To: Victorian Land and Biodiversity Green Paper

Made: June 2008

The Environmental Farmers Network is keen to have a visionary, robust and well supported land and biodiversity strategy. Without such, the future of sustainability is in jeopardy. We believe that the environment provides the primary capital from which we derive our income stream. We cannot afford to depreciate it (or close it down).
The Network considers immediate action is needed to combat the inexorable approach of climate change. Land management and landuse must change dramatically in the short term. To adapt, we need a range of tools, especially market based incentives(MBI’s) to ensure that land, and its intimately associated biodiversity, is properly valued.
Five areas are of critical concern to the Environmental Farmers Network:

  • the creation of strategic bio-links;
  • the management of peri-urban development;
  • the encouragement of regional communities’ involvement in strategic direction and priority setting;
  • the need to protect and restore environmental flows; and
  • the need to have clear (and sequential) priorities for action.

The need for action is urgent.

Since the green-paper/white-paper process started, there has been an alarming deterioration in indicators of climate change. Most indicators are running at very high or worst-case-scenarios levels. Consequently there will be an even greater impact than predicted on both agriculture, and many aspects of land management and biodiversity. Much of this greater impact will be due to unexpected effects in the short term.– for example: small rainfall deficits but large runoff effects; wetlands and rivers drying; population growth tenaciously continuing; accelerating urban sprawl; and compelled landuse change.

Specific comments under Green Paper headings

6.1 Private sector investment in natural resources

  • Private and philanthropic investment in natural resource assets are essential to bring about large scale landscape change. To assist these developments a regional, more flexible and integrated approach to planning regulations is required.
    It is unlikely that resource management based planning regulations can be uniformly applied across all regions of the State if we wish to achieve the best outcomes. Regional variation must be recognized. Current statewide planning provisions have not been effective in protecting remnant native vegetation.
  • Market based instruments should continue to encourage private investment in the conservation and enhancement of remnant vegetation.
  • There are currently large changes in land ownership underway with generational change and small, traditional family farm holdings being bought or leased by larger operators and corporate farming/investment enterprises.  These changes are an opportunity to engage new operators in sustainable land management practices and a consequential improvement in biodiversity and the health of the landscape,  The consequences of not engaging these large land managers will be large scale depletion of biodiversity and degradation of land by unsustainable industrial agricultural practices.  Thus engaging the large-scale landowners is critical.  It is likely that this will only be successful if there are both positive financial incentives, and accountability for management practices both government and market driven.
  • The provision (and protection) of ecosystem services by all managers of private land must be rewarded.
  • Rewards and incentives for “best practice” raise questions as to what can be defined as “best practice” and how will this be audited/certified/regulated.  Programs such as EBMP and other EMS schemes must be expanded and developed to reflect increasing environmental expectations.

6.2 Using carbon markets for biodiversity and soil health

  • The encouragement of carbon storage in both soils and vegetation should be a critical driver in achieving improved soils and biodiversity.
  • A reputable, transparent carbon market capable of servicing the needs of integrated natural resource projects on both public and private land would play an important role in cost benefit analysis and prioritizing inputs.
  • The use of carbon markets to better illustrate comparisons between the sustainability of different farming systems will benefit natural resources.
  • Plantings of indigenous vegetation for carbon sequestration should be encouraged on marginal agricultural land and then contribute to biodiversity and ecosystem services, while concomitantly retiring this land from inefficient and potentially damaging agricultural production.
  • It will be necessary to overcome potential problems in accounting accurately for the offset value of biodiverse vegetation compared with monocultures.

6.3 Improving catchment management

  • Despite Victoria’s catchment management model comparing favorably with ‘natural resource structural arrangements in other Australian states’, we believe improvements can be made in the relationships and responsibilities of Federal, State and Local Governments, Landcare and Catchment Management Authorities.  Such improvements should be aimed at: clarity of governance; reliability of funding streams; avoidance of agency duplication; and integration of regional planning and development.
  • Regional Catchment Strategies need to be planned, agreed-to and implemented by all land managers. These Strategies should include detail on the management of all public land in the region and be developed jointly by State departments, State authorities and local government.  The CMAs are in an ideal position to coordinate the effort at catchment scale as they are (or should be) able to liaise with Govt Depts., landholders, NGOs and the general community.  The community facilitators provide a workable link to the general community but there is a need to consolidate a career path and provide funding certainty.
  • The directing of funding based on  Regional Catchment Strategies is seen as providing the best value for money for public funds directed toward natural resource management.
  • The unpredictability and frequent untimeliness of funding to Regional Catchment Authorities has in the past affected the recruitment of staff, the implementation of projects, and the relationships with Landcare and the community and in some cases created solvency concerns of Boards.
  • Sub-strategies and planning frameworks should intimately align with the RCS and local government MSS’s.

6.4 Managing water for multiple objectives.

  • Regional Sustainable Water Strategies need to take into account the over allocation of the water for consumptive use and the impacts of climate change when setting in place an environmental water reserve.
  • Environmental flows are an increasingly URGENT priority and should take precedence over other uses – without environmental water many ecosystems will be irreversibly degraded
  • Accounting systems need to be developed that recognize the multiple use of environmental water as it is managed in rivers, streams and wetlands.
  • The proliferation of small stock &domestic dams on farms and rural subdivisions is further damaging rivers and steams not only by the amount of water stored but by lessening the “flooding” of streams during the critical spring months.
  • Maximum flow volumes of consumptive use water transferred during the irrigation season need to be introduced to all natural carriers. Water trading has increased this damage to waterways.
  • The management of public land adjoining rivers and streams and the continued practices of logging and grazing are contributing to loss of biodiversity and needs urgent review.

6.5 Managing aquatic systems

  • Pressures of overpopulation, coastal development and rising sea levels threaten coastal wetlands.
  • Salinisation of estuaries is increasing due to growing catchment water-use. Such uses need to be included in future water planning.
  • Inappropriate use (eg bluegums, cropping, pasture establishment) of ephemeral wetlands needs to be prevented.
  • We need MBI’s for wetland restoration and management.
  • Incentives for fencing waterways and wetlands and associated alternative stock watering systems need to be improved to increase adoption rate.
  • CMA’s need to prioritise wetlands and actions needed to protect and enhance them allowing for impact of climate change.
  • Protection of key habitat (much of it associated with wetlands or waterways) is fundamental to preserving and enhancing biodiversity
  • Land managers should be supported to enable them to manage wetlands and waterways on private land for biodiversity purposes.  These wetlands and waterways provide important ecosystem services and are an integral part of biolinks.
  • Strongly endorse suggested approach of reviewing crown frontage licensing process for holistic environmental outcomes.

6.6 Building ecological connectivity

  • Declared biolinks offer the best way forward to ensure functioning ecosystems, by protecting flora and fauna and allowing paths of refuge in a changing climate.
  • Existing State and National Parks, rivers, streams and roadsides offer a foundation for this plan which should take into account the need for north/south migration as well as crossing State boundaries
  • Existing bio-link examples like the Goulburn River need to be enlarged by the consideration of the acquisition or special use zoning of adjoining private lands.
  • All public land should be managed for ecological outcomes.

6.7 Enhancing public land values

  • The often confusing question of who is managing public land needs to be unequivocally answered for community understanding.
  • The roles of government departments and authorities and local government need to be clarified and rationalized.
  • Indigenous communities should have increased involvement in management of public lands.


6.8 Supporting species and ecosystems in a changing climate

  • The community should not accept loss of species unless unavoidable due to climate change. However protecting ecosystems should have priority over protecting species in the decision making process as this is the most efficient way to protect species. Severity of climate change impact may require tough decisions down-the-track.
    Economic redirection into this area might be one of our most efficient and valuable investments.

6.9 Working towards a net gain in native vegetation.

  • Community education and compliance is needed with clearing controls. All offset plantings need to be monitored to ensure the offset is established and managed. The original Native Vegetation Framework came into effect in 1989 and twenty years later we still have not achieved net gain.
  • A net gain is more likely to be obtained by strong support for retention and regeneration of remnant vegetation

  6.10 Using and managing fire.

  • Restrict settlement growth in high fire risk areas as future protection is an unnecessary burden on emergency services.
  • Establishing strategic firebreaks and the strategic grazing of private lands can be used to enhance and protect local biodiversity.
  • Restrictions on campfires during the fire season on public land.
  • Native vegetation should not be the last asset considered once a fire starts, eg pine plantations are assets and native vegetation is sacrificed to protect these whereas we consider that at least equal priority should be applied. Native vegetation is a public asset with multiple values.
  • We agree that controlled burning may be required to protect public land assets into the future.

6.11 Improving management of pest and weeds

  • We must continue to support resources for landcare groups to tackle weeds in peri-urban areas.
  • We need to accept that some native species will increase their range with climate change.
  • Increased prevention and early intervention should be supported at all levels – prevention of importation, detection of new threats before they are established using government and community resources

 7.2 Using market based approaches

  • We agree that market based instruments enable public and private investment in a range of ecosystem services.  They should be promoted strongly by the Government as they allow private land managers to value biodiversity.  The issue of ‘duty of care’ has been raised but our experience is that well managed remnants will be more highly valued in a market based system and provide potential to enhance ‘duty of care’ obligations.
  • Never-the-less, we agree that MBI’s on their own cannot achieve the level of change needed. Dedication and commitment is needed “across the board”

7.4 Improving consistency in planning processes
The review and renewal of regional catchment strategies offers an opportunity for closer working relationships between CMA’S, local government and government departments.

  • We must align RCS’s and MSS’s
  • Regional catchment strategies should have greater influence on planning frameworks. Tools should be developed to firmly incorporate NRM decisions in planning zones and overlays.
  • The planning tools available in Victorian Planning provisions are not adequate to protect native vegetation.

7.5 Education and behavior change

  • The language used by practitioners of natural resource management is often confusing and misinterpreted by the community, a common language is needed.
  • Consideration should be given to a generic advertising campaign that would educate the community on what exactly biodiversity is and its benefits. This would assist greatly those on the ground implementing resource management policies.
  • Highlight the importance of all life forms, not just the “soft and cuddly”
  • Highlight soil as an ecosystem in its own right and not just a physical asset.

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