Australia’s Native Vegetation Framework
Consultation draft
February 2010
Department of Environment, Water, Heritage and the Arts
Officer Submission
Prepared for
Natural Resource Management
Ministerial Council (NRMMC)
Submission
Australia’s Native Vegetation Framework
Consultation draft February 2010
Overview
The Eastern Metropolitan Regional Council (EMRC) is a Regional Council formed by six
member Councils, the Town of Bassendean, the Cities of Bayswater, Belmont and Swan
and the Shires of Kalamunda and Mundaring, to undertake activities on behalf of the
region.
The EMRC is an innovative organisation engaged in natural resource management at a
number of levels through the delivery of services, activities and projects in partnership
with the member Councils. The EMRC and member Councils are active partners in
undertaking activities that benefit the health and sustainability of the region and work
closely with their communities to progress environmental restoration and improvement
programs.
The EMRC has considered the “Australia’s Native Vegetation Framework Consultation”
draft at officer level.
Introduction
The state of Australia’s native vegetation is summarised in detail in this document. It
highlights issues relating to land degradation and discusses actions to be implemented
that have the potential to minimise or reverse land degradation and covers legislation,
policies and programmes to protect native vegetation.
The document credits the revegetation and restoration of catchments as providing
multiple benefits for the environment. Benefits of maintaining existing native vegetation
cover was understated. Preserving vegetation is of more benefit to ecological heath than
rehabilitation efforts. The document indicates there are inclusions for incentives to
encourage businesses to increase and maintain ecosystem services; this document
needs to define these incentives. It is recommended that the document put emphasis on
the importance of maintaining existing vegetation cover as this has not been covered in
any detail.
Aims
It is recommended that the principles outlined in this document be stronger in relation to
vegetation management, for example “…the first aim is to avoid loss; and if that is not
possible, then to minimise loss; and if vegetation loss is unavoidable, that loss should be
managed to maintain ecosystem function”. It is recommended that the principles aim to
avoid loss; the compromise is too great to environmental integrity if just maintaining
ecosystem function is considered as an alternative to avoiding loss.
Threats
Climate change was mentioned several times as a threat to the composition structure
and functioning of native vegetation, however the document ignores major threats to
these functions from clearing for urban and industrial/commercial development, road
infrastructure and mining. It is recommended that the framework address all the major
threats to composition structure and functioning of native vegetation.
The document cites that “Business as usual (BAU) to managing biodiversity is unlikely to
be sufficient response” to the impacts of climate change. This statement does not reflect
the seriousness of the global situation in relation to climate change. BAU is more than
an insufficient response it is irresponsible for any government to entertain BAU as a
response action…additionally it is unclear what a net national increase in vegetation
extend means. It is recommended that the document reflect the serious negative impact
land clearing has on climate change and outlines the definition of “a net national
increase in vegetation”.
Actions and responsibility
Undertaking risk assessment, project planning and making a national vegetation
mapping accessible will allow for good regional plans and programmes to be developed.
It is not clear who will be responsible for funding the planning stage and reducing threats
etc. or for the long-term monitoring and management of the programme. The document
assigns up to six bodies as responsible for implementation of specific action, they
include three levels of government, organisations and stakeholders. It is recommended
that the document be specific about the nature and extent of responsibility for each
individual entity.
It is recommended that stronger measures for legal protection, monitoring and
compliance for the protection of Australian native vegetation be implemented.
Compliance for protecting vegetation is noted as a key tool for protection, but it is
unclear who will be responsible for resourcing and implementation of monitoring
compliance, legal and enforcement action.
Funding
Actions outlined in this document will be dependant on the “jurisdictional or regional
situation, including existing priorities, availability and leveraging of funding…” This
statement indicates that the proposed actions will continue to be constrained by the
availability of funding and is incumbent on volunteer groups to procure funds through a
grant approval system. This process in the past required a considerable amount of
administration by groups, local government and NRM bodies who support the volunteer
groups. It is recommended that funds be allocated to natural resource management
bodies opposed to, the completion of numerous applications for funds through copious
grant applications. This action would free up Natural Resource Management Officers
from administrative duties and allow more time for on-ground activities.
The actions outlined in the document cover a range of native vegetation management
approaches that include formation of policy, information collecting and sharing,
awareness and engagement strategies and regulatory approaches. It is recommended
that funding for implementation be outlined in more detail and include the role,
responsibility and obligation of corporate bodies to contribute to these cost.
Effective management and planning of native vegetation projects needs to involve all
relevant stakeholders however it does not define roles or funding available for effective
management to be implemented. Long-term implementation of projects need funding to
ensure that the goals and targets achieved are maintained.
Building capacity to understand, value and effectively manage native vegetation by all
relevant stakeholders, increasing incentives for business to support native vegetation
conservation on private land is a commendable goal. Increased resourcing is necessary
to achieve this and it is recommended that this be provided federally and managed by
NRM bodies and local governments.
Processes
The strategy needs to be clear on land use development and the protection of native
vegetation. The document states that strategic land use planning is essential and should
impose limitations on clearing of native vegetation. It is recommended that a clear
statutory process emphasising legal obligation on retention of revegetation and
maintaining conservation connectivity be implemented and followed with compliance and
monitoring measures to protect native vegetation. Historically the vast majority of
development of urban and commercial/industrial estates has resulted in the unabated
clear felling of the land.
Current conservation laws, policies and programmes have not served to conserve native
vegetation in the most part. Significant vegetation complexes are regularly cleared for
economic reasons i.e. for mining or infrastructure. It is recommended that these laws,
policies and programmes be reviewed. The focus for these laws should extend further
than broad scale clearing with stronger emphasis on protection and conservation of
native vegetation taking into consideration habitat corridors and linkages, feeding sites
for significant species.
Summary
The Australian Native Vegetation Framework Consultation draft has no significant new
information or actions which will improve the conservation or sustainable use of native
vegetation. The aims and actions proposed to achieve outcomes will be constrained by
lack of funding. Historically funding for conservation programmes for native vegetation
has been driven by NRM bodies, local government and volunteer groups applying for
grants, and this framework appears no different. Long-term and sustainable funding is
required to ensure the success of most conservation programmes which cannot be
guaranteed through the current application and approval process.
A more comprehensive discussion and action plan needs to be outlined in relation to
land use development and mining as a threat to native vegetation, in the most part this
has been ignored in this document.
Legislation, policies and programmes focused on protection, conservation and
sustainable use of native vegetation need strong compliance and prosecution
procedures.
Recommendations
The following recommendations are put forward for consideration:
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More emphasis needs to be placed on the importance of maintaining existing
vegetation cover and avoiding loss of ecosystem function opposed to just
maintaining function.
Major threats to composition structure and functioning of native vegetation need
to be addressed more comprehensively in the framework.
Emphasis needs to be made on the serious negative impact land clearing has on
climate change and outline the definition of “a net national increase in
vegetation”.
Be specific about the nature and extent of individuals/groups/organisation
responsibility for actions outlined in the framework and outline a funding support
mechanism for this.
Stronger measures need to be implemented for, monitoring, compliance and
legal protection for Australian native vegetation.
Be specific regarding who is responsible for resourcing and implementation of
monitoring compliance, legal and enforcement action.
Ongoing sustainable funding needs to be allocated to natural resource
management bodies and relevant local government authorities opposed to being
subject to grant approvals.
Funding for implementation be outlined in more detail and include the role,
responsibility and obligation of corporate bodies to contribute to these cost.
Clear statutory process emphasising the legal obligation to retain native
vegetation and maintaining connectivity of habitats be implemented and followed
with compliance and monitoring measures.
Laws, policies and programmes be reviewed and extend further than broad scale
clearing with stronger emphasis on protection and conservation of native
vegetation taking into consideration habitat corridors and linkages and feeding
sites for significant species.