Chapter Thirteen. BIODIvERSITy

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1 Chapter Thirteen BIODIvERSITy

2 Chapter 13: Biodiversity conservation, recovery planning and threats management Key points Recovery planning, especially species-by-species planning, is not as effective or as efficient as it could be. Concern is focussed on failure to prepare effective plans and failure to implement plans. There was support for outcomes-focused efforts and for multi-species and regional recovery planning approaches. Insufficient resourcing is provided to support the development and implementation of effective recovery actions. Decision-making is often supported by poor information or a limited knowledge base. There was support for a broader approach to biodiversity conservation such as at a landscape or ecosystem level. Current provisions of the Act Recovery plans 13.1 The Minister may make, adopt and implement a recovery plan for threatened fauna, threatened flora (other than conservation dependent species) and threatened ecological communities listed under the Act. The Minister must take account of the precautionary principle in making a decision on whether to have a recovery plan Recovery plans set out the research and management actions necessary to prevent further decline and support the recovery of, listed threatened species or threatened ecological communities. The aim of a recovery plan is to maximise species or communities chances of long-term survival in the wild A recovery plan can be prepared by the Minister alone or jointly with relevant States and Territories. In practice, the Minister may adopt a State or Territory plan, provided it meets the Commonwealth s requirements. There must be public consultation and advice from the Threatened Species Scientific Committee (TSSC) regardless of how this plan is prepared. A recovery plan only has force under the Act if it has been formally adopted by the Minister. Where a recovery plan is in place, the Commonwealth must not take any action which is inconsistent with the recovery plan The preparation of recovery plans is provided for under s.269aa. Prior to the 2006 amendments, the preparation of a recovery plan was mandatory for all listed threatened species and ecological communities. Recovery plans are now only developed where the Minister considers, upon advice from the TSSC, that development of a plan is required to achieve the protection of the species or ecological community Under s.279(2) of the Act, the Minister is required to review the effectiveness of recovery plans at least every five years. Conservation advice 13.6 The Minister must ensure that there is an approved conservation advice for all listed threatened species and ecological communities at all times while the species or community remains listed under the EPBC Act. This general rule applies with the following exceptions: extinct species, conservation dependent species; or species and ecological communities that are already covered by a recovery plan that is in place or in preparation. 212 Independent Review of the EnvIRONMENT PROTECTION and BIODIvERSITy CONSERvATION ACT 1999

3 13.7 Conservation advice includes practical on-ground activities that can be implemented by local communities, natural resource management groups or interested individuals, such as landholders. Conservation advice may also include broader management actions which can be undertaken by organisations such as local councils, government agencies or non-government organisations, to protect the species or ecological community at a regional level. Conservation advices are a simpler form of documentation than recovery plans and provide for more timely conservation actions as they are required upon listing Once approved, a conservation advice has a number of legislative implications, including that the Minister must have regard for the conservation advice when: making a declaration that actions do not need approval under Part 9 of the Act; entering into a bilateral agreement; deciding on whether to approve an action which will have, or is likely to have, a significant impact on a listed threatened species or ecological community; and issuing permits under the Act. Key threatening processes (ktps) 13.9 Under s.183 of the Act, the Minister must establish a list of KTPs. 1 A threatening process is defined in s.188 of the Act as a process that threatens or may threaten the survival, abundance or evolutionary development of a native species or ecological community The listing of a threatening process as a KTP is a key initial step to addressing the impact of a particular threat under Commonwealth law and developing and supporting efforts to ameliorate the impact of those processes. The listing of a KTP is a precondition for a decision to prepare a threat abatement plan (TAP) Any person may nominate a threatening process for listing under the EPBC Act. An invitation to nominate is extended by the Minister each year ahead of a new assessment cycle. Nominations received during the invitation period are considered by the TSSC for inclusion on the proposed priority assessment list. The Committee may also include any Committee-nominated KTP on the proposed priority assessment list, if it believes its assessment and listing is warranted. Nominations included on the Minister s finalised priority assessment list are assessed by the TSSC, and made available for public and expert comment. After assessment, the TSSC s advice is forwarded to the Minister, who decides whether a threatening process is eligible for listing under the Act. Threat abatement plans (taps) Once a KTP is listed under the Act, the Minister must decide whether to develop a TAP 3 for that KTP. A TAP must be developed if the Minister believes that having and implementing a TAP is a feasible, effective and efficient way to abate the threat. For administrative efficiency, the TSSC provides a recommendation regarding a TAP to the Minister at the same time as it provides advice regarding the associated KTP. Consequently, the Minister makes a decision regarding a KTP and the need for a TAP at the same time. Technically, however, the Minister must make a TAP decision within 90 days of a KTP listing TAPs establish a national framework to guide and co-ordinate Australia s response to KTPs listed under the Act. The plans must provide for research, management and other actions needed to ensure the long-term survival of native species and ecological communities affected by KTPs and actions to reduce the impact of the listed KTP on native species and ecological communities more broadly Under s.270a of the Act, the decision not to have a TAP for a KTP must be reviewed every five years. Under s.279(2) of the Act, the Minister is required to review the effectiveness of TAPs at least every five years. 1 The current list of Key Threatening Processes is available at: 2 Environmental Protection and Biodiversity Conservation Act 1999 (Cth) s.188(3). 3 A list of approved Threat Abatement Plans are available at: 4 Environmental Protection and Biodiversity Conservation Act 1999 (Cth) s.270a. Chapter Thirteen BIODIvERSITy conservation, recovery planning and threats management 213

4 13.15 To date, the TSSC has recommended a no-tap decision for four out of 17 KTPs. Three of these decisions are currently under review, and the fourth is due for review by Critical habitat The Minister must maintain a register of habitat critical to the survival of a listed threatened species or a listed ecological community the Register of Critical Habitat. 5 The 2006 amendments require that, in considering whether to list a habitat, the Minister must take into account the conservation benefit of listing the habitat. If the habitat is not located on Commonwealth land, the Minister must also be satisfied that reasonable steps have been taken to consult with the landowner of the property Regulation 7.1 specifies that the Register must contain information to identify the habitat, including its location and extent and the reasons the habitat was identified for inclusion on the Register Since the Act came into force, critical habitat has been listed for five threatened species. There are no ecological communities for which critical habitat has been identified. Biodiversity conservation on private land The conservation of biodiversity on private land is provided for under Part 14 of the Act, via voluntary conservation agreements. A conservation agreement is an agreement between the Minister and another person for the protection and conservation of biodiversity in an area of land or sea A conservation agreement identifies activities that promote the protection and conservation of biodiversity, World Heritage, Commonwealth and National Heritage Places, Ramsar wetlands and the environment on Commonwealth land and marine areas There are other, non-legislative, tools available to protect matters of national environmental significance that have important links to the Act. Such mechanisms include stewardship programs, tax incentives, programs for direct acquisition, conservation covenants and initiatives under Caring for our Country. Key points raised in public submissions Recovery Planning The need for governments to take positive recovery action is reflected in Australia s obligations under Article 8(f) of the Convention on Biological Diversity, in that Australia shall, as far as possible and appropriate: rehabilitate and restore degraded ecosystems and promote the recovery of threatened species, inter alia, through the development and implementation of plans or other management strategies A number of submissions argued that resourcing for the drafting and implementation of recovery plans should be mandated in the Act, and the process should begin as soon as a taxon, community or process is listed It was also argued that the process of recovery planning would be aided by strict deadlines for action and efficiencies may be gained if other listed threatened species and ecological communities with similar ecological requirements could be identified and effectively incorporated in a common recovery process. 5 The Register of Critical Habitat is available at: 6 The Convention on Biological Diversity, done at Rio de Janeiro, 5 June 1992 (Biodiversity Convention), Art.8(f). 214 Independent Review of the EnvIRONMENT PROTECTION and BIODIvERSITy CONSERvATION ACT 1999

5 Priority setting Submissions noted that the institutional framework of the Act in effect prioritises conservation efforts through prioritising the assessment, and therefore listing of threatened species and ecological communities. In making a decision about whether to prepare a recovery plan for selected species, recovery actions are further prioritised WWF noted that: Recovery planning is often hampered by lack of resources, time delays, and also the consideration of socio-economic interests rather than focusing on the science. Recovery planning should be mandatory, with sufficient resources allocated to ensure that it is done effectively The need to improve the effectiveness and implementation of recovery actions was of particular concern. As WWF noted, while the number of recovery plans was increasing, there are insufficient funds to implement the actions contained in the plans Submissions suggested that giving funding to regional bodies to undertake recovery activities was inefficient. It was also suggested that there is a need for the Commonwealth to fund the States and Territories to implement recovery actions WWF noted that: There are currently very significant gaps in the funding of recovery plans and conservation action statements. Caring for our Country does not include the recovery of threatened species as a target (with the exception of the Tasmanian devil), therefore Federal investment in threatened species could be very low. States are not able to adequately fund existing recovery plans and there are significant time delays in the development of new recovery plans also due to funding constraints. Investment in recovery regimes needs to significantly increase in order to meaningfully address recovery of Australia s threatened species and ecological communities Several submissions argued that recovery planning efforts need to be linked to longer term funding models (greater than 12 months) to provide greater security to undertake long-term recovery actions. Recovery programs should be reviewed more frequently than the current five year timeframe. Ideally, they should be reviewed annually or biennially to ascertain the success of the program and whether variation or adaptation is required, perhaps against a set of agreed key performance indicators Submissions supported approaches taken by States and Territories in prioritising recovery strategies. Queensland s approach to the conservation, management and recovery of native species, the Back on Track species prioritisation framework was mentioned as a model intended to better reflect the level of management required to conserve Queensland s native wildlife. Species are prioritised using multiple criteria to allow the identification of species that are in trouble, and those which have the greatest chance of recovery. 11 The New South Wales Threatened Species Priorities Action Statement is an integrated approach for recovery of threatened species in urban and rural land use planning and decision-making, and landscape restoration investments The role that recovery plans might play in the face of the potential impacts of climate change was raised in a number of submissions. Recovery plans, where they are in place, were seen as an important mechanism in protecting species and ecological communities and this role would be of greater importance in dealing with climate change. 7 Submission 181: WWF, p Submission 181: WWF, p Submission 201: Government of Western Australia. 10 Submission 181: WWF, p Queensland Government, Back on Track species prioritisation framework (2008) Queensland EPA Website at 30 April Department of Environment and Climate Change, New South Wales Threatened Species Priorities Action Statement (2007) at 30 April Chapter Thirteen BIODIvERSITy conservation, recovery planning and threats management 215

6 13.33 The Humane Society International (HSI) submitted that: Statutory recovery plans must be negotiated for all species and ecological communities with States and Territories where their range falls wholly or partly outside the Commonwealth jurisdiction to avoid the common circumstance where a recovery plan has not been enacted for a species or ecological community because its range is not wholly within the Commonwealth jurisdiction. 13 Critical habitat Submissions were critical of the lack of utilisation of the Register of Critical Habitat by the Australian Government. The Australian Conservation Foundation (AFC) noted that: While the Act provides for an offence for knowingly damaging critical habitat for a listed threatened species or ecological community, 14, few critical habitats are listed on the official register, meaning that most habitat that is critical for the survival of a threatened species or ecological community is not being given the highest level of protection It was argued that critical habitat for threatened species should be automatically listed on the Register of Critical Habitat once the species is listed and that the Act should require the development and implementation of management plans for habitats on the Register of Critical Habitat. Further, it was submitted that there should be a requirement to gazette critical habitat areas of each recognised threatened species and ecological communities and an on-going process of review to ensure that newly identified critical habitats are protected A lack of resources would appear to be one of the reasons why critical habitats have not been identified and registered under the Act. This is partly because of the requirement to map critical habitat in order for it to be registered HSI made a number of suggestions regarding provisions for critical habitat under the Act: the definition of critical habitat should be amended to include climate refugia for threatened species; it should be mandatory to list critical habitat for EPBC-listed threatened species and ecological communities on the EPBC Register of Critical Habitat; critical habitats for migratory species should be eligible for listing on the EPBC Register of Critical Habitat; critical habitats for a threatened species or ecological community should be identified in the conservation advice that must be in place for every threatened species and ecological community; and protection for critical habitats should be strengthened in Commonwealth, State and Territory jurisdictions Some submissions argued that the lack of use of the critical habitat provision was due to the reluctance of the Department to make decisions that might impact on private landholders, and in part because the Department considers they do not provide effective protection. 18 The somewhat circular definition of critical habitat habitat that is critical to the survival of a listed threatened species or ecological community was questioned. 19 The Queensland definition was suggested as being worthy of consideration: A critical habitat may include an area of land that is considered essential for the conservation of protected wildlife, even though the area is not presently occupied by the wildlife Submission 182: Humane Society International, p Environment Protection and Biodiversity Conservation Act 1999 (Cth) s.207b. 15 Submission 194: Australian Conservation Foundation, p Environment Protection and Biodiversity Conservation Regulations 2000 (Cth) Reg Submission 182: Humane Society International, p Submission 182; Humane Society International, p Additional Submission: The Australian Network of Environmental Defender s Offices. 20 Nature Conservation Act 1992 (Qld) s.13(2). 216 Independent Review of the EnvIRONMENT PROTECTION and BIODIvERSITy CONSERvATION ACT 1999

7 13.39 Submissions also argued that the value of identifying and listing critical habitat will be of greater importance in the face of the potential impacts of climate change. Several submissions and a workshop convened by the review on landscape planning noted that defining and mapping critical habitat could assist in mitigating against cumulative impacts. Critical habitat, particularly those areas outside the reserve system, may have a key role to play in providing refuge or corridor areas for species where the impacts are uncertain or unknown WWF noted that: Protection of future critical habitats in plans was almost completely lacking, and this flaw must be addressed as a matter of urgency in light of climate change. 21 Conservation advice Conservation advices were generally regarded by submissions as desktop recovery plans and received support due to their mandatory nature and their timely availability However, HSI argued that conservation advices do not take away the need to prepare more detailed recovery plans, so it should not be an either/or approach. 22 HSI went on to recommend that: The Minister should not be able to contravene approved conservation advice, (particularly if recovery plans are no longer mandatory) and publication of approved conservation advice should also be a requirement for conservation dependent species (and any other threat category that may be added) The ACF agreed that conservation advice cannot replace the need for detailed and co ordinated recovery plans and TAPs that detail responsibilities, funding and schedules for implementation of on-ground activities and policy co-ordination for the recovery of species and communities and the management of KTPs It was also noted that there is often a link between national recovery plans and State and Local government planning regimes so that, once a recovery plan is in place, activities must be undertaken to implement it, with the additional benefit of attracting funding. There is no similar link to conservation advices and this may result in a lack of incentive for implementation of conservation advice. ktps and taps Submissions viewed the identification of KTPs as an important step in highlighting the impact of these processes on biodiversity conservation and were supportive of listing KTPs. The ACF noted that the existence of a clear integrated framework for abatement that focuses squarely on biodiversity requirements and outcomes is critical to achieving the goals of the Act, and argued that: The current list of KTPs does not encapsulate the full range of processes that are actually threatening Australia s biodiversity and which need immediate management attention. For KTPs and their associated Threat Abatement Plans (TAPs) to effectively operate to address these threats and pressures, a systematic process to identify KTPs integrated with major biodiversity protection programmes is required. Currently the nomination of KTPs is reliant on public nominations through the annual cycle within any conservation themes as determined by the Minister Submissions noted that even where a KTP has been identified, the Act does not require a TAP to be developed. It was noted that there are currently 17 KTP s listed under the Act and only 10 approved TAPs. Submissions highlighted the lack of a TAP for loss of climatic habitat caused by anthropogenic emissions of greenhouse gases. 21 Submission 181: WWF, p Ms Nicola Beynon, Senior Program Manager - Humane Society International, Senate Committee Report, Committee Hansard, 10 December 2008, pp Submission 182: Humane Society International, p Submission 194: Australian Conservation Foundation, p Submission 194: Australian Conservation Foundation, p.7. Chapter Thirteen BIODIvERSITy conservation, recovery planning and threats management 217

8 13.47 Submissions observed that a number of nationally significant threats have not been listed under the Act despite their recognition in a suite of national biodiversity policy documents The Australian Network of Environmental Defender s Offices (ANEDO), supported by a number of other submissions, argued that: The clearing of native vegetation in Australia has a range of well recognised and serious environmental consequences. These include: destruction of biodiversity habitat, degradation of soil, degradation of water quality, increased salinity, release of greenhouse gas emissions, and adverse effects on ecosystem services and broader catchment health. The Australian Government s State of the Environment Report (2001) identified land clearing [as] the single biggest threat to wildlife in Australia Currently the nomination of KTPs is reliant on public nominations through the annual cycle within conservation themes as determined by the Minister. The TSSC currently has the option of including TSSC nominated KTPs on the proposed priority assessment list should they consider assessment is warranted. Submissions argued that there should be a provision in the Act for a mandatory requirement to identify KTPs (through a comprehensive, systematic process as part of a broader biodiversity protection program) Many submissions raised the issue of the ability of the current recovery planning and threat abatement framework to deal with climate change and the potential impacts climate change may have on biodiversity. 27 Submissions noted that there was a need to have tools in place that are able to adapt to the uncertainties of climate change and the identification and listing of KTPs should be seen as a priority, particularly as the current regime under the Act allows for current as well as projected threats to be listed. Submissions suggested that threats likely to be associated with climate change, such as altered fire regimes, changes to hydrology and sea level rise should be listed. TAPs were also viewed as having a key role due to their broader nature, particularly as climate change is likely to change the nature of the threats to biodiversity. Senate inquiry into the operation of the EPBC Act The Senate s Standing Committee on Environment, Communications and the Arts Inquiry into the operation of the Act commented on the provisions for recovery planning under the Act. The Committee concluded: That recovery plans play an important role in detailing steps to be taken to prevent the continued decline, and assist in recovery, of listed threatened species and ecological communities The Committee expressed concern at the lack of application and resourcing provisions for the critical habitat provision and the failure to list critical habitat on the EPBC Register of Critical Habitat, despite their identification as critical to the survival or recovery of threatened species or ecological communities in recovery plans In their Additional Comments to the Senate Committee Report the Australian Greens noted that, in relation to the limitations of provisions of the Act in dealing with cumulative impacts and providing for landscape connectivity that: Commonwealth responsibility for biodiversity is limited to listed threatened species and communities and migratory species. It limits Commonwealth assessment of developments and threatening processes to a narrow focus on their direct impacts on relevant matters of national environmental significance, rather than enabling comprehensive assessments and consideration of cumulative impacts Submission 189: The Australian National Network of Environmental Defender s Offices, p See e.g. Submission 135: CSIRO. 28 The Senate Standing Committee on Environment, Communications and the Arts, The operation of the Environment Protection and Biodiversity Conservation Act 1999: First report (2009) at 4 May 2009, para [5.52]. 29 Senate Committee Report, Additional Comments from the Australian Greens, p Independent Review of the EnvIRONMENT PROTECTION and BIODIvERSITy CONSERvATION ACT 1999

9 Discussion of key points Recovery Planning To date, recovery planning has been considered as a key mechanism for the recovery of threatened species and ecological communities. The Commonwealth, State and Territory governments, and the community, have invested significant effort in developing and implementing recovery plans for listed threatened species and ecological communities As of June 2009, there were 354 recovery plans in place and 259 in preparation for nationally listed threatened species and ecological communities Recovery planning has a significant place within the current group of management tools available under the Act. The approaches taken by State and Territories to prioritise recovery actions is noted, however, any decision about moving towards these types of approaches would need to consider, among other things, the transparency of allocating resources, clear analysis of the value of strategies and priority actions for each species and ecological community and an assessment of the capacity of agencies to implement the actions prescribed The traditional recovery planning approach has been for single or multi-species plans to be developed. In seeking to investigate recovery planning options to augment single-species plans, the Australian Government has been looking at recovery plans which consider the needs of all threatened species or ecological communities The recovery plan for the Lord Howe Island Group, developed in , is an example of a regional recovery plan which takes a holistic approach to managing species and communities via a multi-species threat based approach. 30 There are a number of the regional recovery plans at various stages of development. An initial review of the regional approach indicates that it can be effective in specific circumstances, and may have a greater role as a co ordination mechanism rather than as the core planning tool to identify species protection needs This spatially based approach was also supported by an expert workshop held for the review. It provides the possibility of dealing with recovery and threat abatement at a meaningful scale and therefore has the prospect of being more effective and efficiently delivering co-ordinated activity. Conservation advice Both recovery plans and conservation advices play key roles in determining the steps to be taken by the Department in the conservation and protection of listed threatened species and ecological communities. The Department advised that, following the 2006 amendments to the Act, conservation advices were developed and used preferentially, where appropriate, in some instances over recovery plans. This change was based on the assumption that some species and ecological communities could be protected without the need for a more detailed plan, and in recognition that conservation advices can be prepared quickly and recovery action taken sooner. Conservation advices can also inform future recovery plans where appropriate. 30 Department of Environment and Climate Change, Lord Howe Island Biodiversity Management Plan (2007) at 30 April Chapter Thirteen BIODIvERSITy conservation, recovery planning and threats management 219

10 KTPs and taps The issue of a TAP for the KTP relating to greenhouse gas emissions was considered by the TSSC but it was noted that a national TAP would be difficult to implement because most emissions of greenhouse gases are produced outside of Australia, and a reduction in emissions would require complex national and international negotiations. 31 This reasoning underlies the difficulty with developing a TAP. The scale of the threatening process is often such that it is difficult to develop and implement effective actions to abate the threat The issue of including climate change and land clearance as new triggers under the Act is discussed more fully in Chapters 7 and 8 of this report. There is a need for better linkages between Commonwealth threat abatement planning, recovery planning and funding initiatives. There is also a need to develop an approach that integrates these activities at a scale with which people can engage directly Plans at a national scale are often not specific enough for detailed on-ground decision-making. It is possible that the development of recovery and threat abatement strategies at a regional scale will facilitate more tangible environmental outcomes. The sum of the regional strategies should aid biodiversity conservation at the national scale. Landscape approaches to protecting biodiversity Key points raised in public submissions It was argued that the current approach to protecting Australia s biodiversity, through the use of species and ecological community listings and impact assessment of projects under the Act is reactive and fragmented and takes a snapshot view of conserving species and ecological communities in situ The ANEDO submitted that: This failure stems from a narrow-sighted approach that tries to deal with issues discretely while ignoring the intricate interactions and relationships that exist within an environmental context CSIRO submitted that the focus on protecting matters of NES fails to take into account the broader nature of ecological processes or recognise the role of biodiversity in maintaining ecosystem processes. Such processes and services are often underpinned by more widespread and/or abundant species and communities The Environment Institute of Australia and New Zealand argued that: The EPBC Act is a strong framework for the protection of listed threatened species and ecological communities on a project by project basis however, biodiversity is broader in nature and needs to be addressed holistically and in context. Impacts to overall landscapes and ecological systems, which can cause currently common species to become threatened, are not well addressed It was noted that the Act currently does not deal well with actions that separately do not have a significant impact sufficient to trigger the Act but cumulatively are having a significant impact on matters of NES. As the ANEDO argued, this is limiting the Act s effectiveness, facilitating the death by a thousand cuts scenario and not maximising environmental outcomes The issue was originally considered by the then Endangered Species Scientific Sub-Committee and reaffirmed by the Threatened Species Scientific Committee. 32 Submission 198: Australian Network of Environmental Defender s Offices, p Submission 135: CSIRO, p Submission 087: Environment Institute of Australia and New Zealand, p Submission 198: Australian Network of Environmental Defender s Offices, p Independent Review of the EnvIRONMENT PROTECTION and BIODIvERSITy CONSERvATION ACT 1999

11 Discussion of key points raised in submissions As part of progressing the discussion on landscape-scale approaches to biodiversity protection, the review convened a workshop to explore this idea. The experts who attended the workshop raised a range of issues that they believed would require consideration as part of planning for, and implementation of, a broader, landscape or ecosystem approach to protecting biodiversity. The importance of maintaining ecosystem function and resilience in order to facilitate adaptation, particularly in the face of predicted impacts of climate change on biodiversity was discussed. However, experts were keen to ensure that the current focus on climate change issues did not detract from the need to continue to address existing threats to biodiversity, such as changed disturbance regimes, invasive species and land clearance Workshop attendees also discussed the need to expand the core objectives of biodiversity conservation from the current aim characterised as preventing any change to biodiversity (in selected places) to an approach which targets all levels of biodiversity conservation; species, ecosystems, land/sea scapes and terrestrial landscapes. It was suggested that one approach might be the addition of a new trigger to the matters of NES, such as ecosystems of national significance Landscape scale approaches to biodiversity conservation, as they were described in public submissions, would require greater engagement by the Australian Government in planning activities. This would generally involve close collaboration with State and Territory governments and agencies. Any expanded approach would need to allow for a range of land tenures and existing land uses. There would also be a need for improved environmental knowledge to support decision making If a landscape approach to protecting biodiversity was adopted in addition to the current provisions under the Act, there would also be a need to determine and subsequently define the units of scale that a landscape approach might operate at, including its boundaries and attributes In consideration of the issues raised above, there are a number of options available to the Australian Government in providing better management of impacts on biodiversity. These include: Addition of a new trigger such as ecosystems of national environmental significance ; Increasing the use of strategic assessments; and Expanding the provisions for bioregional assessments to include non Commonwealth land The interrelationship between these options and traditional approaches to threatened species recovery activities and threat abatement will need to be explored further. Chapter Thirteen BIODIvERSITy conservation, recovery planning and threats management 221

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