IMPACT OF THE NATIVE VEGETATION MANAGEMENT FRAMEWORK

BRUCE MCCLURE, General Manager CMPA comments on the Department of Sustainability and Environment (DSE) Native Vegetation Management Framework which has been the subject of a recent submission to the DSE.

THE DSE has issued a discussion paper called “Future directions for native vegetation in Victoria” and sort comments from all stakeholders. The CMPA has responded with comments highlighting the impact on its members and the future viability of the industry.

Part of our submission was a document prepared and presented on a number of occasions to the DSE and the Department of Primary Industries (DPI) when comments were sort which strongly highlights members concerns.

A copy of this document is shown below. It is anticipated that DSE will be seeking further input from stakeholders on the current native vegetation management framework as discussions with other stakeholders has indicated that they are also not happy with the future directions paper and will be seeking further discussions on this subject. The CMPA will be actively involved in all future discussions and will keep members informed on progress.

The CMPA’s members are deeply concerned about the impact of the native vegetation management framework upon their businesses. These concerns have been raised with the DSE and the DPI on numerous occasions without a clear or sustainable resolution.

The native vegetation management framework is forcing our members’ out of this industry as a result of:

• No clear, commercially attainable arrangements or outcomes
• Complex interpretations requiring exorbitant legal and consulting fees throughout the site life-cycle for all business sizes
• An inability to consider the positive environmental benefits of accessing the resource resulting in large, highly valuable sites being locked up.

Since 1966 the extractive industry has been identified with its own Act (Extractive Industries Development Act) and now under the Minerals Resources (Sustainable Development) Act both having as one of their key objectives the guardianship of native vegetation and being secured through the issuing of Work Authorities. Work Authority holders are required under the Act to manage these constrained resources in a manner that is compatible with the economic, social and environmental objectives of the state.

WHERE TO FROM HERE

Our members require assistance in the following areas:

1 – An all of Government review including State Government Departments, Local Government, land developers and industry needs to be carried out on the framework, giving due consideration to the environmental, social and economic implications. This evaluation must be undertaken by a large, reputable firm with wide experience in the financial implications and cumulative legislative burden upon the businesses it is written for.

The terms of reference for the evaluation could include:

• Exploration of what native vegetation is.
• Cost-benefit analysis of the current provisions.
• How to change the current, ad hoc arrangements for ‘conservation’of ‘off sets’ to advance the objectives of a biological architecture for Victoria.
• Exploration of alternative and fairer funding arrangements which includes the value of extractive materials contained under the vegetation on the sites.

2 – Recognition that the Department of Primary Industries (DPI) manages the States earth resources for the benefit of all Victorians and that they be charged with encouraging an efficient extractive industry which makes best use of the resources in a way that is compatible with the economic, social and environmental objectives of the state and evidence of their duties being carried out.

3 – Encourage more flexible policy able to utilise ideas such as:

• Embedding full extractive industry exemptions within the DSE’s framework as this industry is oft en not a permanent change of land use in nature and already heavily regulated.
• Taking a balance sheet approach, giving value to the resource on par with vegetation.

GENERAL COMMENTS

• Policy implementation creates a net tangible loss of native vegetation.
• Transaction costs for offset arrangements are very high which is restricting entry into the industry. This will lead to large costs in extracting materials in the future.
• Almost all the money goes as windfall capital gains to some landholders and as fees to consultants, not to conservation.
• Policy accelerates the loss of native vegetation not caught in the native vegetation planning net. The economic signal sent to the majority of landholders is of native vegetation as a balance sheet liability, particularly rare and threatened species.
• Policy delivers an ad hoc set of offset enclaves, with no reference to any biological, architectural design for Victoria.
• The Net Gain provisions commit future governments to unfunded compliance liabilities ‘in perpetuity’.
• ‘The Framework’, published in 2002, foreshadowed a ‘review’ in four years that has not happened.
• No Government has conducted a cost-benefit analysis of native vegetation controls to find out the real impact that it will have on all Victorians in the future.

Present policy is based on:

• Presumption that Government can force landholders to produce meaningful conservation outcomes, usually against their self interest.
• False assumption that landholders do not and will not react to the threat posed by native vegetation controls to their balance sheet.

SOME IMPORTANT FACTS ABOUT THE EXTRACTIVE INDUSTRIES:

• Work Authorities across Victoria account for only 52,440 hectares of Victoria’s total landmass of 22,741,600 hectares. Within the Work Authority area is a proportion that is approved for extracting and processing to occur equating to approximately one-fifth of the site or 10,488 hectares. This is equivalent to 0.046% of the state’s landmass or one farm in regional Victoria. Of the 52,440 hectares of land taken up by Work Authorities, approximately 30,000 hectares of this land is a repository for flora and fauna as long as the Work Authority is functioning.
• The DPI returns for the 2010-11 financial year reported over 52.2 million tonnes of material being produced worth over $760.3 million. This equates to approximately 9.4 tonnes per Victorian per year.
• At 30 June 2011 the state held $65.0 million in rehabilitation bonds for 876 Work Authorities (average $74,201/ Work Authority).

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