Overall the workplan specifies inadequate responses and timeframes to meet its objectives. Public involvement measures are either non existent or poorly specified. Indigenous involvement and Native Title issues are not specifically addressed. The failure to protect "Of Concern" ecosystems make it impossible for the State to achieve sustainable Vegetation Management. The workplan is silent about specific measures regarding salinity and other forms of land degradation associated with vegetation loss. The workplan is also silent on fire and stock management issues.

Some of the success measures are inimical to sustainability and should be modified or deleted. Some success measures not included in this workplan are

Increases in native Vegetation

Minimisation of threatening processes

Protection of ecological process required to maintain vegetation

Measures to assess maintenance of "broad nature conservation values"

The vegetation management guidelines will not be consistently applied across all tenures. There are differences in management on leasehold, freehold and aboriginal tenures, here are difference between rural and urban locations.

No copy of the application procedures, policies or codes has been made available to the public or some local authorities. There has been no public consultation on developing comprehensive state interest guidelines above and beyond the VMA eg wetlands etc

Regional groups have not been established to date and no guidelines or handbooks have been publicly released. The success measure "% of clearing consistent with RVMPs" is hilteresque "Yes ! Ve are on target for ze final solution to ze tree problem, mein heir !" we suggest that it be replaced by "% of clearing avoided or refused". Attached is our previous comments on this process. The government needs to urgently publish draft "model RVMP" guidelines.

The State appears to have allocated $2 Million less this year to community NRM. It has provided very little funds for the ongoing development and refinement of these strategies.

There has been a lack of public involvement in the process mentioned. The state Govt should involve Local government and NGO's in this process. The Situation Statement hasn't been released or even sighted. The other relevant plans including the RFGM should be consistent with the nature Conservation Strategy not the otherway round. The local governments and NGO's with State assistance have developed the core of this strategy the "SEQROC Common Nature Classification system" and should be acknowledged.

This section must acknowledge the key roles and responsibilities played by NGOs in this area. There should be active indigenous involvement in this process of recovery planning.

This process should only proceed with adequate indigenous, local government and community involvement. We are opposed to the commercialisation or corporatisation of protected areas. The government should develop a reserve linkage plan to establish an effective nature conservation network including management plans for buffer areas around parks and reserves.

See above. The government should amend pastoral lease conditions to create leasehold protected areas in conjunction with traditional owners and other interested parties. There needs to be an urgent assessment of reserve values in wetlands, riparian areas and stock routes

See above The success measures should include "ha declared as High Nature Conservation" and "Numbers of management plans for HCV lands"

This section should make mention of the State land trust and subsidies to local government for rate relief schemes. There should be State subsidies for rate relief schemes. The VCAs should be linked to regional and subregional conservation strategies.

The state should provide some core recurrent funding for community capacity such as catchment coordinators etc.

See above The documents listed in the timeframes have not been sighted nor has there been any community involvement in their drafting.

TBA

The State and local governments should investigate core funding for this project rather than relying on NHT funding

This section should include a commitment to biodiversity and "source water" protection payments, conservation leases and general levies for bushland and waterway protection at the State level. The state should review revenues from land rents and royalty payments.

See above The state should commit to establishing a QLD landcare trust to raise funds for financial and other incentives.

These build up plan have not resulted in less clearing and in the desert uplands they may have accelerated it.

See below

The success measure should be the minimisation of vegetation clearing and the protection of endangered, " of concern" ecosystems, high nature conservation areas and lands vulnerable to degradation. The VMA if proclaimed will still leave at least 55 Million ha of vegetation "at risk" of broadscale clearing. The VMA will be ineffective at halting vegetation clearing for urban development or in coastal areas at risk of land degradation. We need an urgent local government package to address these issues. The VMA was developed without the involvement of traditional owners. The State must establish the State and regional advisory committees required under the VMA. The ERA's for Land Clearing and Housing Development need to be proclaimed.

The State government also requires a policy not to sell off or otherwise harm state owned bushland.

The Nature Conservation should be amended to allow for the listing of plant communities at a state level. This section fails to address the protection of broad nature conservation or common species and their habitat integrity.

The state should commit to halt promotion or introduction of further weed( eg leucaena or buffel grass) species and DPI must be involved along with DNR and EPA.

We need fauna monitoring, baseline wetland and riparian surveys at local and regional levels and high resolution air photography. We need a process to detect and map thickening or thinning of vegetation.

See above

The government should try to do one in four years the last one took 6 years !!!

There should be easier mechanisms and financial assistance to do this.

The workplan also fails to address sea level change, greenhouse issues, reef and costal impacts. It fails to detail any enforcement or compliance measures.