DRAFT National Light Pollution Guidelines for Wildlife

DR ELIZABETH GIBSON, General Manager of the CMPA comments on the Draft National Light Pollution Guidelines for Wildlife.

The Federal Department of the Environment and Energy is developing draft National Light Pollution Guidelines for Wildlife including Marine Turtles, Seabirds and Migratory Shorebirds.

“The National Light Pollution Guidelines aim to raise awareness of the potential impacts of artificial light on wildlife and provide a framework for assessing and managing these impacts around susceptible listed wildlife. Artificial light can disrupt critical behaviours in wildlife, stalling the recovery of threatened species and interfering with a migratory species’ ability to undertake long distance migrations integral to its life cycle.”

The draft Guidelines were released for public comment which closed on 30 September 2019. The following is CMPA’s submission on the Guidelines. ote this submission can also be accessed at www.cmpavic.asn.au

“Thank you for the opportunity to comment on “Draft National Light Pollution Guidelines for Wildlife” (Guidelines).

Specific Comments, Page number , Extract from Guidelines & CMPA comment

p.2

These Guidelines provide users with the theoretical, technical and practical information required to assess if a lighting project is likely to affect wildlife and the management tools to minimise and mitigate that affect. These techniques can be applied regardless of scale, from small, domestic projects to large-scale industrial developments.

The requirements and techniques outlined in the Guidelines
are onerous:
i) Describe wildlife
• Desktop study of wildlife;
• Field surveys for wildlife;
• Baseline monitoring;
ii) Risk assessment
iii) Artificial light management plan
iv) Biological and light monitoring and auditing
v) Review

These techniques whilst very thorough are costly and will only be available to large scale developments which will have the sufficient funds. Small to medium enterprises such as quarries will continue to struggle in the marketplace with yet another legislative requirement.

P.7 Figure 3

Decision tree:

Is there important habitat for listed species located within 20 km? If yes, undertake an environmental impact assessment (EIA) of artificial light on wildlife.

20km from a threatened species is likely to encompass every project/activity in Australia. Rather than conduct an EIA for every project/activity and incurring the subsequent expense (through use of appropriately qualified lighting practitioners and qualified wildlife biologists or ecologists) thought should be given to the Australian Government developing practicable standard controls which if not met then an EIA would have to be completed. Obviously, it would only be required if the project has night-time activity.

Summary

The Guidelines are very comprehensive, however, there is no apparent economy of scale for small to medium enterprises (SME) such as quarries versus large corporations in the prevention of artificial light pollution. If artificial light pollution is to be addressed and SMEs are to continue operating in Australia, then a more equitable mechanism needs to be introduced.

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