native habitats and ecosystems, and their critical processes and functions TSRs preserve remnant vegetation adapted to the fertile soils of valley floors and other agricultural areas, which there are few, if any, national parks. For this reason, they play an important role, complementary to the National Reserve system, in protecting native habitats and ecosystems. TSRs are known to be a vital refuge for the declining native birds of NSW. TSRs often contain remnant old trees, and are thus extremely important to a range of hollow-dependent fauna species. TSRs protect a range of threatened flora and fauna species, including at least 9 endangered or critically endangered ecological communities, at least 14 endangered and vulnerable flora species and at least 9 endangered or vulnerable fauna species. 2. Protect natural stores of carbon in native ecosystems to minimise greenhouse gas emissions TSRs are particularly important for carbon sequestration, as they contain natural stores of carbon in their remnant vegetation. This vegetation currently needs stronger protection from clearing, for example through sale and subsequent agricultural clearing, extensive timber harvesting or clearing for mining infrastructure or exploration. 3. Enhance the resilience of Australia’s biodiversity and its adaptability to climate change Corridors and climate change TSRs may be particularly important for climate change mitigation and resilience building, because they form both an east-west and north-south network. The TSR network also ties in with other connectivity projects. In particular, some TSRs fall within GER corridor, and others provide a “ladder” extending west from the GER area. 4. Support the global and national movements of fauna: TSRs are know to be important for some migratory fauna, including the Regent Honeyeater (listed as endangered under the EPBC Act). Many TSRs run along rivers, which are particularly important corridors for migration of species. In conjunction with network of stock routes in Queensland, TSRs provide a unique, continental-scale network of corridors and stepping stones. 12 NPA and NCC submission on the draft National Wildlife Corridors Plan Page 13 of 13 5. Assist in the management and protection of Australia’s iconic landscapes and Indigenous and non-Indigenous culture and heritage. TSRs are extremely iconic and culturally significant. Some TSRs in NSW are now the focus of cultural tourism programs. Many TSRs are thought to have followed traditional Indigenous travel lines through the landscape, and many are still significant to Aboriginal groups today. (This was reflected by the Aboriginal groups represented at the 2011 TSR conference.) TSRs also have rich non-Indigenous culture and heritage, expressed through a wide range of historical and modern songs, stories, art and folklore about the droving life and the stock routes. 6. Increase community knowledge and understanding of wildlife corridors and connectivity conservation: TSRs have a great capacity to engage people on the community level, as reflected by the wide range of groups represented at the 2011 TSR conference. TSRs have a wide range of sustainable recreational uses (e.g. angling, bird watching) which means that a broad cross-section of the NSW community is engaged with and concerned about the network In some cases, community groups are involved with the management of local TSRs. Through this involvement at the local scale, there is potential for people to be introduced to concepts of connectivity on a larger scale. The TSR network also makes an excellent focal point for communicating messages about connectivity and corridors to the wider public. In NPA’s experience, it is a tangible example of connectivity that people really connect with and understand. NPA’s detailed document about the TSR Network (‘The NSW travelling stock routes and reserves network: Heritage – habitat – livelihood’) is attached as supporting documentation to this submission. NPA would be happy to provide draft text describing the TSR network for inclusion in the plan as the 11th proposed National Wildlife corridor, if desired. 13