NBSAP Taskforce

Update of Australia's Strategy for Nature 2019-2030

Thank you for the opportunity to comment on the Discussion Paper Updating Australia’s Strategy for Nature.

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of native grassy ecosystems, and carries out surveys and other on-ground work. FOG is based in Canberra and its members include professional scientists, landowners, land managers and interested members of the public.

We recognise the proposed Australian targets sit under, and will direct, Australia’s efforts to improve biodiversity outcomes consistent with Global Biodiversity Framework targets, i.e., these targets are very important. FOG comments below on the need to improve thinking regarding three of the six priority areas and associated targets.

I encourage you to address each of these matters as you work with the states and territories to update the Strategy.

Yours sincerely

 

Professor Jamie Pittock

President, Friends of Grasslands

4 April 2024

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Priority area 1: Effective restoration of degraded terrestrial and inland water ... ecosystems

The proposed Australian target:

30% of priority degraded areas under effective restoration by 2030,

is a simplification of the global target:

Ensure that by 2030 at least 30% of areas of degraded terrestrial, inland water, and coastal and marine ecosystems are under effective restoration, in order to enhance biodiversity and ecosystem functions and services,

but the simplification does not work.

Implicit in the global target is an awareness of the ecosystem in which any restoration is to occur, and therefore the ecosystem qualities that are to be restored. This consciousness directs restoration efforts, it implies what good outcomes will look like, in a given ecosystem. Quoting from the Consultation Paper, the notion Australia should aim to “improve biodiversity outcomes” is so vague a perverse outcome might be possible where, for example, trees might be planted where there should be grassland.

Quoting again from the Consultation Paper, the primary focus appears to be the mere identification of priority degraded areas. This is not ambitious at all. If these words are included in the Strategy without improvement, any jurisdiction might later argue they thought the mere identification of priority degraded areas is all they had to achieve.

For the Strategy to be effective, other changes that are needed include:

• ‘degraded areas’ needs better definition, e.g., degraded how, to what extent – effort must be directed to areas where restoration is achievable (elsewhere, a replacement ecology is all that is achievable, and replacement is not restoration)
• ‘effective restoration’ needs better definition, e.g., the Strategy needs to engage with what must happen where threats causing the degradation are ongoing, to be clear about whether rehabilitation of severely degraded land is to be counted against the target, and to rule out restoration that would be inappropriate (e.g., again, to be planting trees where the ecosystem is a grassland)
• new protection mechanisms are needed (more below)
• requiring some specific, measurable, achievable, realistic and timetabled actions.

For protecting important environmental gains made on private land, what is needed are unambiguous, perpetual and secure statutory mechanisms that enable the inclusion of both restrictive and positive elements. 

Mechanisms with these qualities have to date been enacted by state and territory authorities to bring high conservation value private land in each jurisdiction’s protected area estate (private protected areas)[1]; hence, administering authorities have been reluctant to execute such instruments over places in need of extensive rehabilitation.

The new target gives rise to a need for all Australian jurisdictions to enact new forms of mechanisms that will securely protect private land in perpetuity where that land is under rehabilitation; otherwise, every such investment will remain or revert to being susceptible to complete loss.[2]

Priority area 2: Tackling the impact of invasive species

The Australian target must be much more ambitious. Focusing efforts on “our most precious places” will guarantee ongoing biodiversity loss across the nation. The threat is being under-estimated. Australia must stop the introduction and spread of invasive species into biodiverse areas with the sort of rigour currently reserved for threats to the production of food and fibre.

The GBF target recognises pathways to introduction and spread are without jurisdiction. Yes, Australia may be good at preventing things from entering the country, but we can and must do much more to sever the pathways of internal spread.

The threats to ecosystem services by idly allowing invasive species to have severe impacts across vast tracts of land and ocean are broad, serious and urgent. Change needs to occur at fine scale, e.g., changing mowing practices in road reserves to stop the spread of weeds.

Our “least precious places" can harbour enormous quantities of invasive species that can then easily colonise "our most precious places". Hence, we need invasive species management to be both holistic and site-specific if it is to be effective.

Priority Area 5 (which is also the target): Protect and conserve 30% of Australia’s land and 30% of Australia’s oceans by 2030

The Strategy needs to be clear about whether severely degraded areas of land under basic rehabilitation can (or will not) count toward this target.

More action is needed to ensure the management of protected and conserved areas is adequate (the ‘a’ in comprehensive, adequate and representative). It is not enough to merely ‘identify priorities’, action is needed urgently to achieve management effectiveness, i.e., better outcomes overall, across tenures, by giving greater consideration to landscape-scale, ecologically-informed land management.

Minimum standards are needed for the protection and management of all areas of public and private land that count toward Australia’s protected area target.

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[1] For example, Conservation Covenants executed with landholders by the Trust for Nature (Victoria) under s 3A of the Victorian Conservation Trust Act 1972

[2] Assume legislative instruments are made under the Nature Repair Act 2023 (Cth) and a nature repair market is established. In the absence of such a mechanism, any gain secured by a registered nature repair project will be susceptible to complete loss at the end of the project’s so called permanence period.