Travelling Stock Reserves Compliance Strategy

Local Land Services delivers delivers a risk-based compliance program across the Travelling Stock Reserve (TSR) network through its TSR Program.

Compliance officers are responsible for a range of activities on TSR, including issuing and assessing permits, investigating complaints, conducting maintenance and interventions for unauthorised activities (fence line clearing, buildings or stockyards) and will take appropriate action to drive voluntary compliance amongst users. 

This compliance strategy identifies the challenges, responses and outcomes that contribute to the success of the Local Land Services Travelling Stock Reserves state-wide Plan of Management.

Compliance objectives 

A strong compliance presence is needed to support positive environmental, economic and social outcomes across the TSR network. NSW primary producers, drovers, First Nations peoples and other TSR network users should understand and abide by their obligations under the Local Land Services Act 2013 (the Act) and associated regulations relating to TSRs. 

A clear and decisive model for effective compliance services, including the implementation of punitive sanctions, provides surety and confidence for users, the community and the Government. 

The purpose of this compliance strategy is to: 

• Assist with mitigating the economic, social, cultural and environmental risks associated with TSR use.
• Maintain confidence in regulatory measures and activities designed to manage compliance risks across the TSR network.
• Reduce the incidence of unattended animals, unlawful firewood collection, dumping of rubbish and other unauthorised uses occurring across the TSR network.
• Respond to reports of non-compliance by commercial and recreational users, including those people who have chosen not to obtain a reserve use or stock permit under the Act and regulations.

Local Land Services will pursue actions to: 

• Drive voluntary compliance.
• Create effective deterrence to illegal harvesting of firewood, dumping of waste material, unauthorised use (e.g. camping) and permit condition breaches.
• Plan cost-effective and efficient operations to achieve an optimal level of compliance.
• Use extension, advisory and engagement activities programs, and, where appropriate, sanction offenders.
• Communicate compliance outcomes to the LLS Board, ratepayers, the community and key stakeholders, such as the NSW Farmers Association. 

This strategy is underpinned by a risk-based compliance framework and a focus on regulatory outcomes consistent with the LLS Strategic Plan.

Compliance challenges 

Key compliance challenges for the TSR network have been identified, and solutions to some of these challenges rely on approaches other than enforcing the law. 

• Interacting and managing expectations of TSR users, First Nations Peoples and communities and the public, including culturally and linguistically diverse (CALD) groups.
• Failure to appropriately contain livestock between sunset and sunrise where there is a heightened risk of traffic incidents.
• Preventing or removing unauthorised structures created during lawful or illegal activities. e.g. private stockyards, sheds and outbuildings, reclaiming TSR land for private use (like driveways).
• Ensuring that the entire TSR network is represented in compliance interactions.
• Maintaining a risk-based and consistent approach to permit inspections and complaint investigations, especially where intentional or opportunistic offending is alleged.
• Effective compliance interactions with users who are not required to hold a permit to access and use a TSR.
• The geographical locations of TSRs across the network, the variety in permitted uses and proximity to compliance resources.
• Timely and effective communication of intelligence driving targeted compliance operations.
• Biosecurity duty, including reporting livestock movements as part of the National Livestock Identification System (NLIS).
• Inconsistent permit processes impacting quality customer service delivery, preventing voluntary compliance.
• Reporting metrics aimed at highlighting the efficiency of targeted compliance resulting in behaviour change
• Sustained investment in compliance monitoring and responses to deter illegal, unreported or unregulated activities.

Triaging reports 

All information provided to LLS, whether from a concerned user, community member or a partner agency, will be managed under our complaint processes. Reports of illegal activity will be triaged based on the extent, veracity and timeliness of the information provided, the seriousness of the alleged activity and available resources at the time the report is received. 

• Where a report identifies that a suspect movement of livestock, or the alleged unauthorised presence of livestock on a TSR, is imminent or occurring, LLS may seek a coordinated response from:
  • The NSW Police Force:
    • Traffic and Highway Patrol Command, where the movement is alleged to be by vehicle on public roads, or
    • Rural Crime Prevention Team, where the allegation involves stock theft, deception or animals crossing more than one property (with permission or not), or
    • Local Police District where the allegation is general in nature and may include civil disobedience, public safety or a breach of the peace.
  • Local Government Authorities where the allegation involves those parts of the TSR network that feature public roads (sealed or unsealed) and other crown lands managed by the respective council (e.g. a stock route).
• Where the report identifies a significant risk to the environment, economy or the community from the suspected disposal of hazardous materials (e.g. asbestos or more than 1m3 of building waste), LLS will immediately refer the matter to the EPA for a response.
• Where a report is made of suspected illegal activity involving an emergency animal pest or disease, or an emergency plant pest or disease, LLS will immediately notify NSW DPIRD and respond following the relevant emergency response arrangements.

All reports will be responded to under an agreed model, including reports being subject to no further action.

Responding to the challenges

LLS will focus resources on delivering effective compliance outcomes consistent with the TSR Statewide plan of management and this strategy. 

Operational responses will be delivered through: 

• Supporting TSR users, the community and other stakeholders to improve voluntary compliance and maintain their knowledge, support for and understanding of the rules.
• Applying temporary closures to individual TSRs, regional routes or the whole TSR network due to poor compliance behaviours, or other identified risks, like bushfires or pest animals, that pose real (or perceived) risks to public safety, continued access or permitted commercial and recreational activities.
• Targeted intelligence-led compliance activities focused on at-risk behaviours (e.g. illegal firewood collection) that create personal and general deterrence to offending.
• Cataloguing all structures on TSRs, including approval status, priority assessing those causing the greatest harm and the use of statutory powers to remove the structures (including recovering costs and taking action against the person responsible).
• Collaborating with partner agencies, such as Local Government Authorities, the NSW Police Force, and the EPA.
• Developing quality intelligence, analysing information reported to LLS, compliance statistics and information reporting to drive compliance responses to suspected illegal, unregulated or unreported activities.
• Random and intelligence-led inspections of permit holders, including signage, record keeping, notification and surveillance activities.
• Responding to, and deterring, illegal activity by taking possession of unattended property or livestock, and, where needed, seizing items and other property being used in connection with offences.
• Constantly reviewing compliance outputs across the TSR network, especially where offending occurs across the TSR network on a seasonal basis.

Compliance officers will take an advisory approach for the first six (6) months of this Strategy (1 February 2026 to 30 July 2026), where the focus will be on extension, assistance, warnings and directions. Officers will consider the seriousness of the offending against the need for effective deterrence before deciding on the appropriate action under the TSR compliance response matrix. Given the significant implications for biodiversity, social and economic amenity and cultural heritage, from 1 August 2026 onwards, any person found to have breached the TSR rules may be issued a penalty notice in the first instance. 

Key compliance responses include: 

• Monitoring and inspections of commercial TSR users (those expected to have a permit).
• Extension and advice for all users attempting to comply.
• Targeted inspections of high-risk TSRs.
• Warnings and directions where there are legitimate reasons to believe the offence is unintentional.
• Punitive sanctions where the offence is intentional or serious harm is realised on the environmental, economic, cultural or social values of the TSR.
• Applying a zero tolerance response to any person threatening, abusing or intimidating (or trying to do so) a compliance officer undertaking compliance activity or investigating alleged offending. 

Compliance officers may apply punitive sanctions at any time in response to flagrant noncompliance or organised civil disobedience against the TSR management framework. 

LLS will support compliance officers (supervising the TSR network) to maintain the quality of compliance interactions and decision-making, through: 

• Specific and general governance and direction,
• A targeted TSR compliance response matrix, and
• Continuing to enhance their capacity and capabilities. 

LLS may consider legislative amendments to compliance officer powers and/or the TSR management framework to effectively prevent, eliminate or mitigate cultural, social, environmental or economic risks arising from illegal, unlawful or unreported uses. 

LLS may use the media, including social media, to promote the results of TSR compliance operations and positive interactions with users. 

Operational planning and reporting 

This strategy supports the creation of a statewide TSR operation designed to guide resource deployment, initiatives and actions to achieve voluntary compliance within the TSR network. 

Under the operation, targeted operational orders may be developed, focused on addressing new or emerging trends across individual TSRs or the network, in addition to those already identified through risk assessments.

Regular reporting of success under the operation will include the following key elements: 

• Measures and targets relating to regulatory activity.
• Measures and targets relating to regulatory outcomes.
• Summary reports containing strategic analysis.
• Regulator performance against good regulatory practice. 

Periodic review of the operational plan may result in a change of priority or a reallocation of resources, where and when necessary.

Extension and support services

Compliance officers interact with TSR users, including recreational users, who may be adversely affected by TSR management practices or this Strategy. Officers can refer these people to a variety of free guidance resources on using a TSR and valuing the biodiversity and cultural heritage of the TSR network. 

TSR users, especially those primary producers and drovers who move stock through the TSR network, may experience high levels of stress associated with climate change, and unpredictable weather patterns leading to increased drought, fire or flood. These users are encouraged to contact the Rural Assistance Authority for advice and assistance, rather than risk using the TSR network without the required permits. Repeated unauthorised use of a TSR may result in seizure of animals and prosecution. 

For TSR information:

• visit Travelling Stock Reserves
• Contact Local Land Services
• or call 1300 795 299 (office hours Monday to Friday).

Other support services are available to assist primary producers, drovers, and others, including financial counselling and advice, health services, and helplines for men, women and families. Officers should be aware of these services and may be able to help using the attached information. 

Dedicated TSR Rangers 

A dedicated team of TSR Rangers are attached to each region across the State. These Rangers work alongside other compliance officers to manage interactions and to ensure that significant deterrence to noncompliance can be achieved. 

Where needed, TSR Rangers can seek the assistance of specialist investigators from partner agencies (e.g. the NSW Police Rural Crime Prevention Team, DPIRD Hunting, or the Environment Protection Authority)) to investigate serious breaches, civil disobedience, or other disruptive activities where it can be shown that the offending has resulted in environmental harm and the loss of social or economic amenity or cultural heritage across the TSR network. 

TSR Rangers, along with their colleagues, are responsible for providing regular internal reports on performance against this strategy. Aggregated data and reporting may be communicated with the LLS Board, users, ratepayers, the community and partner agencies. 

Using technology 

Compliance officers, including partner agencies, use a range of technologies to monitor compliance with TSR rules and permit conditions. These technologies may include digital applications.

Compliance officers use various applications to record and deliver information in real time, including ESRI products like ArcGIS, Survey123 and Field Maps. Real time information maximises operational field activities and assists in reducing the burden on compliant businesses. 

Other technologies used include: 

• Unmanned aerial vehicles (UAV)
• Satellite and digital landscape mapping
• Water and environmental sampling kits
• Fixed and mobile surveillance devices
• Contemporary intelligence databases.

Achieving outcomes 

The intended outcome of the compliance strategy is to create optimal voluntary compliance with the TSR rules.

Specifically, to support economic growth across primary production, deliver quality recreational and public health outcomes, and prevent the loss of biodiversity and cultural heritage, we will: 

• Monitor compliance with the use of TSRs.
• Increase awareness and foster compliant behaviour through extension, advice and engagement.
• Assess and report on whether the interventions are having the desired effect on the intended outcome.
• Provide effective compliance responses to illegal activity that threatens to undermine the social, environmental, cultural and economic values of the TSR network, and
• Discourage and reduce serious and recidivist offending. 

Compliance officers and other partner agencies may use a variety of sanctions to ensure users and the community follow the rules. These include the use of warnings, directions, seizures, and punitive measures, such as penalty notices. 

Escalation to punitive enforcement measures will be used to deliver outcomes where other tools, such as extension and engagement activities, have been ineffective.

LLS works to improve the skills, attitudes and behaviour of TSR users, and the broader community, including those with no specific interest in TSRs. Reporting how we achieve that change, assists at an individual, industry and community level to drive voluntary compliance. 

Outcomes are achieved using short, medium and long-term goals that challenge quality biodiversity, environmental, cultural and amenity values through the exploitation of TSRs. 

Short term (January 2026 – December 2026) 

• Maximising voluntary compliance amongst users, especially primary producers, graziers and drovers, neighbouring landholders and those who access TSRs for recreational pursuits.
• Targeted approach to drive firewood harvesters, hunters, and neighbouring landowners to change their practices, to reduce the impacts of unlawful activities on TSRs.
• Use media, including CALD media organisations, to promote the compliance outputs of LLS, particularly the level of voluntary compliance across the TSR network.
• Review compliance trends, emerging risks and intelligence to deliver targeted compliance operations for at-risk persons or businesses, from January 2027. 

Medium term (2027 to 2030) 

• Focus extension services on those actions that impact the TSR network consistently with the TSR Statewide plan of management and statewide or regional pest animal and weed plans.
• Implement reporting metrics to drive better understanding of compliance across commercial users, especially those required to obtain a permit.
• Intelligence-led focus on those persons showing lower levels of compliance, especially those who are intentionally non-compliant.
• Apply significant enforcement responses to intentionally non-compliant users, to drive effective deterrence.
• Detect and deter illegal operations by seizing property, animals, or plant and equipment (e.g. timber processing equipment and vehicles) connected to serious offences.
• Use targeted campaigns, including CALD media organisations, to promote compliance operations, particularly where serious offending is the subject of compliance operations.

Long term (Past 2030) 

• Demonstrated change in skills, attitudes, behaviours of primary producers, graziers, drovers and other users of TSRs across the state, especially CALD communities.
• Voluntary Compliance consistently maintained above pre-2026 levels, with the use of punitive sanctions decreasing year on year (since 2026).
• Assist in protecting biodiversity, cultural heritage, social and economic benefits across the TSR network.
• Communications including media outlets and social media platforms to promote our compliance activities, operations and successes.
• Develop enhanced reporting metrics to improve our understanding of compliance across the TSR network.
• Providing regular compliance updates to users, peak bodies and associations and advisory groups, highlighting operational successes, trends and future actions.

Dispute management 

With the new approach to compliance comes potential impacts on business practices and a reasonably foreseeable risk that some users of TSRs may seek to challenge the validity of our enforcement measures. Quality dispute resolution, evidence-gathering procedures and use of technology need to be in place. 

Complaints 

Where a complaint of unethical or unprofessional behaviour is levelled against an individual (or group) of compliance officers, existing complaint handling processes will be utilised. 

Where a complaint is levelled against a compliance officer from another NSW regulator, such as the NSW Police Force or Local Government, the relevant regulator’s complaint handling processes will apply. Where a complaint about an officer from another NSW regulator is made to LLS, we will refer that complaint to the relevant regulator for their action. 

Existing dispute resolution mechanisms are already in place for penalty notices, where an internal review of the circumstances surrounding the issue of a penalty notice is undertaken. Where a person disagrees with the review decision or the decision to issue a penalty notice in the first instance, the court election process allows the NSW court system to adjudicate on the veracity of the claim that the penalty notice was reasonable and necessary. LLS applies an independent prosecution review process that assesses the circumstances of all matters before issuing a court attendance notice. 

Use of body worn video 

The use of Body Worn Video (BWV) is a common officer safety tool used by NSW regulators, and BWV has shown exceptional potential in managing officer and client safety and performance-based disputes. 

Compliance officers may use BWV to record incidents and conversations with primary producers, graziers, drovers or other TSR users, or other persons when undertaking operational activities. 

Compliance officers will wear the BWV so it is clearly visible and may activate the BWV at their discretion, including having the camera on, but not recording. The LED screen shows the person being spoken to what the camera may record. If an officer activates their BWV, they will inform the person they are speaking with that the device is on and not recording (people will still see themselves on the screen) or that the device is on and recording. 

A BWV may be used to record a conversation. If an officer chooses to record a conversation, they are required to seek your consent, unless you are in a public place. All BWV recordings are secured and only used in specific circumstances.