Dear Sir/Madam

I recently received the Issues Paper produced by the Commission in relation to the Inquiry into the impacts of native vegetation and biodiversity regulations.

As a professional environmental planner and land management consultant with a direct interest in this subject, I find the apparent approach and terms of reference rather narrow. In particular, the Issues Paper raises many questions which are cultural and social in nature, and relate to subjective values, which have been reviewed elsewhere in other forums.

I wish to make the following comments for consideration in your inquiries:

1.	Native vegetation and biodiversity regulations form only one aspect of a suite of land use and land management regulations, and cannot be seen in isolation from these. For example, in NSW, threatened species objectives are substantially implemented as part of the Environmental Planning and Assessment Act. Regulation for native vegetation is a result of the failure of other legislation to address these issues. 
2.	A central matter of concern is the lack of clarity between responsibility for land and environmental management issues between Commonwealth, States, Territories and local government. The current regulatory complexity is a direct result of the lack of an adequate constitutional framework to deal with these issues. It should be a Commonwealth responsibility to initiate a review of the Australian Constitution to recognise biodiversity and environmental objectives, clarify responsibilities for land use, ensure consistent state processes for land use planning and land management, and to recognise local government roles in native vegetation and biodiversity conservation. 
3.	A comprehensive literature review of the history, and need for biodiversity regulation is an essential starting point for this inquiry, to understand the social context.

I look forward to further information on the progress of the inquiry, and would be happy to discuss the above aspects further if required.

Thank you for the opportunity of making a submission.

Martin Fallding
Land & Environment Planning
www.calli.com.au/lep