Writing your submission on the National Policy Statement on Indigenous Biodiversity
- Read the Discussion Document and NPS itself if you have time. All documents you need are at MfE’s webpage on the NPS, and you can access it here
- Save the template onto your own computer or laptop and rename it with a title that will help MfE to save your submission easily. You could name it:
NPS IB Submission [your name] March 2020
- Start at the introductory section of the submission template. We have suggested the type of information you can give about your farm and how, if the NPS comes out the way it does now, it will impact (negatively or positively) on your ability to farm.
If you don’t have time to fill out the template section, you can delete the tables and just fill out this section and the cover page.
- If you want to comment in detail on some of the provisions within the NPS-IB, all the likely-to-impact-you provisions have been included within into sections of tables for you. It is handy to work with the draft NPS itself while you write your submission
Note: where it was possible, the words in the section was adapted for ease of understanding. However, many sections were copied into the template word-for-word because how councils will interpret, or implement, these words are where the problems could be.
- Only fill in the parts in the submission template that you want to comment on, and delete the rest. Be brief but specific and clear, keep it fact-based, and keep emotions out if you can.
- For any parts you support, please take the time to let them know why it is a positive step and why it should be adopted.
- For sections you do not support, explain why you don’t think it will work. If you have an alternative solution, please tell them what it is and how it will achieve better outcomes.
- It’s important to take some time to project the costs of the proposals on your farm businesses. Will you need support/funding? If so, suggest ways this could be funded.
Useful phrases to use
The central government officials who developed this policy statement had to ‘test’ their proposals against a set of factors:
- Effectiveness (their economic assessments of the cost and benefits)
- Consistency and certainty
- Acceptability (think social acceptance).
It can be useful to frame your responses using these phrases because they can use it as a guide when they need to summarise all submissions to the Minister.
“I don’t support this proposal because it isn’t flexible enough to accommodate current permitted activities on my farm” or “the way the proposal is written will not bring certainty to how I can farm.”
It’s also very useful to focus on how much time and expense this will be for you. The government officials have acknowledged they don’t know enough about the actual cost (in terms of money, expertise and on-ground practices). Your submissions will help them gain that understanding.