The Energy Networks Association (ENA) thanks you for the extension of the
opportunity to comment on the Native Vegetation Framework (Consultation Draft)
ENA is the peak national body for Australia’s energy networks which provide the vital link
between gas and electricity producers and consumers. ENA represents gas distribution and
electricity network businesses on economic, technical and safety regulation and national
energy policy issues.
Energy network businesses deliver electricity and gas to over 13.5 million customers, employ
more than 40,000 people and contribute approximately 1.25 per cent to Australia's gross
domestic product. Energy is delivered across Australia through approximately 48,000 km of
transmission lines, 800,000 kilometres of electricity distribution lines and 81,000 kilometres of
gas distribution pipelines. Energy network businesses are valued at over $60 billion and
annually undertake an average investment of approximately $6 billion in network operations,
maintenance, reinforcement, expansions and greenfields extensions.
From the above it is probably evident that the maintenance and development of the
energy networks can and does impact on native vegetation and that this qualifies
ENA as a stakeholder.
The increasing demand for energy and urbanization of Australia necessitates the
expansion and augmentation of energy transmission and distribution networks with
consequent impacts on the environment.
In response to this and to climate change ENA have commissioned a report on
“Energy network infrastructure and the climate change challenge”. A key finding of
this study in relation to vegetation was:
It has been predicted that periods of seasonal rainfall, when they occur, are likely to
be more intense. Recent experience in Queensland and northern New South Wales
suggests that when this occurs in summer periods, and is immediately followed by
extended periods of heatwave conditions, vegetation growth rates can increase
substantially. This is particularly the case with some tree species in fertile soils. Tree
growth rates of up to 7.5 m per annum have been recorded for established seedlings.
It is normal business practice for overhead electricity transmission and distribution
networks to be regularly cleared to keep vegetation clear of exposed conductors.
Vegetation that is too close to overhead lines can cause electricity supply
interruptions by touching exposed conductors or by branches dislodging in high winds
and creating short circuits when blown onto lines.
ENA believes that vegetation management over the future periods is likely to become
a more significant issue in areas where rapid growth occurs. At other times, such as
during extended drought, a reduction in vegetation management activities will be
required. The variability in vegetation management costs will require additional
management attention and significant increases in vegetation management
expenditure may be required in some years.
These conclusions have been confirmed in recent times and the consequences have
been experienced in past bushfire seasons, particularly in Victoria and Western
Australia. ENA members are already working on reviewing and revising processes
and practices in anticipation of the findings of the Victorian Bushfire Royal
Commission and these will involve a range of vegetation management strategies.
The challenge for ENA members in the future will be to balance the outcomes in
terms of minimizing the potential for network infrastructure to start bushfires and
minimizing the impact of these activities on the environment, particularly flora and
fauna whilst maintaining the reliability of energy supply to all consumers at
reasonable cost.
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Similarly, our efforts will entail developing appropriate responses to other challenges
arising from climate change that will include changes to :

temperature

wind speed .

storm activity

rainfall levels and location

sea level.
To date our efforts in the area of land management has involved the development of
ENA National Land Management Guidelines.
These guidelines provide ENA members with suggested control measures,
references, considerations and performance indicators that should be considered as
part of good asset management. In developing these guidelines the need to ‘strike a
balance’ between the safe and reliable operation of energy networks and the need to
manage environmental impacts and stakeholder considerations was recognised.
While it is acknowledged that environmental jurisdictions vary from state to state, it is
intended that the industry wide Land Management Guidelines will provide members
with valuable tools for identifying, assessing and managing significant environmental
aspects associated with their activities. The risk associated with not managing these
aspects appropriately is significant for all network managers.
The Guidelines also include specific treatment of the topic of Vegetation
Management. We believe that vegetation management is necessary to ensure public
safety and reliability of electricity supply, mitigate fire risk and reduce asset damage.
In achieving this, the requirement for clearing of vegetation is to be reduced to a
minimum and impacts on sensitive and significant areas avoided. Careful
consultation with landowners and other stakeholders is an essential part of any
vegetation management program.
Impacts and Considerations in this area can include:
• Visual amenity
• Cultural heritage (Aboriginal & European)
• EMF
• Noise
• Electrical Safety
• Land tenure & Native Title
• EPBC and other Federal Legislation
• Wildlife – habitat and movement
• Waste Management
• Oil & PCB management
• Chemical usage
• other National & International Agreements
• Management of fire
In designing and planning network developments, ENA members need to consider
information from databases such as: EPBC database, relevant state databases,
Heritage listed trees, Cultural Heritage consideration, Main Roads database, Forestry
Departments, Commonwealth Land, National Parks and reserves or in other areas
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such as undisturbed bushland. As such we see benefit in the proposed development
of a national framework for native vegetation and recognise the value of a national
approach that provides a means of maximizing the sharing of data and information
whilst providing the necessary flexibility to address differences in terms of
jurisdictional, geographic, social and climatic aspects.
As such we support the statement that there is a strong need to improve national
coordination and consistency in managing and protecting native vegetation.
Goal 4, to “Build capacity to understand, value and effectively manage native
vegetation by all relevant stakeholders” is of greatest relevance to ENA members
and we particularly look forward to the outcomes of

an increase in the resourcing, design and implementation of
appropriate community awareness initiatives that align native vegetation, carbon
and water management issues.

an improvement in the national approach for native vegetation
mapping so that data from all jurisdictions is consistent, comparable and can be
incorporated into a national system through which native vegetation condition and
extent can be measured and reported at multiple scales, including nationally.
We fully support the notion that ecologically sustainable management of native
vegetation relies on informed action—in legislation and policy, through to on-ground
management by government, the private sector and the community.
We also agree that gaps in knowledge exist, as well as difficulties in managing
information to ensure that it is disseminated and applied effectively in on-ground
management. This issue can be addressed by collecting and compiling
comprehensive national datasets and see the value information that can embellish
GIS systems and other tools used by ENA members to manage the technical,
commercial and environmental aspects of networks.
ENA supports the views that:
1. long-term management and behavioural changes are needed to sustain
native vegetation and the many ecosystem services it supports.
2. specific outcomes and targets to help guide and identify our progress support
each goal.
3. a set of indicative actions must be included and that it be acknowledged that
as we progress, we may develop new actions to help achieve our vision.
4. the actions need to cover a range of native vegetation management
approaches, including:
 developing policy
 collecting and sharing information
 developing and implementing awareness and engagement strategies
 using market mechanisms and regulatory approaches.
5. the selection of locally relevant mechanisms by government and nongovernment players from the “tool box” should be based on risk assessment,
threat abatement needs and trend monitoring. Although specific actions and
delivery mechanisms may vary, it is important that they are aligned to
demonstrate progress towards the nationally agreed outcomes and targets.
From an ENA perspective there is much to be gained in terms of efficiency
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and responsiveness from consistency of requirements (eg. for access,
reporting, permits, etc.) across all government agencies, both State and
Federal, ranging from Defence to National Parks to Environmental Protection.
ENA supports the Actions as planned and outlined in Section 3.2 of the Consultation
Draft and are keen to assist in the implementation and ongoing development of the
framework. We believe we can offer our expertise in the areas of

Adopting route / site / configuration options and installation techniques
to minimise impacts - retention of vegetation may assist in reducing the visual
impacts of electrical infrastructure

Use of site specific options for reducing impacts on vegetation that
can include: higher overhead lines, use existing infrastructure corridors, altering
route selection, trident (compact) overhead construction, poles for transmission,
aerial stringing, landscaping, tree pruning to AS 4373, modify clearing techniques
and positioning of structures.

Planning rehabilitation work where this is required to be removed
during construction, but can be rehabilitated prior to commissioning. This work
can involve options to restore habitat / food source / corridors, where safety or
reliability is not compromised and to provide suitable habitat, food sources and
linkages for native wildlife movement across easements.

Fire Management that incorporates the management of the risk of the
infrastructure causing a fire and the risk of an outage due to burning of the
vegetation during management activities.
Thank you again for the opportunity to comment. Please do not hesitate to call me
should explanation or expansion of any point above be required.
Regards
Mark Amos
Director, Energy Infrastructure Policy
Energy Networks Association
W: www.ena.asn.au
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