Comments

The new provisions for clearing around infrastructure are sensible. The previous provisions were not at all practical.

Simplifying Land Management

Are the baseline set-aside ratios appropriate, and what should the obligations be for different levels of management?
The 2% cap is somewhat tight. Where a landholder has retained a > 30% timber, they are disadvantaged if they wish to do a viable amount of work in a particular year.



I am concerned that set-asides will require a permanent land title caveat. This is not desirable.
Are the ratios in the equity and farm planning codes appropriate to ensure, where agricultural land management activities can have environmental impacts, that the impacts are managed appropriately?
I do not believe that there is an issue with over-clearing. Farmers plant and provide for re-growth retention at a far greater rate than any clearing.



We need to be more concerned about clearing for urban development and mining where there are significant funds to make the desired outcome happen (eg clearing of National Park at The North Entrance to make way for a Golf Course)
Should the set-aside loading for clearing of endangered ecological communities also apply to vulnerable ecological communities?
I don't believe that this criteria will get used very often due to the landholder being required to bear the cost of expensive consultants.
Clearing under the codes is not permitted in RAMSAR wetlands, littoral rainforest, core koala habitat, Areas of Outstanding Biodiversity Value and sites managed under the Saving Our Species program. Should similar exclusions apply with respect to mangroves, saltmarshes, riparian zones adjacent to water bodies, land up to the highest banks of streams, lagoons and wetlands, Aboriginal places and culturally modified trees, and national, state and local heritage items?
Normally, No. However some clearing to create Strategic Fire Management Zones may safe the environment from total destruction.
Does the new proposed framework create or support productivity gains on your property?
Concerned about E Zones?



Concerned about the expertise level in Councils and concerned that many can't manage their role now.
Does the proposed new land management framework ensure that, where agricultural land management activities can have environmental impacts, that the impacts are managed appropriately?
Perhaps this is where conservation should be more important. Most of the viable land would have been cleared long ago in these areas.
Are the baseline set-aside ratios appropriate, and what should the obligations be for different levels of management?
It is very difficult to comment on mapping that we have not seen. We need to be able to ground truth it.



Farmers do need to construct infrastructure across riparian zones. They should nor need to take two or three days out to have a paid consultant tell them what they already know.
Does the proposed new land management framework appropriately capture matters under the current Environmental Outcomes Assessment Methodology?
Not sure about native grasslands & native grasslands under open woodland (retained vegetation). Originally, Native Grasslands on the tablelands were to be left out of the whole process. Perhaps we should consider if there is a need to include Native Grasslands now.



Again, we will need to see the maps to make a reasoned comment.
Clearing under the codes is not permitted in RAMSAR wetlands, littoral rainforest, core koala habitat, Areas of Outstanding Biodiversity Value and sites managed under the Saving Our Species program. Should similar exclusions apply to any other areas? For example, mangroves, saltmarshes, riparian zones adjacent to water bodies, land up to the highest banks of streams, lagoons and wetlands, Aboriginal places and culturally modified trees, and national, state and local heritage items?
An retained woody vegetation open woodland on slopes may well distort the percentage of timber cover as the trees in this situation spread out much more and the ground slope will appear level from above (from a percentage cover perspective)
Should the LLS or the local council be responsible for issuing permits for E zones and R5 zones in rural areas of the State?
We need the maps to comment on this

Ecologically Sustainable Development

How can the Trust make the estimation of Fund administration expenses more reliable?
Yes, commercial harvesting of Kangaroos is essential. Accredited (very important) harvesters can make some money from what is a pest in large numbers. Farmers really don't have the time to get into roo culling.
Should the calculator produce a fixed price in all circumstances or could there be some situations where it would be appropriate to allow a proponent to negotiate a price with the Trust?
Feral Deer and Feral Pigs should be covered. Deer are becoming a much greater issue and should not simply be a species set aside for leisure sports. We should ensure that all hunters are very well controlled and the industry is not a cover for illegal activities.
Should the Trust be able to set and update all aspects of the calculator? Are there any components that should be set and updated by the Minister or another party?
We already have an extensive Landcare network. They just need resources.

Native Plants and Animals

The NSW Government has prepared an example wildlife code of practice that will be developed before the Biodiversity Conservation Act commences. Do you have any comments on the example code of practice for commercial kangaroo harvesting? How could it be improved?
Where farmers conserve native vegetation, there should be a recognition of that and suitable compensation. Timbered land can be grazed strategically and the bush fire risk is significantly reduced.
What other activities could be covered by a code of practice for wildlife management and why?
I suggest that the Trust may in fact consult the landholders and learn from them.
What needs to be considered in developing education materials on the new framework and for raising awareness about native plants and animals?
Quite involved, but better than the PVPs
Is the proposed protection for Areas of Outstanding Biodiversity Value appropriate?
This topic needs a lot of research and time to adequately respond to.

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