Comments

The Officer in Charge PO Box A290 South Sydney NSW 1232 www.landmanagement.nsw.gov.au/have-your-say/ Dear Officer in Charge As a covenant holder with NSW Nature Conservation Trust I would like to protest against the NSW biodiversity law reforms package, including the proposed draft of the Biodiversity Conservation Bill 2016 and the draft Local Land Services Amendment Bill 2016 [hereinafter referred to as 'the proposed new laws'] as they provide a significantly reduced level of environmental protection than the Native Vegetation Act 2003 and the Threatened Species Conservation Act 1995. We request that the NSW government withdraw the proposed new laws and strengthen existing laws to conserve the environment, and commit to providing additional resources for their effective implementation. We have particular concerns about the following proposed changes: Repeal of the native vegetation act 2003 We disagree that there is a need to repeal the native vegetation act 2003, which is one of the state's more significant conservation laws because it protects bushland and wildlife habitat across most of NSW. The current vegetation and land clearing laws are working and the act has stopped biodiversity loss. Since the Native Vegetation Act 2003 was introduced to stop widespread land clearing, the world wildlife fund has estimated an 88-fold reduction in areas approved for clearing, a 20% decline in actual clearing of remnant bushland and a 14% drop in native mammal deaths. The NSW State of the Environment Report 2015 identified the Native Vegetation Act 2003 as a key piece of legislation protecting soils and facilitating sustainable land management. There have been a significant number of successful property vegetation plans developed under the act that has resulted in over 4 million hectares of native vegetation on rural land being preserved and managed. Under the act, land clearing has been reduced whilst farmers and landholders have still had the freedom to clear land that is not environmentally sensitive. The current system worked well till funding cuts delayed land clearing approvals. Employing more environmental officers across the state would decrease the amount of time taken to produce property vegetation plans and allow for increased availability of expertise to rural landholders and farmers. Repeal of the threatened species conservation act 1995 Loss of local threatened species listings Under the proposed new laws there will be no local threatened species listings (unless there is no listing for the species in NSW), resulting in a 'one size fits all' approach. Considering the size of NSW, it is inconceivable that the same level of threat to any one species would apply across the state. The koala populations between the Tweed and Brunswick Rivers east of the Pacific Highway were officially listed as endangered by the NSW Scientific Committee on 22 April 2016 as a result of the alarming findings of The Tweed Coast Koala Habitat Study 2011. Local residents are outraged that these koalas will revert to being listed as vulnerable, even though the updated Tweed Coast Koala Study 2015 revealed that these koalas are on the brink of extinction. Self-assessable codes Increased land clearing and biodiversity loss The proposed changes to land management, especially the self-assessable codes, will result in increased broadscale land clearing and biodiversity loss, allowing landholders to clear trees with little oversight. This has been seen with the introduction of self-assessable codes under the Native Vegetation Regulation 2013. For example, recent figures show that the rate of paddock tree clearing under the self-assessable clearing of paddock trees in a cultivation area has increased 140% under the native vegetation regulation 2013 with absolutely no compliance checking. The proposed new laws do not include information as to how the self-assessable codes were developed, which should be part of the public consultation process. The following points are of particular concern and should not be permitted under self-assessable codes:

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