Re: public comment on the Impacts of Native Vegetation and Biodiversity Regulations document.

Thank you for allowing me the opportunity to read and comment on this document.

Overall, I find it a clearly structured document that is easy to read.

It has effectively gathered together information about the effectiveness and impacts of current clearing regulations. It has alerted me to a number of issues that I was not previously aware of, as well as acknowledging issues that I am very familiar with, especially through living in a broad-acre agriculture community.

I have some specific comments that I would like to make:

Overview
•	Table 1, page XXIV. Clarification is needed as to whether the table is showing % of vegetation that has been cleared, or is remaining.
•	Page XXVI. Could there perhaps been a slight reduction in clearing due to there being less area left to clear, as well as a result of the legislation?
•	Page XXX, Box 2. Has the loss in soil quality / water table rise / loss of stock shelter etc been factored into the future economic expectations in a case where clearing was not outlawed?
•	Page XXXI. I had not known that South Australia gave compensation for a rejected clearing application. I like that idea.
•	Page XXXIII, box 3. I agree with most of the points outlined in the box, but not point 5. Taking economic and social reasons into account if an application has been rejected on environmental grounds would have to be strictly guided and monitored. I feel that only in extenuating circumstances should a proposal go ahead if it were found to have adverse environmental impacts, and would like to think that some form of offset for the area cleared and damage expected to be prescribed.
•	Page XXXIV. There is definite value in allowing some regional control over the assessment of clearing. However, there needs to have an over-arching legislation eg state-wide closely guiding the process. There is definite potential for a “you scratch my back and I’ll scratch yours” mentality to develop, and as a result marginal applications be approved. 
•	Page XXXVIII. If a landholder is prepared to own a large area of land, which is inextricably linked with the surrounding environment, then they do need to take some responsibility for public benefits. They have stewardship over the land. Public benefits do not necessarily “free-ride” off work on private land and vice-versa, they are related.

Recommendations.
1.	 
2.	
3.	 - mapping information definitely needs to be improved.
4.	As mentioned above for page XXXIII, I have concerns about the fifth point
5.	I express caution at giving local communities too much flexibility in regulating clearing control. While it is highly important for them to be involved in the process, and recognising the value of local knowledge, it needs supervision by a third party.
6.	Point two raises concerns that economics could come before environment frequently. Tight guiding principals, and more clarification in this sentence, are required.
7.	Landholders private benefit cannot always be easily separated from public benefit – more often than not, an action will benefit both. Remove the word “simply”.
8.	This recommendation needs to be clarified in its wording and presentation.

Draft findings
•	Page XLVI. Draft Finding 3.7. This finding is why I am concerned about Recommendation number 4
•	I agree with Draft finding number 7.9.

Western Australia
•	I am pleased that rural and urban clearing applications are proposed to be assessed consistently.
•	Page 426, dot point 4. Good recognition of the sentiment that government agencies often appear to operate outside of the legislation.
•	Page 432. I agree with the recognition that there is not enough funding available to support incentive programs on private land.

Ella Maesepp
PO Box 99
Dumbleyung WA 6350
dyglandcare@westnet.com.au