6 April 2010
Native Vegetation Review Secretariat
Biodiversity Conservation Branch
Dept Environment, Water, Heritage and the Arts
Canberra ACT 2601
Dear Secretariat
Re: Submission on Australia’s Native Vegetation Framework
Consultation draft February 2010
Thank you for extending the deadline for this Framework from 31 March to 7 April. This
submission replaces my somewhat scrappy submission, due to illness, of 31 March. This
submission is somewhat more considered than my previous submission, but I wish to submit
something rather than nothing.
Since childhood, I have had a long-standing interest in the natural environment, wherever my life
and travels have taken me—the English countryside, Europe, Middle East, Afghanistan,
Pakistan, India, New Zealand, USA, Africa, Nepal, Cyprus, and the Australian landscape. Since
retirement, I have become a conservation volunteer. So it is with much interest, enthusiasm and
concern that I comment on this important Framework for improved outcomes for Australia’s
native vegetation, and the wildlife that depends upon it.
In my view, if Australia is to remain habitable for people, plants and animals, then the key
factors to address are: (1) climate change, (2) population pressure and lifestyle, and (3)
biodiversity loss. I have numbered paragraphs for ease of reference.
General Comments
1. Climate change. Regarding threats from climate change, temperatures are rising faster than
species can adapt. This Framework states that a global temperature rise of 1.5 - 2oC is likely
to lead to massive biodiversity loss with extinctions here and globally. At a current 1.3oC
increase, wildfires have become more frequent and intense, and climate zones worldwide
have already shifted and will continue to do so with continued warming that will cause
further collapse of ecosystems and species extinctions. So global warming must somehow be
kept below 2 oC. Therefore, to support the native vegetation conservation intent of this
Framework it must contain an action/s for governments and the community to mitigate causal
factors of global warming that are far more effective and stringent than those already set.
2. Regarding wildfires, which seem to be increasing in frequency and intensity with climate
change, rather than removing native vegetation to protect dwellings and people against
wildfires, dwellings should cease to be built in wildfire zones. I support the calls for
governments at all levels to buy back land in wildfire zones. These wildfire zones could then
act as carbon sequestration and be allowed to regenerate along with weed management.
3. Suggest this Framework states that canopy trees and water bodies have an important cooling
effect that mitigates global warming.
4. The term ‘climate’ is loosely used in a variety of ways; it can mean political climate.
Suggest that, to avoid ambiguity, reference to climate change in this Framework could be
more clearly defined as, say ‘physical or atmospheric climate change’.
5. Population. Overpopulation is a worldwide problem. The population of Australia must be
stabilised now. At 22.5 million, we are already living beyond the capacity of this hot and dry
country to support our existing population, without any further increase. Our native
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vegetation and wildlife habitat is being decimated from population growth alone. To
promote high population in this land seems completely foolish and irresponsible.
6. In Melbourne, the population growth and expansion is crazy—covering up fertile land;
removing bush, grasslands and wetlands; displacing wildlife; pushing dwellings into wildfire
zones; increasing road congestion, vehicle travel times, and food miles; increasing
greenhouse gases—it’s unsustainable. And this situation is being replicated in other
Australian cities.
7. The Australian mindset is consumed with growth—any growth—but it comes with a huge
cost to our climate, environment, and quality of life. Some European cities maintain a stable
population and modest but civilised lifestyle yet still thrive. Surely, some limits to the
growth fetish here can be set, and all levels of Australian government take responsible action.
8. Belatedly, a Federal Population Minister has been appointed, which might seem a good and
timely thing. But one gets the impression that, in assessing a ‘sustainable’ population for
Australia, consideration may be given to what in the natural environment can be sacrificed
and where, and what population increases can be squeezed in where, particularly in rural
areas. But rural landscapes and water availability may not be able to carry more people.
9. In considering population growth, humanitarian migration should continue, and only
necessary skilled migrations continue, but the impact on our natural environment, including
native vegetation, must be the very first consideration. I support calls for a Senate enquiry
into sustainable population targets for Australia. The issue of stabilising Australia’s
population at a sustainable level should be included in this Framework, perhaps with an
additional Goal, Target, and Action.
10. Planning. So often, the impact on the natural environment of any development is considered
last or not at all. In planning and decisions for any new mines or resource extraction, roads,
infrastructure, buildings, etc, on public or private land, again, the impact on our natural
environment, including native vegetation, must be the very first consideration. This issue
could be included in Goal 4, with an appropriate Target, and Action.
11. Biodiversity. In this 2010 UN International Year of Biodiversity, the Species Survival
Commission for the International Union for the Conservation of Nature–the body that
officially declares species threatened and extinct–has released data on the human-driven rate
of species extinction compared with the rate of evolution. It says, ‘Humans driving
extinction faster than species can evolve, say experts. Conservationists say rate of new
species is slower than diversity loss caused by the destruction of habitats and climate
change’. (Source: UK Guardian and iucn.org, March 2010.)
12. This is sobering information that illustrates we humans have contributed to this alarming loss
of biodiversity. One wonders what the extinction-evolution rate is for Australia. As thinking
species that have a choice about the way we act and live our lives, everyone of us—
governments and community—has a duty of care to ensure remaining species survive into
the future. The intent of this Framework—conservation and extension of Australia’s native
vegetation—may be a belated but important step towards redressing the imbalance between
species extinctions and evolution in this part of the world.
13. Native vegetation. Whilst it might seem comforting that Australia retains 87% of native
vegetation, this does not mean that all plant communities remain viable because of
fragmentation and degradation, as shown by the statement that less than 10% remains in
some areas. Given that about 85% of native vegetation is endemic in Australia, then it is all
the more important to conserve, restore and reconnect it, and encourage appreciation of it.
Please state this in a relevent section, such as:
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14. ‘Whilst the rate of loss and degradation of native vegetation has declined, this masks the fact
that the quality of the remaining vegetation (and the range and quantity of species it
contains), continues to decline. Therefore, it is vital that activities that affect the quality and
survival of native vegetation be curtailed, and regeneration and revegetation programs
increased’. Are the current laws adequate to restrict broadscale clearing of native vegetation?
15. Fully agree with further expanding the formal National Reserve System of native vegetation
where possible and appropriate. This should be referred to under Goal 1 with an appropriate
Target and Action.
16. Australia’s native wildlife and vegetation, though iconic, is held in poor regard by the
Australian community. One reason is that we are a nation of migrants that wish to see
familiar vegetation and landscapes from our homelands. As a result, the Australian
community is fed images of exotic vegetation in landscape designs, real estate promotion,
horticultural institutions and magazines, etc. So our native vegetation does not come to mind
in planning for these things. However, climate change and drought have changed
perspectives somewhat, but appreciation of our native vegetation and wildife still needs to be
promoted in every way. This issue might fit under Goal 4 with an appropriate Target and
Action.
17. Education and awareness raising of the value and importance of native vegetation and habitat
is essential at all levels of government and the Australian community. In Federal and State
agencies, local governments, town planners, schools, educational institutions (especially
horticultural), media, industry, business (especially real estate and property developers),
commerce, farmers, and landscapers. This issue might fit under Goal 4 with an appropriate
Target and Action.
18. Native vegetation management. Known data of bioregions, ecosystems, and the native
plant (EVCs) and animal communities they contain, must be used as a guide for land use and
native vegetation management.
19. Avoiding and managing in situ native vegetation loss is paramount. The Framework
glossary definition of the term ‘whole-of-ecosystem’ states ‘maintain viable populations of
all native species in situ’. Therefore, please make this clear when referring to native
vegetation management:
‘A decision-making hierarchy should be applied to native vegetation management where the
first aim is to avoid in situ loss between and within bioregions and their ecosystems; and, if
that is not possible, then to minimise loss; and if vegetation loss is unavoidable, that loss
should be managed to maintain ecosystem function, including, where appropriate,
identification of offsets’.
20. Natural regeneration should have priority over revegetation and this should be stated in
Action 9. Land targeted for native vegetation management may need to lie fallow across all
seasons, but weed species removed, to allow emergent vegetation to appear and, hence, to
inform vegetation management and land use decisions. Ecological burns can be useful,
providing wildlife can escape to nearby habitat, and important plants are protected or
avoided.
21. The value of isolated or semi-isolated local reserves needs to be carefully assessed in
decision-making, especially in any development for roads, infrastructure, etc. For example,
in south-east Melbourne a new arterial is about to decimate Coomoora Woodland, The Pines
Flora and Fauna Reserve, and Westerfields reserve. This issue would fit under Goal 1.
22. The Living Links Program for the Dandenong Valley Catchment in the south-east of
Melbourne, set up by the Port Phillip and Westernport Catchment Management Authority, is
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an excellent model for vegetation and habitat connectivity, that could be considered under
Goal 1.
23. Ensure decisions and actions about management of native vegetation is based on the needs of
local environments, not on commercial interests, bureaucratic or personal whims. This
would seem to fit under Goal 4.
24. Encourage schools, local residents, community groups, landscapers to grow or use local
native plants. And encourage rural, suburban, and urban land occupiers to grow local native
plants for connectivity and to increase the extent of an EVC or bioregion. This could fit
under Goal 1 and/or Goal 4.
25. Lowland snowgums and cherry ballart are disappearing around Melbourne, because their
plant communities are being removed, fragmented or degraded. Please encourage restoration
of lowland snowgum and cherry ballart plant communities where possible. (An issue for
regional and local authorities.)
26. The practice of legal and illegal harvesting of firewood for heating from our native
vegetation reserves can damage, fragment, or remove habitat—in reality, we destroy homes
for wildlife to warm ours. Wood smoke emits nasty compounds dangerous to health, adds to
particle pollution in our atmosphere, and is a nuisance in urban and suburban areas. Solid
fuel heaters should cease in built up areas. For all these reasons, unsustainable harvesting of
firewood needs to be included in this Framework and an Action implemented to regulate it.
27. Town, country, infrastructure, and leisure planners, at all levels of government should
receive training in recognising and understanding local native vegetation, EVCs, ecosystems,
and bioregions, including the impact of planning outcomes (development or infrastructure)
on the natural environment. This would seem to fit under Goal 4.
28. Local native vegetation retention or regeneration should be included in the design for new
development or redevelopment of residential, recreational, commercial, or industrial areas.
Each site could have, say, 50% local native vegetation, depending upon local EVC gaps or
any vegetation extension needed. Local native vegetation can be used creatively in
playgrounds, landscaping, etc. This could fit under Goal 1 and 4.
29. It is essential that all land agencies—rural, semi-rural, suburban and urban—communicate
and cooperate about the management of native vegetation (eg. road, rail, and catchment
agencies). This would seem to fit under Goal 4.
30. The offset principle can be misused and may not always be appropriate, see Goal 3, and
Action 13.
31. The types of carbon sequestration and carbon markets should be defined in relevant sections
of this document, especially under Goal 3 and Action 15.
32. Incentives are needed to encourage private landholders to appropriately manage native
vegetation. However, the market incentives must be guided by the environmental needs of a
bioregion and its climate, local ecosystems and their plant and animal communities. This
would seem to fit under Goal 3 and Action 15.
33. Where locally-native monoculture plantings are mentioned, for clarity, please state examples,
e.g. as used in landscaping or plantations. And please state that monoculture plantings are to
be avoided or minimised. Monoculture plantings may be cheaper and easier, so
encouragement or incentives may be needed for more biodiverse plantings to be considered
and chosen. This issue may fit under Goal 3.
34. This Framework should recognise that Australia’s natural world is on everyone’s
‘doorstep’, not just out in the ‘bush’. Many urban and suburban areas contain valuable
native vegetation on public and private land, including road and rail reserves, and are
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adjacent to green wedges. These native vegetation areas may contain remnant vegetation, are
home to wildlife and provide essential connectivity across metropolitan regions to the coast,
waterways, hinterlands, or inland areas.
For example, my home area contains important bush or grassland reserves, including
remnant vegetation, along 13km foreshore, along Mordialloc Creek, in Epsom Grasslands
and Wetlands, Ramsar-listed Edithvale-Seaford Wetlands, Waterways Wetlands, Woodlands
Wetlands, Braeside Park, and beyond into the south-east green wedge and down the
Mornington Pensinsula.
35. Please ensure that this issue is covered in a relevant section, and also under Goal 2 and
relevant Actions.
36. Threats. Threats from invasive exotic species and diseases, creeping urbanisation, and
climate variability badly need resolving through national and state legislation, and local
laws. Damaging exotic species and diseases must not enter Australia via imports, visitors or
returnees, and some exotic species must not be in the public domain. This issue is referred
to in this Framework, but it needs to be covered under Goal 4 with a relevant Target and
Action.
37. Reference to damage from livestock and feral animals (page 15) should include buffalo,
pigs, deer and brumbies, as well as sheep, cattle and camels. (Stray and feral cats also injure
and kill enormous quantities of insects and wildlife.)
38. Water availability is an increasing threat for the survival of plants and animals.
Environmental flows need to be returned to river and lake systems where possible, to
replenish ground water and freshwater environments. Water seepage from irrigation
channels and water bodies should remain, as it is a natural process that maintains ground
water levels and water flows. Bore water use needs to be restricted. Storm water could be
harvested for re-use and for environmental flows, and the use of recycled water increased.
Some water-hungry agriculture could be relocated. This issue should be covered under Goal
2 and/or Goal 4, and an Action, possibly Action 15.
39. Vision. This vision is appropriate but seems incomplete, in that it needs a definition of
native vegetation, reference to fauna and habitat, and a definition of changing climate.
Please reword to read: ‘Existing remnant, emergent or planted native vegetation across the
Australian landscape, and the fauna that depends upon it, is protected, extended, improved
and/or managed as essential habitat. And in an ecologically sustainable way, in recognition
of its enduring environmental, economic, social, cultural and spiritual values in a physical
or atmospheric changing climate’.
40. Principles. Absolutely agree, in general, that these principles are appropriate, except where
indicated:
1. Please include wildlife to read: Vegetation is vital for life on earth; its conservation is
fundamental to our survival and that of all wildlife.
2. Australia’s native vegetation is important to our national identity, and integral to the
relationship of Indigenous peoples with country—their traditional lands and waters.
3. Our natural resources are finite: the sustainable use of native vegetation is important for
maintaining ecosystem services, as well as for the economy.
4. Investment in native vegetation management should be ecosystem-based, strategic and
efficient. Whole-of-ecosystem approaches should be complemented by species specific
management for threatened species or species with unique requirements.
5. A decision-making hierarchy should be applied to native vegetation management where
the first aim is to avoid loss; and, if that is not possible, then to minimise loss; and if
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vegetation loss is unavoidable, that loss should be managed to maintain ecosystem function
including, where appropriate, identification of offsets.
6. Our environment is continually changing, accelerated by human disturbance, including
impacts of climate change, and we need to adapt our native vegetation management
accordingly.
7. All decisions should be made according to the best available knowledge and we should
apply the precautionary principle where knowledge is incomplete.
8. Climate change will affect the composition, structure and functioning of native vegetation
through altering species habitat thresholds, and modifying threatening processes.
9. Knowledge about the value and management of native vegetation, including Indigenous
knowledge (where culturally appropriate), should be widely disseminated and used.
41. Add a principle. Please add a principle about the interdependency of species, such as:
‘All flora and fauna species within an ecosystem have a unique interdependency—remove or
add a species and the functioning of an ecosystem is changed or degraded. For example, the
value of insects is often overlooked in the survival of plants and animals; they can be
perceived as a nuisance rather than an asset.
42. Figures 1, 2 and 3 (p16 & 17). The small size makes the fine detail hard to read, suggest
these figures are larger for better legibility—a page per Figure 1 & 2, and half page for
Figure 3.
43. Goals. The five goals below are appropriate, in general, and all are important and necessary:
Goal 1 Increase the national extent of native vegetation to build ecosystem resilience and
improve the productive capacity of the landscape
Goal 2 Maintain and improve the condition of native vegetation
Goal 3 Maximise the native vegetation benefits of carbon markets
Goal 4 Build capacity to understand, value and effectively manage native vegetation by all
relevant stakeholders
Goal 5 Progress the engagement and inclusion of Indigenous peoples in management of
native vegetation.
44. Additional goal. However, in relation to conservation of native vegetation, there are three
further issues that should be covered with either an additional Goal or under Goal 4 with
appropriate Targets and Actions:
1. Setting a sustainable population level for Australia
2. Planners and decision makers first considering the impact of development on the natural
environment, and
3. Raising awareness amongst migrants and visitors of the importance of native vegetation.
45. Goal 1. Increase the national extent of native vegetation to build ecosystem resilience and
improve the productive capacity of the landscape. Agree, especially with commencing this
year a net national increase in native vegetation extent. Reference to expanding the National
Reserve System should be included in Goal 1 with an appropriate Target and Action.
46. Regarding an increase in jurisdictions governing native vegetation to assist decision-making
and implementation, for clarity, state jurisdictions by whom—Federal, State, Territories or
local governments.
47. Regarding offsets, for clarity state the type of offsets and under what conditions.
48. Define the types of management practices, economic benefits and environmental services.
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49. Absolutely agree with the first rationale about the impact of extensive clearing of native
vegetation on landscapes, and with the second rationale about the benefits of increasing the
extent of native vegetation.
50. Goal 1 Example Targets. I agree with a ‘net national increase in the extent of native
vegetation by 2015’, but it is hard to suggest a realistic percentage.
I agree with ‘By 2015 all strategic land-use planning decisions maximise opportunities to
encourage revegetation, build conservation connectivity and limit clearing of native
vegetation’, but I would hope this would commence sooner than 2015.
51. Goal 2. Maintain and improve the condition of native vegetation. Agree with these four
points, in brief:
set of national standards
an increase in maintaining/improving the conditon of native vegetation through
investment/management priorities and communicating info to land manager
increase the capacity of native vegetation to sustain ecosystems and their
services/productivity
practices for sustainable management of native vegetation in production landscapes.
But for clarity suggest ‘production landscapes’ is defined. And regarding a set of national
standards, suggest this point state what benchmark/s is used.
52. Agree with all the Goal 2 rationale points, especially restoring native vegetation on private
and leasehold lands, which is so often overlooked.
53. Goal 2 Example Targets. Agree with ‘By 2015 the condition of X% of Australia’s native
vegetation has been significantly improved, but it is hard to suggest a realistic percentage.
Agree with ‘By 2015 all of Australia’s native vegetation is covered by management planning
aimed at reducing priority threats to condition and their underlying drivers’, but would hope
this would commence sooner than 2015.
54. Goal 3. Maximise the native vegetation benefits of carbon markets. Regarding ‘an increase
in effectiveness of native vegetation policies, plans and programs for carbon market
opportunities and native vegetation condition outcomes’, for clarity, suggest this point states
how the increase in effectiveness is to be achieved, and the types of carbon market
opportunities.
55. Regarding ‘suitable fire management regimes for positive native vegetation outcomes, to
protect the community and reduce greenhouse gas emissions, wherever feasible’, for clarity,
suggest this point states how the increase in effectiveness of programs is to be achieved and
by whom.
56. Goal 3 Example Targets. Agree with ‘By 2013 national standards have been developed
for accreditation and reporting of schemes that promote biodiverse native vegetation
outcomes along with carbon sequestration and other environmental benefits’, providing
carbon sequestration is of appropriate native vegetation.
Unsure that ‘By 2015 all native vegetation plans, policies and programs will be designed to
maximise native vegetation condition outcomes of carbon market opportunities’. Agree that
native vegetation condition outcomes are maximised, and that incentives or opportunities
might achieve this, but am unsure that carbon markets would do this.
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57. Goal 4. ‘Build capacity to understand, value and effectively manage native vegetation by all
relevant stakeholders’. Agree, but define the stakeholders. Visitors and immigrants also
need to understand and value our native vegetation, but would they be stakeholders?
58. Regarding incentives and business opportunities to encourage and support native vegetation
conservation on private land, suggest defining the types of incentives and opportunities.
59. Regarding community awareness initiatives that connect native vegetation, carbon and water
management issues, state why this is important and needed.
60. Regarding improving the national approach for native vegetation mapping, I would hope this
would reveal the ecological vegetation classes that would guide vegetation management. If
so, then this should be clearly stated.
61. Goal 4 Example Targets. Wholeheartedly agree that ‘By 2015 the majority of Australians
understand and value native vegetation’. Certainly, the passage of policies such as this
Framework would be much smoother if most Australians understood and valued our native
vegetation.
Agree that ‘By 2015 the functions and values of native vegetation are appreciated and
existing knowledge is shared among the wider community’, which would be a wonderful
outcome.
62. Goal 5. Absolutely agree with this goal to ‘Progress the engagement and inclusion of
Indigeous peoples in management of native vegetation’. Indigenous peoples will gain
inclusion and respect, and non-indigenous people may learn valuable things. However, state
how this will be done.
63. Goal 5 example targets. I agree that ‘By 2015 the majority of decision-makers understand
the cultural significance of native vegetation to Indigenous peoples and give that
significance weight in their decision-making, and I would hope that is possible.
64. Fully agree that ‘By 2015 Indigenous peoples are fully involved in native vegetation
management and decision making’, but unsure how realistic this is.
65. Targets. The example targets, at beginning of this Framework, refer to 2013 or 2015
timelines, but not beyond. Please state an intention to continue native vegetation
improvement targets into the future through periodic reviews of this Framework.
66. Regarding targets for the five goals, they would need to demonstrate how the targets are to be
achieved. As a lay person, I find it difficult to suggest appropriate targets.
67. Implementation. This section provides a good overview of intentions. Regarding
Indigenous peoples involvement in the implementation of this Framework, please state how
this will be done.
68. Actions. Please ensure these Actions cover:
1. The lack of or weakness of regulations regarding clearance of native vegetation and
inappropriate replacements
2. Inadequate system for tracking clearance of vegetation types that needs rectifying, and
3. Vegetation links for isolated local reserves, whether rural, suburban or urban.
69. One of the actions below should include expanding the National Reserve System referred
to on page 50 of the Framework.
70. Add Actions. Please add the following Actions:
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1. Develop stringent policies, legislation, goals, targets, and actions to mitigate greenhouse
gas emissions that cause global warming and climate change that threatens the survival
of all life forms, including native vegetation.
2. Examine a sustainable population growth for Australia, with the impact of population
growth on the natural environment and its capacity to absorb population growth being the
first consideration.
3. Develop programs for all levels of government to buy back land in wildfire zones.
71. Action 1. ‘Develop national guidelines for native vegetation legislation to provide a basis
for consistency, where possible, in definition and scope of coverage.’ Agree.
72. Action 2. ‘Undertake risk assessments to identify vegetation types where action to improve
condition or extent is urgently needed, is likely to be needed in the future, or where
vegetation has the potential to act as a refuge from climate change.’ Agree. Please consult
with Indigenous peoples, public and private land managers, local botanists and Friends
73. Action 3. ‘Develop national criteria for classifying the condition of native vegetation.’
Agree, but state benchmark/s used for national criteria. Please consult with Indigenous
peoples; public and private land managers; local botanists and Friends groups, as well as
74. Action 4. ‘Develop management plans to address priority threats to the extent and condition
of native vegetation, based on the outcomes of Actions 2 and 3.’ Agree. Please consult with
Indigenous peoples, public and private land managers, local botanists and Friends groups, as
well as Austral
and CMAs.
75. Action 5. ‘Develop a national approach for vegetation mapping so that data from all
veg
and ecosystem services into national accounts.’ Agree, but mapping should have a higher
priority and be done concurrently with risk assessment, and classification of condition of
76. Action 6. ‘Undertake mapping of native vegetation using the outcomes of Actions 3 and 5.’
Agree. Include local governments and land agencies, as well as Australian Government,
77. Action 7. ‘Ensure native vegetation datasets are accessible and designed to facilitate
national monitoring, mapping and reporting on trends in native vegetation condition and
extent, in line with Action 5.’ Agree. Include local governments and land agencies, as well
78. Action 8. ‘Integrate native vegetation protection and management into regional strategic,
long-term land-use planning. This should be informed by the outcomes of Actions 2, 3, 4 and
6.’ Agree with this action, and with responsible authorities: state and territory governments,
planners.
79. Action 9. ‘Develop regional plans and programs (in combination with Action 2) that
natural
priority
given to natural regeneration over active revegetation. Agree with responsible
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bodies
80. Action 10. ‘Develop, resource and implement a range of innovative approaches and
incentive programs (for example, market-based instruments, covenanting programs,
economic/business opportunities to deliver ecosystem services) that encourage land
managers to maintain and increase native vegetation on all land, including on private land.’
CMAs, Private land managers.
81. Action 11. ‘Inform, engage, educate and where appropriate, train land managers and the
community generally on the values (including biodiversity and carbon storage values) of
native vegetation and its management (including appropriate fire regimes)’. Agree with this
ion between
land managers. Visitors and immigrants also need to be targeted.
82. Action 12. ‘Target planners, policy-makers, decision-makers and developers with an
education campaign on the importance and value of native vegetation.’ Yes, absolutely
agree! Also target real-estate agencies, landscapers, media, commerce, horticultural people.
and territory governments.
83. Action 13. ‘Integrate native vegetation protection into planning instruments through
implementing a decision-making hierarchy to native vegetation management where the first
aim is to avoid loss; and, if that is not possible, then to minimise loss; and if vegetation loss
is unavoidable, that loss should be managed to maintain ecosystem function including, where
appropriate, identification of offsets’. Yes! Include allowing time for natural regeneration
(with weed control). Offsets can be a pernicious tool, as an offset principle can be misused
and an offset can be inappropriate, so at least define the offsets and under what conditions,
and what data informs offset decisions. Responsibility should include include local
governments, as well as State and territory governments.
84. Action 14. ‘Develop standards for reporting and accreditation of schemes that promote
biodiverse native vegetation outcomes along with carbon sequestration and other
environmental benefits.’ Agree, but ensure carbon sequestration is biodiverse and not
monoculture. Responsibility is
take place with other levels of government and agencies.
85. Action 15. ‘Develop policies and plans complementary to carbon and water markets, which
maximise biodiverse native vegetation.’ Agree, providing vegetation management and
offsets are guided by the environmental needs of a bioregion, ecosystem or an EVC. Agree
86. Action 16. ‘Facilitate dialogue between researchers, government, planners, developers,
land managers, and Indigenous peoples to ensure knowledge of best practice native
vegetation management is shared, regularly reviewed, updated and implemented.’
Absolutely agree with action, and with responsibility: Austr
87. Action 17. ‘Provide capacity building for Indigenous peoples to empower effective
engagement, increase opportunities for Indigenous involvement in native vegetation
management as significant landholders, and increase economic opportunities related to
sustainable utilisation of native vegetation.’ Absolutely agree with action, and with
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responsib
88. Action 18. ‘Explicitly recognise, value, respect and provide for the consideration of
traditional Indigenous knowledge in appropriate high-level government decision-making
processes, policies and statutes related to native vegetation management.’ Wholeheartedly
onal NRM bodies and CMAs.
89. Action 19. ‘Identify knowledge gaps and prioritise research concerning the value and
management of native vegetation.’ Agree with action. In responsibility, include local
peoples.
90. Action 20. ‘Adopt and promote use of appropriate fire regimes in native vegetation
communities which aim to maximise biodiversity, reduce greenhouse gas emissions and
protect public safety (Case Study 7)’. Agree, but fire management regimes need to include
fire-safety upgrading of power lines and infrastructure–bundling, undergrounding, etc.
Include Indigenous peoples, Landcare and Friends groups, as well as State and territory
governments,
91. Action 21. ‘Develop a nationally consistent approach to management of sustainable
harvesting of native flora and vegetation products through state and regional management
plans and policies. (This does not include forestry industry products).’ Agree, but state the
‘products’, including harvesting of firewood. Include Indigenous peoples, local botanists,
governments.
92. Action 22. ‘Develop communication strategies aimed at encouraging and facilitating
collaborative management of native vegetation at a bioregional scale.’ Agree with action
and w
93. Action 23. ‘Identify and promote investment in the maintenance and appropriate sharing of
traditional and contemporary Indigenous knowledge where relevant to native vegetation
management.’ Agree with action, but state with Indigenous peoples permission. Agree with
governments,
94. Action 24. ‘Incorporate cultural landscape mapping and planning in the early stages of
planning native vegetation management where this is appropriate.’ Agree with action and
responsibility: Australian
95. Action 25. ‘Develop and implement programs, in collaboration with Indigenous traditional
knowledge holders, to ensure decision-makers understand the cultural significance of native
vegetation to Indigenous peoples.’ Absolutely agree with action. Include public and private
es.
96. Action 26. ‘Resource and implement awareness programs to build land managers’
awareness of their legislative responsibilities for native vegetation management and the
consequences of non-compliance, and of conservation business opportunities.’ Agree with
governments.
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97. Case Studies. These are inspiring and heartening initiatives that demonstrate the value of
government, agencies and the community working together to improve local environment
outcomes.
98. Case Study 2: Building resilience to climate change (Tas. Govt). This whole-of-landscape
approach could be a good model for initiatives elsewhere. Please explain ‘spatial layers’.
99. Case Study 3: Caring for our Country – Environmental Stewardship (Aust. Govt).
Caring for our Country is a proven and great initiative. Environmental Stewardship is fine, if
land and vegetation management is guided by local environmental needs or gaps in
bioregions, ecosystems and EVCs, and if offsets are within them.
100. Case Study 4: Property Vegetation Plans and the Native Vegetation Assessment
Tool (NSW Govt). Incentives for landholders to conserve and enhance native vegetation on
their properties may be necessary and useful, providing important plants or plant
communities and wildlife habitat are protected or avoided.
101. Case Study 5: Integration of native vegetation and development assessments (SA
Govt). This seems an excellent nation-wide model, providing offsets are within a bioregion,
ecosystem or EVC, and local environmental needs or gaps of these areas determine the
offsets.
102. Case Study 6: BushBroker (Vic. Govt). Regarding regeneration/restoration, time needs
to be allowed across all seasons and plant cycles for emergent vegetation to appear, which
could then determine offset and management regimes. And offsets need to be of an
appropriate vegetation type and location.
103. Case Study 7: Northern Kimberley Fire Project (WA Govt and CSIRO). This seems
to be a valuable investigation of changes in wildfire patterns, and experimental practices to
reduce the frequency and intensity of these wildfires.
104.
Monitoring and reviewing the framework
Seems fine. Agree with second and fourth year reports in the five-year review cycle so that
the national interested community can follow progress.
105.
Adaptive management
Agree with the ‘common sense’ sharing of knowledge, experience and further research
amongst NRMMC agencies and the national community. This initiative is essential to
develop adaptive management to ‘protect valuable existing vegetation; increase the extent of
native vegetation; and improve the condition of degraded areas’, especially in this time of
climate change and shifting climate zones.
I do hope my comments are useful. And I hope this Framework generates greater interest in and
appreciation of our native plants and animals. Thank you for the opportunity to comment on this
significant and important Framework that may lead to better outcomes for native vegetation
quality and extent, and for native wildlife across Australia.
Yours faithfully
N. Earl
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