Dear Minister: You invited the Canberra Ornithologists Group (COG) to provide comments on this Bill, which replaces legislation (for the protection of biodiversity) which is more than 30 years old. However, we wish to advise that there has been insufficient time allowed to study such a large and complex piece of legislation and its implications for protecting birds and their habitats, well as to consult fully with our colleagues in other environmental groups or our membership. It is an extremely busy time of year leading up to Xmas and the holidays period for community volunteers to undertake what is a very substantial task. 

We are, therefore, not able to provide a detailed submission at this time and seek a reasonable extension of time, well after the holidays/closedown period, until the end of February 2014. It is of some significance that your department has taken many years to produce a Draft Bill, yet the community is given very little time to consider and respond to such complex legislation. In COGs view, the current legislation has failed to protect the habitats of listed threatened birds which continue to decline, and we see deficiencies in the current Draft Bill.

COG has been concerned that there has not been a proper process for independent discussion and scrutiny of such a major revision of legislation, for example, through round table discussions and a Legislative Assembly Committee process. We support the correspondence from the Conservation Council ACT Region, written on behalf of a number of community groups, seeking a significant extension of time and a more thorough and independent process of review to ensure that the legislation achieves the biodiversity objectives outlined.

yours sincerely

Conservation Officer
Canberra Ornithologists Group