I make the following comments on the draft report both as an individual, and on behalf of the Ecological Society of Australia. 

Combined comments on the draft:

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The report is both thorough and well presented, and the Productivity Commission is to be congratulated on its substantial draft.

There are 3 small but important gaps in the Commission's consideration of this issue I have noted in my quick reading of the report  - I apologise if I may have missed these points and are actually included in the report.

1. Consideration of passive clearing (allowing an absence of management, or deliberate inaction or access by stock to a patch of remnant vegetation to allow its degeneration and ultimate demise) is not mentioned. The report should discuss this issue within the framework of duty of care.

2. Consideration of the opportunities for profit from retained/regenerated vegetation is not addressed in the draft. Where managed as part of an agricultural system, remnant vegetation may sustainably yield various crops through - sustainable grazing, sustainable  harvesting of cut flowers/seed, honey bee use of nectar for honey production, and bush tucker and the sustainable use of other resources (eg sandlewood). Ecotourism values of remnant vegetation can also be significance to farmstay and other such enterprises.

3. The final report should include a recommendation that  State and Federal Governments to must support sustained research novel, sustainable uses of bushland and value adding to crops/products derived from native vegetation, thereby ensuring that land holders have an additional incentive to retain vegetation in perpetuity.

As time is short I have not expanded on these points but if invited would be happy to address this issue further in writing, or at the public hearing (this is an offer to appear, not a request to appear!)

regards, Ray Wills

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  Dr Ray Wills 
  Adjunct Senior Research Fellow,
  School of Earth and Geographical Sciences,
  The University of Western Australia
  rwills@segs.uwa.edu.au    www.geog.uwa.edu.au

"The world belongs to the optimists, pessimists are only spectators." 
                                                      Francois Guizot

In addition this submission is also made on behalf of the Ecological Society of Australia 
 -  address and contact details are:

Dr Craig James, President
Ecological Society of Australia Incorporated
PO Box 1564
Canberra ACT 2601 
President@ecolsoc.org.au