Draft National Other Effective area-based Conservation Measures Framework

The framework strongly focuses on private landholders but omits any mention of environmental NGOs that are already working with them to achieve biodiversity outcomes, whether they are using conservation covenants or not. Among these organisations are Australia’s UNESCO designated Biosphere Reserves which can effectively contribute to achieving the 30 x 30 land targets. We see the omission of Biosphere Reserves as a major missed opportunity and lost potential.

A recent UNESCO Policy Brief (attached) specifically recommends that countries such as Australia that participate in UNESCO’s Man and the Biosphere (MAB) program “build upon the foundations created by biosphere reserves to advance their national commitments on biodiversity and position their network of biosphere reserves as key instruments to support the implementation of the post-2020 Global Biodiversity Framework.”

Table 1 in the UNESCO Policy brief demonstrates the compatibility between the criteria for biosphere reserves and for OECMs. International jurisdictions such as Canada and India are already exploring using their biosphere reserves to meet their commitments (see attachments). UNESCO representatives confirmed this approach with us directly during conversations on K’gari in September 2023 at the XI World Network of International Coastal Biosphere Reserves conference. By targeting the buffer and transition zones of existing Australian Biospheres, the 30x30 land targets could be more effectively achieved on a scale that would enable meaningful monitoring, measurement, and impact.

In the northern states, NGOs such as The Nature Conservancy, Bush Heritage and Greening Australia work at a regional scale with private landholders to improve biodiversity values (as well as individual species). These properties are more likely to have covenants placed on them, thus fitting the criterion for Protected Areas, rather than Conserved areas, but could be used in the case studies.

In the southern states, private landholders working towards biodiversity improvements tend to manage much smaller properties, which are less likely to be covenanted. They are therefore more likely to fit the criteria for Conserved Areas. However, unless there is some recognition of the need for an overarching plan at a regional scale, including the establishment of biolinks across this patchwork of non-contiguous properties, the effectiveness of the framework will be compromised. While ecological connectivity is included in Figure 2 as an Important biodiversity value for Conserved Areas, it is not emphasized in the most relevant Principles 3 and 4.

The document is well laid out with useful and clear figures and diagrams. As noted above, we see the framework’s focus on individual landholders as being an issue. While there will be thousands of small private landholders who might be interested in the process, there is no discussion of any assistance that could be offered to them to complete the initial site assessment, let alone contribute to maintenance/management of the property should it be approved for recognition as part of the Conserved Area Network. The management requirements as outlined in Appendix 3 are likely to put off many individual landholders who are not part of a Landcare Network or members of a similar organisation that could provide advice and assistance.

To reiterate the points already raised, the framework should include some indication of priority areas on a regional scale and needs to include guidance on how Australia’s five biospheres and many conservation NGOs, including Landcare networks, might contribute to the expansion of the Conserved Areas Network and the objective of ‘management of biodiversity values in a way that achieves their long term maintenance or improvement’.

Given the long-term site management requirements including monitoring and data storage for landholdings accepted as Conserved Areas, it is anticipated that many private individuals will require ongoing support, advice and possibly resources.

Australia’s biospheres could contribute to this through awareness raising, encouraging landholders to consider applying for OECM status and/or assisting them with the completion of the assessment tool. They may also be able to provide assistance with land management arrangements once recognition as a Conserved Area has been achieved.

We also note that while the focus on terrestrial areas only is understandable, it would be helpful if the framework included some thoughts on how the government is planning to work on the marine environment. Biosphere Reserves embrace both terrestrial and marine environments and can initiate and oversee relevant partnerships to facilitate projects in both.

It is problematic that Protected Areas eligible to be included in our National Reserve System under the IUCN guidelines are different to Protected Areas under the EPBC Act. There should be more guidance about this anomaly over and above a note in the glossary.

The introduction on the website states that "the draft National OECMs Framework provides guidance on how Conserved Areas can be recognised and implemented in Australia” but there is nothing more on implementation other than “how implementation and delivery arrangements will operate in practice will be developed following agreement to the Framework. Wherever possible, implementation will seek to leverage existing jurisdictional mechanisms.”

We believe the Framework needs to go further into some of the questions that will inevitably be asked. How will DCCEEW and its successors be involved? How will state governments be involved? Will there be some sort of central repository for monitoring data? What funding and other support will be available to landholders and organisations involved in the process?

We see the absence of any discussion on these issues as gaps that needs to be addressed.

We have not had an opportunity to test the assessment tool but note that it is similar to other tools that seek to improve biodiversity values on individual properties. A minimum size in hectares should be defined to assist landholders assess whether it is worth their time and effort to undertake the process.

We think the main issue with the tool is the amount of detail asked. While it is beneficial to include all the various weblinks to useful sites to assist landholders to complete the detailed site assessment, the supporting information/evidence requirements will likely be extremely daunting for many individual landholders. This brings us back to earlier comments about the need to provide more tangible support to encourage individuals, rather than organisations, to go through the process.

There are many responses marked “not essential for Conserved Area recognition” but no comment about whether these are mandatory to be completed, or how failure to complete these sections might influence the ultimate decision.