Victorian Parliamentary Inquiry Into Ecosystem Decline To: the Standing Committee on Environment and Planning

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

Victorian Parliamentary Inquiry into Ecosystem Decline To: The Standing Committee on Environment and Planning

Murrindindi Climate Network Inc. submission (31. August 2020)

1. Who we are

Founded in 2007, the Murrindindi Climate Network Inc. is a not-for-profit community group located in the Murrindindi Shire area. Our objectives are to promote renewable energy generation and use, to provide education related to understanding climate change and its impacts on the natural environment and the community, to provide education on pro- environmental lifestyle choices and business practices and strategies to reduce greenhouse gas emissions, including but not limited to behaviour change measures, energy efficiency measures and renewable energy technologies.

2. Witnessing drastic ecosystem decline and biodiversity impacts first hand

The Black Saturday 2009 fires had a dramatic impact on the Murrindindi Shire, its population and its natural environment with 1,539 km2 or 40% of its area burnt.

In accordance with the Code of Practice for Fire Management on Public Land (DSE 2006), the Victorian Interagency Rehabilitation Group (including staff from the Department of Sustainability and Environment and Parks Victoria) and the Burned Area Emergency Response (BAER) Team (visiting from the USA) conducted an assessment.

In summary the recommendations included (Murrindindi Shire Council, 2011):

• Catchments—Over 49% of the burnt area was rated moderate to high soil burn severity, and 52% had steep slopes and therefore increased risk of erosion and runoff. Recommendations for treatment include posting public warnings, removing debris from channels and infrastructure, developing debris basins, maintaining roads and monitoring water quality. • Forests—126,000 ha of forested Ecological Vegetation Classes were affected with 54% of total land burned to moderate to high levels. Twenty thousand hectares of high-value mountain ash and alpine ash forest were affected. Recommendations include selected salvage logging on slopes that are less than 30º inclination, are outside Leadbeater’s possum habitats and 50 m from rainforest stands; reforestation of alpine ash stands younger than 20 years; examination of over 800 km of roads and walking trails; and removal of tree hazards. • Flora—Noxious and environmental weeds are present within and adjacent to the burnt area, with the risk that weeds will invade areas not yet infested. Burning of mountain ash and alpine ash before seed maturity results in changes of vegetation types and structure, with immediate post-fire dominance by Acacias. Plants vary in their responses to particular fire regimes and fire suppression activities. Recommendations include protection of sphagnum bog areas, installation of straw tubes to stabilize the ground against erosion and survey and detection of environmental weeds. • Fauna—Many rare and threatened species were affected by the fires, as shown by the Figure 1 below. Five species listed under the Victorian Flora and Fauna Guarantee Act 1988 occur within the burnt areas: Leadbeater’s possum Gymnobelideus leadbeateri, Macquarie perch Macquaria australasica, barred galaxias Galaxias olidus var. fuscus, powerful owl Ninox strenua and sooty owl Tyto tenebricosa. Leadbeater’s possum, barred galaxia and Macquarie perch are also listed under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999. Specifications for emergency stabilisation included assessing water quality, removing barred galaxias and Macquarie perch from creeks if necessary, and installing trout barriers in barred galaxias streams. One specification included monitoring the distribution, abundance and habitat use of Leadbeater’s possum. General recommendations included future research, a review of fuel reduction and fire

1 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

management programs, the preservation of large hollowbearing trees and habitat corridors, trout removal and riparian revegetation (DSE 2009).

Tallarook Yarck Glenaroua

Kerrisdale Cathkin Molesworth MOUNT HICKEY (MOUNT TALLAROOK) Goughs Bay Alexandra Broadford Yea GOULBURN RIVER Eildon MELBA HIGHWAY Limestone LAKE EILDON

Snobs Creek HUME FREEWAY FREEWAY HUME Flowerdale Taggerty Clonbinane Rubicon Bylands MOUNT TORBRECK Wandong THE CATHEDRAL Heathcote Junction

Wallan MOUNT DISAPPOINTMENT Glenburn Buxton Enoch Point

TOOROURRONG RESERVOIR Kinglake West

LAKE MOUNTAIN Whittlesea MOUNT TANGLEFOOT Marysville Kinglake Toolangi

YAN YEAN RESERVOIR MOUNT SAINT LEONARD Narbethong MOUNT EVERARD

Saint Andrews THE GREAT DIVIDING RANGE

MOUNT RITCHIE Hurstbridge MAROONDAH RESERVOIR Epping Christmas Hills Yarra Glen Healesville Diamond Creek SUGARLOAF RESERVOIR OSHANNASSY RESERVOIR Thomastown MAROONDAH HIGHWAY UPPER YARRA RESERVOIR Mcmahons Creek Greensborough MOUNT DONNA BUANG YARRA RIVER Eltham BRIARTY HILL Warrandyte Coburg Preston Heidelberg Lilydale Warburton Brunswick Wesburn

Launching Place Kilmore East - Murrindindi Complex North Fire 2009 Victoria Overview

Threatened Fauna Top Kill / Vegetation Mortality Plan Boundary Freeway

Barred Galaxias Unburned Fire Boundary Highway Mortality Kill / Vegetation Threatened Fauna & Top Leadbeater's Possum Low Permanent Waterbody Main Road Macquarie Perch Moderate Wetland Area Collector 1:350,000 Powerful Owl High Major Water Course 063 12 Sooty Owl Minor Water Course Kilometers Disclaimer: Base layer information on this map has been sourced from Firemap 100k topographic map series. This material may be of assistance to you but the State of Victoria does not guarantee that the publication is without flaw of any kind or is wholly appropriate for your particular purposes and therefore disclaims all liability for error, loss or damage which may arise from reliance upon it.

Source: Department of Sustainability and Environment (2009) Murrindindi Complex North Fire Emergency Stabilization and Rehabilitation Plan. Prepared by the Victorian Interagency Rehabilitation Group and USA Burned Area Emergency Response Team (BAER). Page 18. Legend: Threatened Fauna: orange triangle: Barred Galaxias; yellow dots: Leadbeaters Possum; purple star: Macquarie Perch; blue cross: Powerful Owl, pink star: Sooty Owl Top kill/ vegetation mortality: dark green: unburned; light green: low; yellow: moderate; red: high.

Figure 1 Threatened Fauna and Top Kill / Vegetation Mortality – Kilmore East – Murrindindi Complex North Fire 2009

Over the past ten years, since the 2009 fires the residents of the fire affected areas in the Murrindindi Shire have by and large been trying to make a “green recovery”, rebuilding in energy efficient ways and engaging in sustainable land improvements. The post fire recovery process has also seen a high level of cooperation between Landcare, Parks Victoria, DSE/DPI (now DELWP), the local government (Murrindindi Shire Council), the Catchment management authorities and affected landowners - all pulling together trying to revegetate riparian zones and reserves and combatting weeds spreading in fire affected areas.

Sadly, with the 2019/20 fires the pressure on the natural habitat and flora/fauna species in Victoria (and other States of Australia) has increased exponentially. First estimates amounted to 1 billion animals killed (C. Dickman, 2020). However, the most recent estimates now talk about 3 billion animals killed or displaced as a more realistic number (WWF, 2020). Rising average temperatures, extended periods of drought and extreme weather events are a consequence of human induced climate change and will increase enormous pressure on

2 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759 ecosystems in the decades to come – especially if we are not able to keep average global warming at a maximum of 1.5 Celsius above pre-industrial levels (UNFCCC, 2015). Without immediate action, the extinction crisis will be irreversible.

3. Why we have grave concerns about ecosystem decline and its drivers

The Murrindindi Climate Network believes that the natural environment has an intrinsic value and that it is our ethical and moral obligation to respect it, take great care of it and actively protect it. We also have a moral obligation to future generations, our children and grand children, for them to be able to live in a healthy natural environment – with intact ecosystem services underpinning their societies and their quality of life.

For over 40,000 years, the First Nations people of Australia have lived on the land in environmentally caring ways following elaborate and sophisticated cultural traditions that were able to durably preserve nature with all its varied and diverse ecosystem services in a sustainable homeostasis (Pascoe B, 2014). In Australia since the start of colonisation, in just two centuries an enormous and often violent socio-cultural transformation has taken place leading to extensive land clearing – e.g. in Victoria of 66 % (DSE, 2011). Even today, native vegetation continues to be lost at approximately 4,000 habitat hectares per year (SoE, 2018).

Since the industrialisation, anthropogenic climate change is exacerbating ecosystem decline and is bringing global warming near levels that are endangering ANY life on Earth.

In the global context, the average Australian per capita greenhouse gas emissions of 21.5 t of CO2-equivalent (2018) are amongst the highest (Australian Geenhouse Emissions Information system: 2018: AU Total CO2-e 537.446 Mt; population 24.99 million). The Australian per capita CO2-e emissions are twice as high as the average of the Group of Twenty (G20) nations and the European Union (Climate Analytics, 2018).

4. A shared future vision must include a paradigm shift

In 1977 in their seminal report to the Club of Rome “Factor 4 – Doubling Wealth – Halving Resource Use”, the authors Ernst von Weitzäcker, Amory B. Lovins, L. Hunter Lovins established what David Suzuki calls a “priceless guide to the ways we can maintain a high quality of life while saving energy, money and the biosphere”.

Some forty (!!!) years ago, these scientists provided us with a detailed ‘how to’ guide with practical tips to improve energy efficiency, material productivity in all economic sectors, ecological tax reform, green economics to name just a few areas. All their advice is today more relevant than ever.

To have half of a chance to preserve our natural environment, stabilise the health of our climate and our ecosystems, reverse ecosystem decline and species extinction, we must urgently decouple economic growth from resource depletion - and we, as a society including the governments at local, state and federal level must take bold actions without further delay.

What we need is a Paradigm Shift and act upon it. Now.

3 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

5. Translating this paradigm shift into concrete action

5.1 Adhering to the Victorian Climate Change Act 2017 and related interim targets

The Victorian government recognises that “Climate change will increase the pressure on Victoria’s biodiversity, by exacerbating existing threats and introducing new ones (DELWP 2017, p. 11). Victoria’s Climate Change Act 2017 has established a long-term emission reduction target of net zero greenhouse gas emissions by 2050 consistent with the international UN Framework Convention on Climate Change Paris Agreement of 2015. The Act also requires five-yearly interim emission reduction targets to keep Victoria on track for the long-term target.

For the interim targets commencing for 2025-2030, the independent expert panel advice includes a 32-39% reduction in CO2-e emissions below 2005 levels in 2025 and 45-60% below 2005 levels in 2030.

The Victorian climate change targets (Climate Change Act 2017) and related interim emission reduction targets for 2025-2030 must be integral part of the Environmental Effect Statement process for public and private infrastructure projects and projects under Public Private Partnerships. Also, the compatibility test with climate change targets needs to include resource extraction and primary industries, including the forestry sector. Projects that are not able to deliver their economic performance within the interim emissions reduction targets or in a carbon neutral way by 2050 should not be permitted.

Importantly, all post-COVID economic recovery measures should equally comply with the Climate Change Act 2017 objectives and the interim emission reduction targets and all other environmental laws.

5.2 Need for a faster transition away from native timber harvesting to farm forestry and commercial timber plantations

5.2.1 Climate impacts

Post-colonization land clearing is leaving Victoria with 34% of the state’s land area covered by native forests or some 7 837 000 ha (Australian Bureau of Rural Sciences 2010). Despite the introduction of anti-clearing legislation in 1987, proportional clearance rates from 1995 to 2005 remained high and even increased in the latter part of that decade to become the highest among all states and territories in 2005 (Bradshaw, 2012).

4 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

Source: Bradshaw, 2012; Journal of Plant Ecology , Vol. 1, Num 5, March 2012, p. 112 (based on data from Australian Bureau of Statistics 2009)

Figure 2 Proportional forest clearance rates by state and year from 1995 to 2005 relative to total land area

Deforestation has two principal effects on climate (Bradshaw, 2012). First, the physical act of vegetation clearance releases substantial quantities of greenhouse gases into the atmosphere, which increases overall carbon emissions and exacerbates anthropogenic climate change (IPCC 2007). A study of the carbon-carrying capacity of 14.5 million ha of native eucalypt forests in Queensland, New South Wales, Victoria and Tasmania indicated a capacity of 640 tonnes C ha-1 , or 33 billion tonnes of CO2 equivalents in the forests’ natural state (Mackey et al. 2008). According to Keith et al. (2009) the world’s highest total biomass carbon density (both living and dead tissue, 1,867 tonnes C ha-1) is found in the moist temperate Eucalyptus regnans mountain ash forests of Victoria.

Secondly, forest clearance over large areas also affects local climate conditions including temperature variation and rainfall patterns (Deo 2011; Deo et al. 2009). Due to the change in vegetation cover, the solar energy available for plant transpiration, evaporation and convection between the land and the atmosphere and soil moisture feedback are all changed, leading to more rapid local climate anomalies (Deo 2011). Climate change related temperature rise and shifts in rainfall patterns are therefore exacerbated by vegetation clearance making drought events last longer and more extreme (i.e. hotter and drier) (Deo et al. 2009).

Given that more than half of Victoria’s area has been cleared, there is a massive potential for carbon sequestration via revegetation both on Crown land along riparian zones, road verges, parks and on private land as revegetation integrated in whole farm plans and farm forestry.

5.2.2 Water impacts

In addition to climate impacts Deloitte (2017) estimates that water production in Victoria would increase in the absence of native timber harvesting, by an estimated 4,295ML per annum, valued at around $1.76 million to $2.43 million per annum. Some marginal improvement in water quality would also be expected to occur.

5 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

5.2.3 Area and volume of timber harvesting in Victoria

Under the Sustainable Forest (Timber) Act 2004 the Working Forest Area (WFA) is 1,874,733 ha or 26% of native forests in Victoria (Deloitte, 2017). Of the WFA, 24% or an area of 463,087 ha is Suitable Forest Area (SFA) and on average an area of 3,570 ha is harvested annually across Eastern Victoria and in their economic report Deloitte (2017) recorded 1.32 m cubic meters of timber harvested by Vic Forests in 2015-2016.

In contrast to the previous years, most recent figures of commercial plantations (ABARES, 2020) indicate a reduction in Victoria from 433,100 ha in 2013/2014 to 420,000 ha in 2017/18 and to 418,500 ha in 2018/2019.

In terms of volumes harvested for the year 2018/2019, ABARES (2020) reports for Victoria the following volumes for native timber and commercial plantations:

Hardwood from native timber harvesting 1,078,000 m3 (12.2 %) Hardwood from commercial plantation 3,893,000 m3 (43.9 %) Softwood from commercial plantation 3,888,000 m3 (43.9 %) Total 8,859,000 m3 (100 %)

5.2.4 Low employment and productivity of the native timber industry in Victoria

According to Deloitte (2017), 19 out of 20 jobs in the Victorian forestry sector are already based on plantations. In 2015-16 only some 500 FTE jobs were directly employed in the native forest logging industry of Vicforests, achieving a annual revenue of $112m and a Value Added of $70m (revenue minus costs – note: we believe that this figure seems to include only a deduction of labour costs and without accounting for material costs and overheads).

In its report “Rethinking Victoria’s approach to forestry” Pricewaterhouse Coopers (PwC, 2016) alerts to the low productivity of native timber harvesting compared to commercial plantations: • One FTE (full time equivalent) job in native forest logging requires over $5m capital investment • Thus, the capital investment employment impact in native timber harvesting is only 0.2 FTE in direct employment and 0.63 FTE in flow-on employment per $1 million. • In comparison, in the Australian forestry sector, the capital investment employment impact is 1.74 FTE in direct employment and 7.29 FTE in flow on employment per $1 million. • The direct and flow-on effects of native timber harvesting per $ capital investment are also much lower for the native timber industry (direct 0.03, flow-on 0.11, total 0.14) compared to commercial plantations (direct 0.37, flow-on 1.26, total 1.63) and average non-forestry manufacturing (direct 0.45, flow-on 2.2, total 2.65)

To quote PwC (2016): “From a regional development or employment perspective, the higher level of investment required to create one FTE, suggests that supporting native forestry would be less beneficial than supporting other industries, as it generates lower employment per dollar spent.’ And “the native forestry sector does not contribute widespread economic returns: every dollar of capital investment in the native forestry sector results in a total multiplier effect of 0.14 to Gross State Product, the lowest of the industries considered”.

6 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

5.2.5 The value of Ecosystem services compared to timber harvesting

In a first experimental establishment of Ecosystem Accounts for the Central Highlands of Victoria, Keith et al. (2017) found that the value of ecosystem services in 2013-14 for agricultural production ($121m) and for water provisioning service ($101 m) was an order of magnitude greater than the native timber provisioning service ($19 m). The contribution to GDP (Industry Value Added) of agriculture ($312m), water supply ($210m) and tourism industries ($260) were all more than twenty times higher than for the native forestry industry ($12m).

The native timber industry in Victoria is thus competing against very high opportunity costs. In this regards it will be interesting to see the results of Eco-system Accounting planned by the Victorian government under the Biodiversity 2037 plan and the assessment results of carbon sequestration and storage of DELWP under the regional forest agreement modernisation program (DELWP Fact sheet 8 , 2019).

5.2.6 Native timber industry’s pressure on listed species

Despite the increasing pressure on native species including listed flora and fauna species and ecological communities, exacerbated by recent widespread 2009 and 2019/20 bushfires, the Victorian government plans to transition out of native forest logging by 2030 only.

Since 2002 under the Howard government’s Regional Forest Agreements Act, native forest logging has been exempt from the Federal Biodiversity and Environment Protection Act (1999) and has thus been the only economic sector to enjoy a special treatment and less stringent environmental regulations under the Regional Forest Agreements.

In a recent Federal Court case of Friends of the Leadbeater’s Possum (FBL) vs. VicForests, in May 2020 the Court found that VicForests had not and is unlikely in future to comply with both state and federal laws designed to protect threatened species (Environmental Justice Australia, 2020). FBL had argued that logging by VicForests in 66 areas of habitat critical to the vulnerable Greater Glider and critically endangered Leadbeater’s Possum contravenes federal law. The Court found that logging operations in certain areas of the Central Highlands failed to comply with the Victorian Code of Practice for Timber Production, which is a requirement under the Regional Forest Agreement (RFA). EJA further explains that the non-compliance with RFA means that the exemption does not apply and that VicForests must therefore comply with national environmental laws (EJA 2020). The central breach of the Code found that VicForests did not comply with precautionary principle laws in certain forests where Greater Gliders are living, because those logging operations do not avoid serious or irreversible damage to the species wherever practical. The species is known to be threatened by logging yet logging occurred, and is planned, in habitat where Gliders have been sighted. The Court also found a number of other breaches of the Code – including relating to protection of Leadbeater’s Possum habitat (EJA, 2020).

VicForest is no longer eligible for a membership of the Forest Stewardship Council of Australia, because it has failed to achieve Controlled Wood Standard within the required time (timberbiz Australian Forests & Timber News, 2020). And Non-compliance with environmental law is also consequential economically: In July 2020, Bunnings announced to no longer sell products from

7 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

VicForests’ native timber harvesting, saying that it always had a zero-tolerance approach to illegally logged timber (ABC , 2020; The Guardian, 2020).

For biodiversity and ecosystem quality most consequential is the fact that VicForests have systematically been failing to conduct state of the art in-field surveys for endangered species required by the RFA in every planned coupe ahead of any logging activities.

For a long time and repeatedly concerns regarding affected habitat of endangered species in planned coupes had been raised by concerned community members, local community groups (including the Murrindindi Climate Network) and local governments (including the Murrindindi Shire Council) with VicForest, with DELWP and with the Catchment management authorities (in our case the Goulburn Broken Catchment management authorities) - but have not been followed up or addressed properly.

This Federal Court case is therefore an important signal for the Victorian government to ensure that its own agencies adhere to environmental laws at all times.

5.2.7 Now is a good opportunity for fast-tracking the transition out of native timber harvesting

In light of the relative modest workforce directly employed by VicForests and considering the low productivity compared to plantation timber and other sectors and considering the potentially high opportunity costs of native timber harvesting as demonstrated by the Ecosystem Accounting, we believe that both the ecosystem in Victoria’s native forest areas and the Victorian economy would benefit from a fast-tracked transition out of native timber harvesting, commencing prior to 2030.

The Murrindindi Climate Network urges the Victorian government to actively take up the following transition opportunities:

Transition opportunities for VicForests and the Victorian government

• The plantation timber sector (in Victoria, New South Wales and South Australia) needs urgently a lot of workforce to cope with the vast areas of salvage logging after the 2019/20 bushfires. This constitutes a short-term employment opportunity for VicForests workforce skilled in forestry work over the next 2-3 years. • Direct additional governmental assistance (including post-Covid economic recovery funds) to the commercial plantation sector to increase its operations. • Encourage VicForests to diversity away from traditional native forest activities towards activities that will generate higher returns, such as supporting on-farm hardwood forestry, focusing on plantation forests to take advantage of funding under the national Emissions Reduction Fund (ERF) , regulated by the Clean Energy Regulator, (2016). VicForests could be positioned as facilitator of development of native forests by supporting Victorian farmers in accessing the ERF, conditional on future revenue sharing arrangements (Pricewaterhouse Coopers, 2016). • Assist VicForests in establishing collaboration with Australian and internationally based Offset brokers (such as Carbon Neutral, Climatepatner, Enviro Offset Trading and Earthtrade) to access corporate customers for eligible revegetation offset projects, farm forestry projects or timber plantations that it can help establish and manage. • The Victorian State government and local governments should endeavour to achieve carbon neutrality under the National Carbon Offset Standard (NCOS) and offset their

8 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

own carbon emissions with local offset projects including projects established and managed by VicForests. • The Victorian government should intensify and extend its promotional campaign (TAKE2 Victoria’s climate change pledge started in 2016) with the corporate sector, local governments, utility service providers, education institutions and community groups to direct them to local Offsetting projects including in the forestry sector rather than accessing Offsetting opportunities abroad.

5.3 Direct compensation of farmers for ecological services

In EU member countries and also in non-EU countries like the UK, Switzerland and Norway the farming businesses receive direct compensation for ecological services undertaken on their farm. These payments must follow high statutory management requirements in regards to public, animal and plant health, animal welfare and protection of the environment (See Council Directive 92/43/EEC). The EU has to direct 30% of the direct payments to “green direct payments” for measures undertaken to reach environmental and climate objectives, thus rewarding farmers for environmental services for a public good not reflected in market prices (https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/income-support/greening_en). Under this cross-compliance system there are strict compliance and control mechanisms, and farmers who are not respecting these EU rules, will see their payments reduced. For example, in Switzerland, the key conditions of the direct compensation for ecosystem protection services are • an ecological performance record (e.g. including biodiversity promotion areas on the farm must be up to 7% of the productive area; management of biotopes protected in the national inventory – i.e. wetlands; etc. ) , • a regular control by an independent and accredited control organisation, and • a participation in annual surveys. Ecosystem related measures include for example regulated crop rotation, crop diversification, protection of specially protected biotopes such as wetlands, hedges and revegetation zones, establishment of buffer zones, erosion control, soil protection, increase in soil carbon, maintenance of permanent grass land for biodiversity and to support carbon sequestration, weed and pest control as outlined in governmental documentation (See: UK Department for Environment , Food and Rural Affairs (2013) Payments for ecosystem Services: A Best Practice Guide: https://www.cbd.int/financial/pes/unitedkingdom-bestpractice.pdf or the current Guidelines of Direct payments for eco-system services of the Kanton of Berne, Switzerland https://www.vol.be.ch/vol/de/index/landwirtschaft/landwirtschaft/direktzahlungen.html ). The approach of supporting farmers with direct payments for their environmental services is also promoted internationally by the Food and Agriculture Organisation of the United Nations FAO (http://www.fao.org/3/a1200e/a1200e02.pdf).

In Australia, it is mainly the voluntary landcare groups that have to shoulder the very big workload of habitat restoration and ecological improvements without any remuneration for their labour. The Caring for our Country Grant programs (2008-2013 and 2013-2018) and follow-on grant programs administered through Natural Resource Management Councils or Catchment Management Authorities and allocated to landcare groups are often just covering facilitator wages and a fraction of the material costs needed, whereas all the labour is put in for free.

Given the humungous task at hand, e.g. combatting the ever-increasing weed and pest infestations and the restoration of vast areas of degraded land including revegetation of public and private land, punctual deployment of voluntary auction-based programs such as

9 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

EcoTender and BushTender or the input of under-resourced volunteer-based landcare groups is simply not sufficient. It is therefore time to introduce direct payments for the farming community to compensate farmers and landholders for the necessary services to the ecosystem restoration they need to deliver.

5.4 Regional Biodiversity Action Plans

All on-ground natural resource management activities by local governments, farming businesses, private landholders, landcare groups and other stakeholders operating on the land need to be embedded in overarching systematic long-term Regional Ecosystem & Biodiversity Action Plans set up by DELWP and the Catchment Management Authorities in collaboration with local councils, the regional chapters of the Farmers Federation, Water Authorities, regional Landcare Networks and other stakeholders (e.g. Victorian National Parks Association).

These Regional Ecosystem & Biodiversity Action Plans must include concrete short-term operational deliverables and related annual activity plans including educational and training programs to enable the different stakeholder types to effectively achieve annual deliverables set under the plan.

Sufficient funding must be allocated for the development of the Regional Ecosystem & Biodiversity Action Plans and related annual operational plans, for educational and training programs and on-ground operational support and monitoring.

5.5 Effective legal implementation tools, control and enforcement of compliance with environmental law

To turn around the negative development of ecosystem decline and the progressing extinction crisis, it is critical to complement effective implementation tools with effective control and enforcement of compliance with environmental laws and regulations.

5.5.1 Improvement and timing of implementation tools

a) Management plans for endangered species Sufficient resources need to be allocated for urgent completion of management plans for endangered species and ecological communities. The fact that management plans have been taking an incredibly long time, some of which are still incomplete, has corroded the trust of concerned community members in the government. It almost felt like governmental agencies had to follow a higher political agenda that was willingly putting the establishment of management plans for endangered species on the back-burner in order to focus on other priorities.

b) Flora and Fauna Guarantee Act 1988 and reforms 2018 Amended in 2018 the Flora and Fauna Guarantee Act is a critical law for Victoria’s biodiversity conservation. Due to come in force on the 1st of July 2020, the act has been placed on hold to ease restrictions on industry during the COVID pandemic. However, the post-pandemic economic recovery should not take place at the detriment of Victoria’s environmental laws in the first place. Quite the contrary: The post-pandemic recovery should be seen as the ideal opportunity to transition to economic practices with a better environmental performance record. We therefore request that the Victorian government immediately revoke the delay of the Environment Protection Act 2018.

10 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

c) Strengthening the implementation of the Native Vegetation Regulations 2017 For local governments in rural areas the Native Vegetation Regulations 2017 are difficult to implement. There is a lack in clarity on how the concept of ‘no net loss’ should be measured and monitored. There is also insufficient training provided to council staff of how to prevent unlawful clearing and how to enforce appropriate native offset planting. Once illegal clearing has occurred, the enforcement of the Native Vegetation Regulations under the Planning and Environment Act 1987 is difficult and costly for the local governments.

We therefore think that the re-introduction of well-trained and properly funded state government compliance officers is needed to enforce environmental laws effectively.

5.5.2 Independent compliance control and law enforcement

The introduction of the Office of Conservation Regulator by DELWP in 2019 in response to the independent review of Timber Harvesting Regulation is not addressing the intrinsic problem of DELWP – that is, its multiple often conflicting policy objectives within the same agency that are undermining and hampering effective compliance control and law enforcement – a result of missing checks and balances. Whilst the Office of Conservation Regulator is in charge of monitoring compliance with regulatory requirements and taking enforcement action against non-compliance in matters of timber harvesting, biodiversity, fire prevention and land-use regulation, this is still not a body that is independent from DELWP. It may therefore potentially be affected again by conflicting internal policy objectives.

To restore trust in the system and to guarantee effective compliance control and law enforcement, Victoria needs an independent conservation regulator with a clear legal foundation that can ensure that all environmental laws are complied with.

At municipal level, the control and enforcement of compliance with environmental law and control of on-ground NRM activities financed by governmental grant funding is insufficient, ineffective, underfunded and under-resourced. Although some of the rural shires (e.g. Mitchell Shire) attach environmental obligations to their planning permit process and try to conduct random checks of landholders’ engagement in effective weed control on their properties, these measures are not sufficient. On the whole, local governments (especially in rural areas) and catchment management authorities do not have the staff nor the funding to regularly assess and enforce compliance of landowners and businesses with environmental laws and regulations and are often unable to take effective action against environmental breaches.

For rural and regional Victoria an independent agency with well-trained and properly funded compliance officers to control compliance and enforce the environmental laws is absolutely critical.

Dr Rita Seethaler, OAM 31. August 2020 Chair, Murrindindi Climate Network Inc.

11 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

References consulted for this submission

ABC (2020) Bunnings drops VicForests wood after illegal logging ruling. (1. July 2020) https://www.abc.net.au/triplej/programs/hack/bunnings-vicforests-timber/12412642

Australian Bureau of Rural Sciences (2010) Australia’s Forests at a Glance 2010, Australian Government Department of Agriculture. Canberra, Australia: Fisheries and Forestry ABARES (Australian Bureau of Agricultural and Resource Economics and Sciences), 2019, Australian Plantation Statistics 2019 Update, https://www.agriculture.gov.au/sites/default/files/sitecollectiondocuments/abares/publicati ons/AustPlantationStats_2019_v.1.0.0.pdf

Bradshaw, C.J.A. (2012) Little left to lose: deforestation and forest degradation in Australia since European colonization, Journal of Plant Ecology VOLUME 5, NUMBER 1, PAGES 109–120 MARCH 2012. https://www.serca.org.au/research/2012/Bradshaw.pdf (last accessed 29.8.2020)

Clean Energy Regultor (2016) About the Emissions Reduction Fund http://www.cleanenergyregulator.gov.au/ERF/About-the-Emissions-Reduction-Fund (last accessed 29.8.2020)

Climate Analytics (2018) Climate change: Australia vs the World Australia’s pollution profile & how to turn it around. Factsheet 1. https://climateanalytics.org/media/australiaclimatefactsheets2018-australianeconomy- climateanalytics.pdf (last accessed 29.8.2020)

Commissioner for Environmental Sustainability Victoria (2018) State of Environment 2018. https://www.ces.vic.gov.au/reports/state-environment-2018 (last accessed 28.8.2020)

Commissioner for Environmental Sustainability Victoria (2018) Biodiversity (B) Scientific Assessment Part III https://www.ces.vic.gov.au/sites/default/files/SoE2018ScientificAssessment_B.pdf (last accessed 28.8.2020)

Deloitte Access Economics (2017) The economic impact of VicForests on the Victorian community, http://www.vicforests.com.au/static/uploads/files/report-vf-2017-deloitte- report-final-wfxocecnfegf.pdf (last accessed 29.8.2020)

Department of Agriculture, Water and the Environment (undated) National Landcare Program. Previous Programs , Government of Australia; http://www.nrm.gov.au/news-and- resources/resources/previous-programmes (last accessed 28.8.2020)

Department of Agriculture of the Canton of Berne, Switzerland https://www.vol.be.ch/vol/de/index/landwirtschaft/landwirtschaft/direktzahlungen.html

Department of Environment, Land, Water and Planning (2019) Office of the Conservation Regulator. https://www.delwp.vic.gov.au/our-department/regulator (last accessed 28.8.2020)

12 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

Department of Environment, Land, Water and Planning (2019) Fact Sheet 8: Valuing forest carbon. https://www.delwp.vic.gov.au/__data/assets/pdf_file/0023/416408/8-Carbon- factsheet-FINAL.pdf (last accessed 28.8.2020)

Department of Environment, Land, Water and Planning (2017) Protecting Victoria’s Environment –Biodiversity 2037; Government of Victoria (https://www.environment.vic.gov.au/__data/assets/pdf_file/0022/51259/Protecting-Victorias-Environment-Biodiversity- 2037.pdf last accessed 28.8.2020)

Department of Industry, Science, Energy and Resources (undated) Australian Greenhouse Emissions Information system; Commonwealth of Australia https://ageis.climatechange.gov.au/ANZSIC.aspx (last accessed 30.8.2020)

Department of Sustainability and Environment (2011) Native Vegetation. Melbourne, Australia: Victoria Government. http://www.dse.vic.gov.au/land-management/land/native-vegetation-home/what-is-native- vegetation#Status

Department of Sustainability and Environment (2009) Murrindindi Complex North Fire Emergency Stabilization and Rehabilitation Plan. Prepared by the Victorian Interagency Rehabilitation Group and USA Burned Area Emergency Response Team.

Dickman C. (2020) More than one billion animals killed in Australian bushfire - Update on number of animals killed in Australian bushfires. University of Sydney. https://www.sydney.edu.au/news-opinion/news/2020/01/08/australian-bushfires-more-than-one-billion-animals- impacted.html (last accessed 29.8.2020)

Deo RC, Syktus JI, McAlpine CA, et al. (2009) Impact of historical land over change on daily indices of climate extremes including droughts in eastern Australia. Geophys Res Lett 36:L08705.

Deo RC (2011) Links between native forest and climate in Australia. Weather 66:64–9

Ecosystem Services Working Group of the Natural Resource Policies and Programs Committee (2007). Ecosystem services and Australian natural resource management (NRM) futures: Paper to the Natural Resource Policies and Programs Committee (NRPPC) and the Natural Resource Management Standing Committee (NRMSC)

Environmental Justice Australia (2020) The case to stop VicForests logging critical habitat for our threatened possums. https://www.envirojustice.org.au/our- work/nature/forests/possums-case/ (last accessed 29.8.2020)

European Community Council Directive 92/43/EEC https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/income-support/greening_en

Food and Agriculture Organisation of the United Nations FAO (2007) Paying Farmers for their Environmental Services, Part I (http://www.fao.org/3/a1200e/a1200e02.pdf) (last accessed 28.8.2020).

IPCC (2007) Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Geneva,

13 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 759

Switzerland: Intergovernmental Panel on Climate Change.

Keith H, Mackey BG, Lindenmayer DB (2009) Re-evaluation of forest biomass carbon stocks and lessons from the world’s most carbondense forests. Proc Natl Acad Sci U S A 106:11635– 40.

Keith H., Vardon M., Stein J., Stein J, Lindenmayer D (2017) Experimental Ecosystem Accounts for the Central Highlands of Victoria, Final Report, ANU https://tsrhub.worldsecuresystems.com/Ecosystem%20Complete%20Report_V5_highest%20 quality.pdf (last accessed 29.8.2020)

Mackey BG, Keith H, Berry S, et al. (2008) Green Carbon: The Role of Natural Forests in Carbon Storage. Canberra, Australia: The Australian National University.

Pascoe B. (2014 ) Dark Emu. Magabala Books

Pricewaterhouse Coopers (2016) Rethinking Victoria’s approach to forestry. https://d3n8a8pro7vhmx.cloudfront.net/friendsofearthmelbourne/pages/2765/attachments/original/1520234386/PwC- Rethinking-Victorias-approach-to-forestry_FINAL-markup%281%29.pdf?1520234386 (last accessed 30.8.2020)

The Guardian (2020) Bunnings stops selling timber logged by VicForests after court ruling (1. July 2020) https://www.theguardian.com/environment/2020/jul/01/bunnings-stops-selling- timber-logged-vicforests-court-ruling (last accessed 28.8.2020)

Timberbiz (2020) VicForests not eligible for FSC membership. 17. April 2020. https://www.timberbiz.com.au/vicforests-not-eligible-for-fsc-membership/ (last accessed 28.8.2020)

UK Department for Environment , Food and Rural Affairs (2013) Payments for ecosystem Services: A Best Practice Guide: https://www.cbd.int/financial/pes/unitedkingdom- bestpractice.pdf

United Nations Framework Convention on Climate Change (2015) , The Paris Agreement https://unfccc.int/process-and-meetings/the-paris-agreement/the-paris-agreement (last accessed 28.8.2020)

WWF (2020) Australia’s 2019-2020 Bushfires: The Wildlife toll Contributing Authors: Lily van Eeden – The University of Sydney; Dale Nimmo – Charles Sturt University; Michael Mahony – University of Newcastle; Kerryn Herman, Glenn Ehmke, Joris Driessen, James O’Connor – BirdLife Australia; Gilad Bino – University of New South Wales; Martin Taylor – WWF-Australia; Chris Dickman – The University of Sydney. file:///Users/ritaseethaler1/Desktop/Animals%20Impacted%20Interim%20Report%2024072020%20final.pdf (last accessed 29.8.2020)

VAFI Victorian Association of Forest Industries (2017) Industry Review, http://www.vafi.org.au/wp-content/uploads/2018/05/171023-VAFI035-Industry-Review- 2017-v8.pdf

Von Weizsäcker E. , Amory B. Lovins, L. Hunter Lovins (1977 and 1997) Factor 4 – Doubling Wealth-Halving Resource Use. Allen & Unwin