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					Flora and Fauna Guarantee Act 1988
Scientific Advisory Committee
c/- 2/8 Nicholson St., (PO Box 500) East Melbourne 3002

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                                                                                                                 FLORA & FAUNA
Date: 3 July 2008

Project Director,
Land and Biodiversity White Paper,
Department of Sustainability and Environment,
PO Box 500
East Melbourne VIC 3002

                           Land and biodiversity at a time of climate change - Green Paper
                   Submission by the Flora and Fauna Guarantee Act Scientific Advisory Committee

Dear Director,
As a committee, we are pleased to see the review of approaches to management and proposed simplification of
process in land and biodiversity management. The intent for changes to legislation to streamline management
have much potential to improve on-ground and in-water management and to direct resources more appropriately
to where they are required.
  However, there is clear need to ensure that Victoria’s biodiversity is adequately protected by these legislative
and procedural changes and that the purpose and function of the Flora and Fauna Guarantee Act 1988 (FFG
Act) is not diluted. Likewise, ecological processes and the diversity of natural habitats must be sustained. This
response is not a comprehensive appraisal of the Green Paper. Rather, it summarises some of our concerns on
major considerations, concentrating on those issues of particular relevance to the FFG Act and Victoria’s

The Green Paper and the FFG Act.
It is interesting to note in the Green Paper the apparent attitude of the Department of Sustainability and
Environment (DSE) to the Flora and Fauna Guarantee process. We are extremely concerned with what follows
and feel that we are unable to respond in the detail required; it is perhaps also inappropriate to do so here. We
hope that the expertise of the Scientific Advisory Committee (SAC) may be involved more closely in the
process in future, including involvement in development of the Victorian Biodiversity Strategy.
On page 28, we read:
“Victoria’s approach to threatened species protection is scientifically rigorous but with current investment the
listing process and the development of management plans and on ground actions isn’t keeping pace with the
number of species or decline rates. Fundamental decisions need to be made about the level of resources that
can be invested in this area and whether we want to continue to aim to protect all species.”

The important notion in this statement is reference to the current investment. Investment by the state was
considerably better when the act was introduced but as the number of species, ecosystems and threatening
processes have continued to increase, the amount of investment has continued to decline, a trend we deplore and
urge be effectively redressed. We have expressed our concern about the delayed production, and poor quality of
FFG action statements resulting from our recommendations, for some time but this has been largely ignored.
Federal funding over this period is still not adequate.

On page 65:
“Notwithstanding the need to delay any legislation review until after the policy framework is developed, there
are certain elements of existing legislation we know hinder land and biodiversity management activities. For
example, the Flora and Fauna Guarantee Act 1988 states that the principal objective for threatened species
recovery is “to guarantee that all taxa of Victoria’s flora and fauna …. Can survive, flourish and retain their
potential for evolutionary development in the wild”. Given the magnitude of the likely implications of climate
change, while this goal is laudable, it is probably beyond our management capacity and could be revised to a
more realistic objective.”

                                              c/- 2/8 Nicholson St. (PO Box 500), East Melbourne VICTORIA 3002
In the above two quotes we have the DSE summarising their view that their operation of the FFG Act since its
inception has hindered biodiversity management activities and failed due to inadequate investment to allow it to
operate well.
  Nevertheless, under the Act and the principles it was designed to embrace, we cannot condone any move to
weaken its scope, or for deliberate neglect of any aspect of biodiversity conservation within Victoria. Rather, the
priority must be to address what remedial measures can be instituted rapidly to deal with the “hindrances” and to
ensure that current investment is adequate. Assumptions are made here that major changes are required in the
FFG act. These are discussed below.
It is a recurrent theme throughout the Green Paper that not all species or ecosystems will be targeted, suggesting
that the decision to proceed in this manner has already been made. If so, this is deplorable, and admits major
weakness in the ‘system’
On page 28 is: “New paradigms are needed that guide programs to respond to well defined problems and direct
interventions towards multiple outcomes rather than single issues or problems.”
The SAC considers that adequate knowledge is not available to ensure that these proposed changes would be
measurable or successful.
On page 53 there is: “Given our finite resources, most effort should be directed to on-ground action to
implement and monitor recovery plans, rather than listing processes and planning. Investment should be
targeted to actions which will do the most to reduce the risk of extinction. We also need to implement adequate
monitoring programs to determine whether our interventions are effective.”
Again, a very important decision appears to have been made already without the basis of the decision being
discussed. Given that listing under the FFG is a result of individual nominations of species and other entities,
and is NOT a planned program, there are large gaps in the list as it stands. To help overcome this problem, the
department has its own lists of threatened species (Advisory Lists). Even with these lists, there are probably far
more threatened species (particularly of invertebrates, fungi and non-vascular plants) absent from the combined
lists than on them. A major stumbling block has been non-action from the existing lists, through expeditious
development of practicable Action Plans and pursuing these in practice.
Also on page 53, the following questions are posed:
What should the renewed Biodiversity Strategy focus on for the next 10 years? How can we address these
These questions are too long and involved for us to answer here and again we suggest that the SAC could
usefully be more involved in the future planning of the white paper.
Some other issues of concern to us are as follows, not in any particular order:

1. Providing protection of biodiversity using market approaches.
Market approaches such as Bush Tender are excellent in agricultural and peri-urban areas and warrant increase
in scope and efficiency. However, the most valuable ecosystems are those that are least modified and it is
difficult to see how appropriate markets can be developed that protect these to the fullest extent, perhaps
particularly when they are on private land. Extension of these types of markets to estuaries and marine
environments is particularly problematic.
  The approach as outlined suggests that emphasis is given to finding what markets exist already or can be
developed and how they can be utilised. It does not focus on what can be done and the best way to achieve an
optimal outcome. Adequate funding must be assured to develop any market approach.
  The use of carbon trading to encourage investment in riparian zone revegetation is appealing but does carry
risks. While there are potentially large sums involved, if not well managed it may have only mediocre
biodiversity outcomes. Other market schemes may have potential negatives that need to be closely monitored.
For example, little is known about the impacts of tree planting on other aspects of biodiversity, particularly
bryophytes, fungi and invertebrates. Incorporating these aspects into management, in addition to considering
vertebrates and perhaps also targeting threatened species could substantially augment effective biodiversity

2. Prioritising of species/issues/ecosystems to be protected.
The assumption is made here that we cannot preserve all species or ecosystems and therefore should not try to
do so. This is an ill-conceived and unethical approach. The statement is made on page 2 of the green paper that
“Our past actions have reduced Victoria’s biodiversity, making our ecosystems vulnerable to change.”
  Clearly, further reduction will lead to greater vulnerability. The targeting of species and ecosystems assumes a
degree of knowledge far above our current levels. Until more is known about ecosystems to allow such
selections, and the implications of making such selections, it remains unambivalent that we must aim to protect
as many species and ecosystems as possible.
  In part 5.1 vision framework, it is not apparent how Outcome 1 will be achieved as the long-term goal to
maintain and enhance natural capital relies on only targeted species and ecological communities being secured.
In our view natural capital cannot be maintained simply by conserving a limited subset of current biodiversity

3. Over emphasis on vascular plants, particularly over storey species
It is obvious throughout the Green Paper that the most frequently employed indices for appraising biodiversity
and management measures are currently based on vegetation. This is despite published information that these
measures are not appropriate for reptiles or invertebrates. The proposed headline indicators in section 8.3,
understanding the impact of our actions, are highly unlikely to provide the required information on land,
particularly in aquatic environments, and certainly in the marine environment.

4. Inadequate baseline data, research and monitoring.
Due to lack of investment, little research is carried out on threatened species or biodiversity in Victoria and it
overwhelmingly targets terrestrial and freshwater ecosystems, to the neglect of most marine and estuarine
ecosystems. Almost no research is carried out in Victoria on particularly important components of major
ecosystems, particularly those ecosystems that provide many of our economic resources. Leaf litter invertebrates
and mycorrhizal fungi both have major roles in forest ecosystems and are particularly poorly known and
understood. Lack of taxonomic study of a wide array of marine and terrestrial taxonomic groups will ensure that
there will not be sufficient information in the near future. Clearly focused studies of the function of the
ecological roles, responses and impacts on these groups are crucial in the short term, together with selection of
appropriate indicator groups through which to monitor for change in conservation status. Appropriate headline
indicators for various ecosystems and biodiversity need to be developed rapidly, then implemented.
  Ecological understanding of even our major biomes is very limited and it will be a long time before it is
possible to set their sustainable limits. Thus this proposed headline measure for ensuring that our economy is
viable and sustainable will not be measurable for some time.

5. Biodiversity on private land.
The enormous difficulties of managing biodiversity on private land can be addressed in part by market forces.
The SAC believes that it is important for these initiatives to be based on the best possible science to maximise
the benefit gained. Experimenting with market forces should be carried out in areas where improved outcomes
can be reasonably anticipated, rather than on public land where there is risk of further biodiversity decline.
Should you have any queries on this submission please feel free to contact the Committee via the SAC
Executive Officer (Martin O’Brien) on 9637 9869.
Yours sincerely,

Prof. Tim New
Scientific Advisory Committee


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