It is my central submission that the focus of the reforms is mis-concentrated on massaging what is falsely seen as a competing interest contest largely between all farmers and environmentalists. The government has not articulated a clear far-sighted legislative agenda guided by genuine public interests, in place of the current scrappy bandaid for a multi-interest group of small and large farmers, Australian and overseas owned. This group is not entitled to more 'freedom' irrespective of as-yet-not-fully-known interests of future generations of NSW people, and certainly not without verified investigation into impacts on otherwise-voiceless members and communities of species that may be targeted by such freedom.

Serious deficiencies and problems associated with proposed new NSW biodiversity conservation and land-clearing laws have been identified, analysed and publicised by scientists and others with relevant knowledge and experience, including with respect to biodiversity conservation, ecology, land and soil management, water flow and quality, sustainable agriculture, Indigenous heritage and culture, evidence-based farming, climate change and legal enforcement.

Such deep and widely-based criticism reveals what a 'dog's breakfast' these statutory changes really are.

Their criticism stands in strong contrast to the views of those lobbying for change to existing laws so as to open up both the possibility, and probability, of broad-scale land clearing. Their heartfelt lobbying rhetoric is strident and well-funded, but lacking in factual data and rigorous analysis, and any asserted 'science' on which they rely is insubstantial.

I firmly believe that the ensuing politicisation of the proposals into a 'farmers vs environmentalists' confrontation has been generated not only because of natural resource politics but because, at a fundamental level, the proposals are seriously amiss in lacking a coherent governmental narrative about their ultimate purpose and underlying principles.

To give one example: It is a fundamental role of Government to maintain both a past and ongoing public interest perspective on natural resource issues (in which I include soil and vegetated land). When granted private ownership or other use rights, it is unsurprising in our modern culture that such resources can be regarded as private capital, more than as resources that are bound by some higher stewardship notion in the general public interest.

Many NSW native soils and land surfaces have been converted (including with the aid of broad scale clearing) for largely non-native oriented farming practices. Some such lands have later been abandoned in an unrestored condition, leaving them degraded for either farming or natural ecosystem purposes; some farmlands have later become urban or suburban lands to meet residential and industrial needs of growing populations. In either case, there is a twofold loss - an overall loss of, or significant impact on retention of, natural biodiversity as well as agricultural security in a climate-changed world of increasing human population.

The current government proposals do not contain mechanisms that would effectively guard against and redress subsequent changes such as these, despite growing urgency to do so. On this point alone, I think that the proposals should not proceed.

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