National Vegetation Framework Review Secretariat
Biodiversity Conservation Branch
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
CANBERRA ACT 2601
By email: vegsubmissions@environment.gov.au
RE: Comments on Australia’s Native Vegetation Framework
Consultation Draft
I have been directed by the State Council of Wildlife Preservation Society of
Queensland (Wildlife Queensland) to provide comment on the draft
framework referred to above.
Wildlife Queensland is one of the most respected wildlife-focused conservation
groups in Queensland. With over 4000 supporters spread across regional
branches throughout Queensland, Wildlife Queensland is a strong voice for our
wildlife and its habitat.
Wildlife Queensland is apolitical. Our aims include;
Preserve the flora and fauna of Australia by all lawful means
Educate the community in an understanding of the principles of conservation and
preservation of the natural environment
Discourage by all legal means, the possible destruction, exploitation and
unnecessary development of any part of the natural environment.
Encourage rational land use and proper land planning of existing and future
development, and the use of the natural environment and its management.
W ildlife Queensland commends the Natural resource Management
Ministerial Council (NRMMC) for their efforts in developing and
endorsing a framework for the management of Australian native
vegetation.
General Comments
In broad terms the document is very readable and the goals and
principles laudable. Most commendable is the effort to involve
Indigenous peoples in the management of native vegetation.
W ildlife Queensland strongly support their involvement assumin g
the indigenous peoples are involved in discussing how they should
be involved and the targets they require to met their cultural
requirements. Indigenous peoples aspirations for management of
Wildlife Queensland: Australia’s Native Vegetation Framework(Consultation Draft)
their native vegetation may not necessarily align with that of the
post settlement community.
There is strong support for encouraging not for profit private
organizations acquiring and managing native vegetation to enhance
the environment and afford protection to our biodiversity. There is
the need for incentives not disincentives. W ildlife Queensland
believes such positive action for the envir onment needs to be
rewarded not penalized. In Queensland, organizations established
for this purpose and own land in freehold title are penalized with
land tax and those thousands of dollars can do much more to
enhance the environment than fill Treasury co ffers.
Unfortunately W ildlife Queensland is of the opinion that this
framework will have the same fate as that of many similar
frameworks and strategies developed at the national level with the
assistance and cooperation of other jurisdictions -a well writ ten
document that does not deliver its primary goals. Currently effective
management of native vegetation in Queensland, while there have
been significant advances in recent years, with the multiplicity of
legislation, the extensive range of exemptions and failure to deal
with connectivity and resilience adequately cannot be achieved.
For guidelines to work at a national level there must be comparable
legislation within the various jurisdictions, accepted standard
definitions so comparisons can be made wit h some degree of
confidence. W hen a definition for “marine plants” cannot be
achieved across state and territory borders it does not instill a large
degree of confidence. In addition connectivity across borders is
essential. Fauna that rely on native veget ation for habitat do not
recognize jurisdictional boundaries.
Finally W ildlife Queensland appreciates that this is a framework
document and traditionally not the place to discuss resource and
funding matters. However there needs to be an additional append ix
to indicate resource implications and funding required by the
various jurisdictions. W ithout that information the development of
realistic, measurable targets is a waste of time. W ildlife
Queensland will not be offering any comment on actions or targets
in view of the lack of such data.
Vision
In several instances in the consultation draft and in Goal 4, in
particular, the word “value” arises. W ildlife Queensland shares a
view that it is essential for at least stakeholders if not the
community as a who le to value native vegetation if enhanced
management is to be achieved. Such a concept should be clearly
reflected in the vision.
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Wildlife Queensland: Australia’s Native Vegetation Framework(Consultation Draft)
Suggest: “The vision of this framework is that native vegetation
across the Australian landscape is valued by stakeholders an d is
managed …..”
Goals
Page 23. Goal 1
2.3.1 Outcomes for Goal 1
The first dot point should be amended.
A net national increase from 2010 in native vegetation extent with
no loss of endangered or of concern regional ecosystems.
Dot point 2. Use o f offsets has to be in accordance with strict
guidelines that give a positive gain for native vegetation. The
concept of like for like and a ratio of 3 for 1 in extent must be the
minimum.
Page 24
Dot point 2 There is a need for more emphasis on this.
Governments alone can not achieve effective vegetation
management. Not for Profit organizations and landholders must
have incentives.
Dot point 4. Concerns about offsets already expressed. Offsets can
encourage development where development should never oc cur.
Dot point 6. use of fodder trees need a mention. Eg Mulga is used
year in year out by good managers and much more in drought
years. Managed appropriately mulga has the capacity to regenerate
to such an extent that inexperienced observers may conside r the y
are viewing pristine vegetation.
Page 25 Goal 2
Dot point 1 Essential in order to make valid comparisons.
Page 27 Goal 3
W ildlife Queensland strongly supports this concept but there is still
a large degree of uncertainty about what is to be acc redited.
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Wildlife Queensland: Australia’s Native Vegetation Framework(Consultation Draft)
Recent studies in the Queensland mulga lands by W itt et al(2009) 1*,
show the benefits of carbon sequestration and biodiversit y
restoration potential of the mulga lands based on exclosure studies
but what economical benefits can flow to land holder s is uncertain.
Page 28 Goal 4.
Strong support for this goal .
Dot point 2.
Unless there is a commitment to resources and
funding this outcome is questionable.
Dot point 3. Strongly supported. Scale must be a consideration.
Vegetation mapping is an extremely valuable tool but undoubtedly
in Queensland has caused most complaints and concerns from the
broader community. Vegetation mapping must be done at a scale
that fits the purpose. Continental scale mapping if applied at the
property level frequent ly is totally inappropriate.
Dot point 4 Perhaps landholders should be consulted to find out
what mechanisms will work for them.
Specific comments
There are only two issues.
Page 17. 1.2.1 Increasing threats. Key threats
Dot point 2. Feral animals n eed to be specified. Deer, rabbits,
donkeys, camels goats are all threats to native vegetation. The
inclusion of feral animals may be inferred but not specific.
Page 18. paragraph 5. “ business as usual “ is not working now and
biodiversity is on the decl ine. Check the draft of the draft of the
revised Biodiversity Strategy under review. A stronger statement is
required.
Conclusion
Thank you for the opportunity to comment. The document is a step
in the right direction but for it to be meaningful there is need to
address concerns raised. The greatest challenge is to achieve
1
Witt,G.B.,Noel,M.V.Bird,M.I.,Beeton, R.J.S. (2009)“Investigating long-term grazing exclosures for
the assessment of carbon sequestration and biodiversity restoration potential of the mulga lands”
University of Queensland, Australia.
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Wildlife Queensland: Australia’s Native Vegetation Framework(Consultation Draft)
comparable legislation and then an appropriate enforcement
program across all jurisdictions. Legislation does not have to be
uniform but to monitor progress like with like must be compa red.
Des Boyland, Policies & Campaign Manager
31 March 2010
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