I wish my comments to be regarded as my interim submission on the proposed Draft Biodiversity legislation Bill for NSW.
As an individual who has a lifetime of working with biodiversity conservation I am absolutely opposed to the present proposal in its Draft Form.
I strongly request that this Draft be withdrawn until there are accurate maps available to assess the implications of the proposal.
Why does the NSW Government propose throwing out a World class Threatened Species Act which has been objectively and scientifically drawn up for one the is NOT scientifically based nor objective.
Our Native species and their connectivity cannot be so randomly regarded without the distinct possibility of further massive extinctions as a result of this proposal.
Concerned and knowledgeable citizens can have no confidence in the unknown outcomes of this proposal which is not even supported by the majority of landholders.
I refer to all major points as iterated by the EDO Office who make an excellent and accurate assessment of this biodiversity proposal which will result in the Massive loss of Biodiversity if it were ever to be legislated. The proposal is both destructive and reductive of the NSW Natural Heritage; the very thing that urgently needs responsible protection and management.
Much lower standards of Biodiversity protection are proposed in the Draft.
No maps are available. It is supposed that these are available to the Department and not to the public because they are known to be inaccurate. Maps are a vital tool, and must be accurate on the ground.
Further overall work is essential as is public knowledge and disclosure.
There have been great missed opportunities to effect improvement of existing legislation. There has been a huge wasting of public resources and time by the existing ANTI Biodiversity Bill Draft proposal.
There is contradictory legislation which cannot be put into action without further great legal challenges.
'Biocertification' is a completely unscientific proposal.
Conservation gains are in no way certain or guaranteed. Biodiversity loss and bio connectivity is certainly non existent leading to species and bio-communities being lost in this proposal, leading to further needlessly caused extinctions if this proposal were ever to be enacted.
Withdraw this Draft and make any further proposal both scientifically objective and able to be supported by the human community. A repeal of the native Vegetation Act and the environmental standards that go with it MUST be retained. The existing EOAM is world class and must not be sacrificed to self assessable Codes with discretionary exemptions and discretionary clearing assessed by both biased and unscientific means, which is the proposed way suggested by the Draft. It could not stand up in law for biodiversity protection.
A very undesirable, and unscientific aspect of the draft is the Heavy re liance on flexible and indirect biodiversity offsets. Such measures should not be allowed as they are both inequitable and result in a negative overall outcomes. as well as loss of ecocommunities and connectivity, resulting in a downgrade bio diversity result.
The fact that this draft arose out of a MOU by political interests is testimony of the fact that it will have an appalling effect on our NSW Bio diversity if ever enacted. Already our Native vegetation and world class unique flora and fauna has been so drastically and unnecessarily compromised that it needs further protection and assistance not further indiscriminate clearing and destruction. Soil Water and microclimate must be considered.
Please withdraw this draft proposal and instead work with the human community and scientists to improve the existing biodiversity acts.
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