22nd March 2013

The National Parks Association of Queensland (NPAQ) is a non-profit, non-government organisation established in 1930 to promote the preservation, expansion and wise management of National Parks and protected areas in Queensland.

NPAQ supports Option 1 – maintaining the current legislative framework, and the existing levels of protection and regulation, for protected plants in Queensland.  Co-regulation was not considered a viable option because of the difficulties and lack of certainty associated with ensuring that landholders would take full responsibility for identifying and managing threatened plants and special interest species on their land.

NPAQ supports Option 1 for several reasons:

1. Approximately 50 new plants are found in Queensland every year.  All new findings are categorised as least concern initially, however many of these progress to a higher conservation status once the Herbarium have established core population sizes, range and tenure of habitat.  Allowing the clearing of land, without formal botanical surveys, risks the loss of new plant species and all that that implies – loss of new pharmaceutical discoveries, loss of potential endangered or vulnerable species, and a compounding failure to add to the floristic diversity of Queensland.
2. For this very reason, Option 2 will not ensure that populations of threatened and commercially valuable plants are not depleted (Page 19) because it fails to take into account considerations outlined under point 1 above.
3. Removing permits for the clearing of least concern plants dispenses with the precautionary principle with potentially dire consequences.  For example, failure to survey some areas will result in a failure to identify known or new weed species, the knowledge and prompt management of which could save the State Government and landholders millions of dollars in land management costs.  This is a major deficiency in every cost calculation under each option.  By their inclusive nature, Option 1 surveys will identify more exotic species and arguably are the more cost effective option, particularly for Government.
4. Current survey requirements already have several limitations including seasonality (time of year limits the ability to find and record plant species, especially annuals), extreme weather (long periods of drought also limit the ability to find and record plant species), and variability and gaps in survey effort across many parts of Queensland.
5. The effective implementation of Option 2 is limited by previous survey effort.  As stated in point 4, it is well known that many parts of Queensland are under-surveyed, and that there are major gaps in the botanical record for this State.  Relying only on current knowledge of the location, habitat and extent of listed flora narrows the scope of survey effort under Option 2.
6. The status of least concern plants is not a permanent designation.  As threatening processes, habitat loss and climate change take their toll, some plants thought to be common may become less so.  There is no better evidence for this than the changes brought about by the Back on Track process which reviewed the status of previously listed rare species.  While many species simply moved into the near threatened category, some were reclassified as vulnerable for any or all of the reasons stated above.
7. The review clearly states – Plant biodiversity is more likely to be maintained if there is a legislative framework in place to manage threatening processes. (Page 16)  This review has been commissioned by the Department of Environment and Heritage Protection.  NPAQ would argue that DEHP should have the protection and retention of (plant) biodiversity as one of, if not its highest, priorities.
8. The best way to encourage the trade of native plants and increase the number available for sale (Page 20) is to educate the public about the role and value of native plants, and to restrict the number of exotic species available for purchase.
9. It is unacceptable to NPAQ that clearing under Option 2 could inadvertently result in the clearing of a threatened plant (Page 19).  Government has a leadership role in the protection of biodiversity and is obligated to design and implement policies and practices that reflect this role.  Nor is it viable or realistic to encourage communities to notify the department of locations where there are threatened plant populations (Page 18); few individuals have this level of identification skill, and in some cases, they may perceive that it is in their interest to not make such notifications.
10. Exempting unrestricted least concern plants from existing permitting and licensing requirements associated with harvesting, trade and reproduction (as argued under Option 2) could potentially put at risk the future viability of popular species.  Any process that potentially elevates the conservation status of a plant species (from least concern to near threatened or beyond) should not be implemented.

The disappearance of any species represents a great aesthetic loss for the entire world.  It can perhaps be compared to the destruction of a great work of art by a famous painter or sculptor, except that, unlike a man-made work of art, the evolution of a single species is a process that takes many millions of years and can never again be duplicated.