Gidgegannup Progress Association (Inc.)
Working with the Community – For the Community
c/o P.O. Box 66,
Gidgegannup 6083.
Tel.: 08 9574 7065
gpa@gidgenet.com.au
30th March, 2010
National Vegetation Framework Review Secretariat,
Biodiversity Conservation Branch,
Department of the Environment, Water, Heritage and the Arts,
GPO Box 787,
Canberra,
ACT 2601
(vegsubmissions@environment.gov.au)
Dear Sirs,
Re. The National Native Vegetation Framework Policy
Protection of Australia’s Native vegetation is of paramount importance and our
community living in the Hills of Western Australia are particularly aware of the impact of
both residential and resource development on a fast vanishing natural heritage.
Unfortunately we feel that this document does not address the issues and is not a concise
and clear blueprint to guide and enforce the preservation of one of Australia’s most
precious assets.
Concerns Regarding this Policy:
The Policy is poorly written, it proposes another layer of bureaucracy and control and
monitoring on the private and Indigenous landholder whilst failing to attach
responsibility and accountability to government managers of landholdings (which then
cause problems for the private/indigenous landholder).
It proposes an enormous amount of monitoring, administration and more policy making
with no statement as to how it will all be funded.
It makes broad sweeping statements that are far short of the reality of lack of funding and
manpower for existing land management and preservation.
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It speaks volumes about more laws and policies but fails to invest the law administrators
with the clout to punish those who defy law and policy, this framework policy is only
policy – not law.
It places another burden of Federal bureaucracy on State and Local Governments who are
already overloaded with policies (see Appendices 2 pages 54-60).
It acknowledges the effort of private landholders (page 32 – Victorian farmers spend an
average of 85 days a year protecting the native vegetation on their properties) whilst
citing clear intent to impose more law and policies without real financial relief or
compensation (pastoral and rangeland degraded environments to be under the spotlight,
whilst the lessees pay 500% rent increases).
The 5 goals it promotes are broad, non-specific and nothing new. This framework
Policy is to augment and be in addition to the 1999 policy, which is acknowledged as
having had limited effect. Vegetation continues to be degraded, fragmented,
unsustainably cleared, fire, development, changing land use, invasive species etc (page 7)
and been unable to stem the tide of environmental degradation. What assurance is there
that another policy will work? This new policy won’t even replace the 1999 one, it is to
be added to it.
This Policy is carefully worded to provide plenty of escape clauses. It simply provides
the framework for Governments and big business to go through the motion and empty
speech of considering the environmental consequences, without accountability or
consequence.
It seeks to endorse the principle of climate change (not scientifically proven) and
government policy of carbon trading by attaching a carbon value to native vegetation and
promoting its use in carbon sequestration calculations.
The Policy is poorly written and extremely irritating in its constant repetitiveness.
A closer look at the style in which the information is presented shows that the document
length would be greatly reduced from 72 pages to approx one third of this, if the
repetition were eliminated and the habit of filling only half the page with text (amidst
broad margins) were corrected. The end result is a cumbersome document which shows
scant regard for the environment which provided the paper and therefore, an inefficient
use of this resource.
Together with the comments to follow, the Document is a waste of time, tax payer
resource and the only sure outcome is more taxes to pay for the bureaucratic personnel
required to administer and create even more layers of control that work against the
landholder and tax payer. We should be simplifying the system, not adding to an already
over-loaded structure that offers no real solutions, only words we’ve all heard before.
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Specific comments:
P. 2
“Increase the national extent of native vegetation”. How is this to be achieved? By
planting or changing the definitions of Parks and Reserves” The only way the extent can
be increased is to resume degrade/cleared land and return it to its native state.
“Maintain and improve the condition of native vegetation”. This is already happening.
Volunteer groups and landholders work hard to preserve their native bushland. It’s the
Local/State Governments who allow mining/quarrying to remove vast tracts of
irreplaceable native vegetation and inappropriate development, who are most accountable
(against community opinion), yet these authorities seem to be excluded from the Policy.
P. 3
Agree with attaching a carbon value to native intact bushland environments. Do not
agree with the carbon tax and trading system.
“Build capacity to understand, value and manage native vegetation by all stakeholders”.
This is too broad a statement. Who are the stakeholders referred to here? (only
indigenous and private landholders). Who will pay for all this?
“………….include indigenous people” This is already being done by granting them
Native Title over vast tracts of land, but……….. at great cost to the European tax payer
and heavily subsidized by royalties and grants which are squandered on bureaucracy,
organizations that achieve nothing. The indigenous people are losing their middle aged
and young generations to drink, drugs, crime, European foods and lifestyle. The majority
don’t want to work their landholding, or live the indigenous lifestyle or want to know
about culture and environment.
This policy goal is idealistic and ignores the fact that current social policies have been
unsuccessful in preventing the degradation of the indigenous identity and way of life. It
also ignores the simple fact that the indigenous way of life did not originally require the
vast sums of European finance to uphold their nomadic way of life. Today, these
indigenous organizations want Title to all these lands, and European money to subsidise
them. It appears to be forgotten that the Indigenous people were a nomadic race who
hunted to survive. They did not farm and some not all, attempts to provide a farming
lifestyle for them have failed. To address this problem is far beyond the scope of this
document and is a matter for Business and Government to address. .
P. 7
Native vegetation should not be permitted to be cleared in the vicinity of major cities (eg
Perth Darling Scarp). It is simply not acceptable to have “offsets”. Offsets are just
another mechanism for permitting the clearing of 50% of native vegetation, because the
other 50% has been used as an offset. Sometimes the “offset” is another land parcel
many km’s away and of classification entirely different to that which is being destroyed.
There needs to be more focus on utilizing land that is already degraded/cleared, and
preserving the quality native ecosystems. There should be no more clearing permitted.
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Indigenous “land management practices” is nothing more than seasonal nomadic
migration according to food source availability. No permanent habitation or settlements,
harvest of the environment according to its resource level, subsistence existence, no
cultivation, no clearing, small family group/clan occupancy levels, no pollution, the use
of fire to catch food. European settlement never intended to live in this manner. The
true indigenous way of life did not need to be subsidized by European money to succeed.
P. 8
“Identify/protect key areas………” Who will fund this? The D of Environment and
Conservation is severely under funded, we are all overloaded by taxes and inefficient
governance. The native forests are being logged for the value of charcoal. Pristine bush
is being destroyed for quarrying and residential development.
“in relatively undeveloped areas….. plan development to retain maximum native
vegetation”.
What about those who degrade by neglect?. Define “relatively
undeveloped areas”
“prevent over-clearing” What about illegal clearing? The use of the word over-clearing,
merely leaves the door open for conjecture and debate (and legal escape) on what is over
or justifiable clearing. It doesn’t offer protection or significant consequence.
“pastoral rangelands” the lessees have received 500% rent increases. Now this policy
addresses the degradation of their environments (rightfully too in some cases). Who will
pay their compensation when they are forced to destock or change their livestock
management practices to comply with Government laws. Unfortunately, whilst the
mining company can afford court appearances and fight the system, the small/family
business cannot, and will be adversely affected. Landholders pay huge amounts of tax
and rates. Now they will be forced to shoulder the burden of more policy and monitoring.
These non-specific feel-good goals are too broad. Far better, something more specific
such as “preserve all bushland in the vicinity (eg 50km) of major urban centres”
P.10
“offsets” comment as below. This provision merely allows the proponent to clear 50%
of native vegetation because of capacity to “offset”. True offset is only by
comprehensive rehabilitation of degraded land (not vertical quarry slopes to which access
is forever denied). Only full replacement of that destroyed will maintain “the extent of
native vegetation”. An offset arrangement will continue the decline in the “extent of
native vegetation”. As per comment on page 2, “the extent of native vegetation” will
only be accomplished by the rehabilitation of cleared land and its return to its native state.
P. 12
“Precautionary principle of incomplete knowledge”. Yet Governments still allow PER
documents to be based on desktop surveys years/decades out of date and no compulsory
continuous 12 month surveying of flora and fauna.
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“mature and diverse ecosystems” should be quarantined from all clearing activities. Their
value lies in the time in which they were developed. They are irreplaceable.
P.17
Preservation and protection of native vegetation is dependant on other Government
policies that discuss urban sprawl, infill development, better use of urban cleared zones,
water management.
Policies such as this one do not address the fundamental truth and need for change in
areas such as agriculture (growing rice in Australia is unsustainable, irrigation is no
longer a compatible activity in many areas where it compromises the health of local and
regional hydrological systems, some areas should never have been cleared for cropping
and should be returned to their native state) and development/urban occupancy patterns.
Climate change is not proven.
P.19
“Continued intensification of natural resource use”. This activity comes at great expense
of the native environment. It is high time that the value of the natural environment was
factored in as a significant input cost to the extracted product. This country is selling its
resources and food too cheaply. The environment cost and consequence is something we
have yet to really appreciate or understand. The abuse of our soil and water means the
reckoning is yet to come. Increased market value will promote the development of more
efficient processing practices and minimize waste.
Again, this Policy glosses over the real underlying issues and creates a band aid effect,
failing to treat the symptoms because it does not address the source of the problem.
P.20
National Strategy 1996. National Framework 1999. This National Policy 2010. Same
product just re-badged and re-named and padded out with more empty word. Nothing
new, no new action, just more bureaucracy.
P. 22
“Net increase”. Another cleverly worded phrase that is not defined. It implies that
native vegetation can be destroyed where convenience or money is at stake, as long as
native vegetation is preserved elsewhere, without the requirement of equal or greater
value. It assumes it is ok to clear native vegetation on the Darling Scarp (50km from
Perth CBD) as long as native vegetation is preserved elsewhere (never mind that it might
be 200km away or of lesser value by way of fragmentation and exposure to weeds,
degradation). This Policy is just that, not enforceable law.
“Where possible, the use of offsets”. A weak comment that allows avoidance of Policy.
The Policy does not define a suitable offset.
“First aim is to avoid loss, minimize, maintain existing systems, then offsets”. This
amounts to nothing more than escape clauses.
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P.25
More broad sweeping statements without the detail or understanding of implementation
or funding.
P.26
Policy without the clout of consequence for illegal activity. No punishment is defined.
More bureaucracy for private/European landholders who are also required to subsidize
the indigenous landholder
P.7
Existing carbon rating systems favour non-native monolithic forestry and not the
protection of mature/existing quality native bushland ecosystems of diversity of flora and
fauna.
P.28
Who will pay for all this?
P.29
20% indigenous landholders, 60% private landholders. Where is the other 20% including
Government reserves, leases, mineral tenements etc ? Is the Government landholder
excluded from this policy of good land management practice? We all know that the
Government is a poor neighbour in terms of managing fire, trespass and invasive feral
flora and fauna species.
P.32
“Continued clearing of high value (definition please) vegetation may be occurring”. Of
course it is occurring. It’s happening on the doorstep of Perth and other cities and towns.
It is this head-in-the-sand desktop approach that makes these Policies a waste of time and
money and autonomous from the grass-roots issues. Therefore, unworkable, unrealistic,
impracticable and burdensome.
These policies victimize the smaller business/family landholder, by burdening them with
more laws, more monitoring, more paperwork, more bureaucracy, punishment,
officiousness and no compensation for deprivation of land use and activity (pastoral).
P.33 – 45
Feel good case studies.
P.46
Monitoring every 5 years is out of sync with Federal/State Government 4 year terms.
Based on jurisdictional reporting in the 2nd year and actions/targets in the 4th year of the 5
year period. Therefore, reporting occurs only every 5 years. This is vastly inadequate.
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P. 47
“Adaptive management” Broad statement lacking the specifics, detail, real solution and
manner of implementation. It is merely fashionable new terminology and by-words.
“Sound science” should not be based on desktop studies as these are years/decades out of
date and assumptive and incomprehensive.
“Changing circumstances associated with climate change”. Climate change is not proven
beyond doubt, circumstances also change due to poor policy frameworks, poor decisions
and poor implementation practices and poor land management procedures. Climate
change is not responsible for everything. It is not responsible for the errors and poor
judgment of humans. Blaming Climate change is a cop out. There is far more damage
caused by incompatible agricultural practices, pollution, land clearing, mining,
incineration, urban development and sprawl etc.
P.49
“Laws to restrict broad scale clearing”. Restrict? Not prevent? Another broad statement
that fails to protect quality native vegetation. Laws without significant penalties. Laws
without the administrators being granted the resources to investigate and prosecute.
Funding schemes for private landholders to enhance protection of native vegetation are
restrictive, demand titular convenanting, limited in scope and funding and are short term.
P. 50
More accolades for institutional reform that is nothing more than name changing, rebadging, and comes with none of the responsibility for action or accountability for
inaction, poor outcome performance or misuse of tax payer funding.
Summary:
Vast tracts of native vegetation are being cleared for residential and resource
development. Particularly in the Metropolitan and Outer Metropolitan areas. With
particular reference to the Perth Hills in Western Australia, we are extremely concerned
that this proposed development is now encompassing the Scarp. There is no overall
plan, but Resource and Residential development being proposed piecemeal, without
consideration to the cumulative impact.
Quarries are being proposed with 100 year and 50 year approvals. How can we forecast
what our world is going to be like at that time. We are selling the future. We ask that
Government explore the feasibility of moving the Resource area away from the Scarp,
possibly further inland. This would necessitate the use of rail transport and depots to
receive the commodity. Our road network could not cope with the increased truck traffic
through settled residential areas. There are already problems with this.
Native vegetation in good condition should be retained in Metropolitan and Outer
Metropolitan areas. This is a habitat and feeding ground for our native flora and a
reserve for our fauna. We will lose these if we do not make this provision. Native
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vegetation can then be enjoyed by all without having to travel hundreds of kilometers to
see it. Offsets have to be in those areas.
Native vegetation in Metropolitan areas is the lungs of that area to lose it does not add to
the health of our Cities.
Unfortunately we feel this document does not address the need. It needs to be rewritten
clearly and concisely.
We would ask that our points in this submission be taken into account.
Yours faithfully,
Gidgegannup Progress Association Inc.
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