It would appear that the Consultation Draft is anti the natural environment, pro developer and Melbourne centric. The end result of the failure to adopt many of the proposals offered that would protect and enhance the biodiversity values within the urban landscape will be to eliminate most if not all of the natural environment from such areas. As a result the Draft if implemented will produce a significant reduction in the liveability and the environmental sustainability of Victoria.
Bendigo and District Environment Council Inc (BDEC) is a non-profit organisation whose main interest is the conservation of the natural environment and Australia’s progress towards the achievement of ecological sustainability.
"A society is defined not only by what it creates, but by what it refuses to destroy."
— John Sawhill, former president and CEO of The Nature conservancy.
Statutory planning Systems Reform
Department of Planning and Community Development
GPO Box 2392
Melbourne 3001
Date: 07/04/09
Re: New residential zones for Victoria, Consultation Draft
It would appear that the Consultation Draft is anti the natural environment, pro developer and Melbourne centric. The end result of the failure to adopt many of the proposals offered that would protect and enhance the biodiversity values within the urban landscape will be to eliminate most if not all of the natural environment from such areas. As a result the Draft if implemented will produce a significant reduction in the liveability and the environmental sustainability of Victoria.
This will suit developers but not the citizens of Victoria.
• Suburbia is where the developer bulldozes out the trees, then names the streets after them.
~Bill Vaughn
The Government should accept the need for change that brings greater protection to the natural environment within residential/urban not just change that suits the needs of developers.
The reasons for our disgust at the tardy performance of the government within this discussion paper are:
• An Urban Conservation Zone needs to be introduced for the protection of vegetation/biodiversity in urban areas. After all a natural environment protection zone now exists within rural. Such a zone is not being proposed within the Draft!
• The proposed new zones are development focused without adequate emphasis on the protection of the natural environment. ResCode needs to be reviewed so that adequate protections for biodiversity exist within it. This has not happened within the Draft!
• Greenfields development within regional Victoria requires a new zone whose purpose is the development of new residential areas within rural and regional areas. It is important that such a zone is created but what is being proposed, with the three zones, is nothing more than a better means of implementing Melbourne 2030 and will not serve the needs of country Victoria at all.
The belief that vegetation and its accompanying fauna can be shifted without loss if it is in the road of development to somewhere that will not be a bother to the needs of developers, in other words out of the road, is just a belief and does not stand up to scrutiny. This always leads to a net loss even though the Government has been changing the criteria so that a net gain can appear to be achieved. Pure Orwell!
The superior man seeks what is right; the inferior one, what is profitable."
— Confucius
We are now being presented with Precinct Plans as though they will be able to satisfy the needs of developers and the natural environment. But of course they are just business as usual, dressed up a bit to give the appearance that it will protect the natural environment, just because the Minister will not have a bar of the idea of a Conservation Zone for the urban areas.
What is actually happening is that the Government is dressing up the process of virtual vegetation protection to mind its own back so that it will not be blamed for the inevitable loss of biodiversity.
Shifting biodiversity to allow for residential development creates a net loss
The failure of Native: vegetation management – A framework for action:
Victorias’ ‘Native Vegetation Management – A Framework for Action’ (VPP) 52.17, deals with indigenous vegetation. If the Frameworks offset provision is used for issuing permits to clear native vegetation, a net loss will inevitably occur. The Framework does not have within its structure the ability to produce a net gain. Just saying that there will be a net gain does not make it so.
The primary goal for native vegetation management within Victoria of the Framework for Action is the achievement of “A reversal, across the entire landscape, of the long-term decline in the extent and quality of native vegetation, leading to a Net Gain”. Even with an incredibly narrow and unrealistic interpretation of net gain, the ‘Native Vegetation Net Gain Accounting first approximation report (April 2008)’found, that there has been a significant loss of indigenous vegetation across the state. After nearly six years the primary goal has not been met! A ‘Net Loss’ across Victoria of vegetation and habitat is what has actually happened! The report found that there had been a net loss of 4,000 HHa/yr. (Habitat Hectares per year)
We do understand that all forms of government, all government agencies, VCAT and even the independent panels within Victoria are compelled to comply with the planning regulations. Nevertheless, just because a government creates laws it does not mean that they are in anyway correct or that we have to agree with them.
The best biodiversity and landscape outcome is obtained by avoiding vegetation destruction.
It has become a habit within Victoria to allow vegetation in areas that are targeted for development to be cleared and traded out into chosen places where developers with large cheque books can buy and protect vegetation that will not damage their development plans. This is what Bush Broker helps to facilitate.
Even though the Framework has been a failure, everyone has had to comply with it, but we do not have to accept the stupidity of it. In fact the Framework’s ‘net gain’ term for the administration of native vegetation controls has become a convenient facade for the governments to hide behind when they allow vegetation to be cleared, thus protecting themselves from criticism.
Whenever the failed Victorian Planning Provisions inevitably allow vegetation to be cleared there are two ways the Framework provides for a replacement, so called ‘Offsets’.
1. An amount of existent vegetation is protected in another location to replace the vegetation destroyed.
As the vegetation already exists it is not a replacement and therefore not a ‘Net Gain’, it is in fact been a ‘Net Loss’. The cases where this has been used are where the loss of indigenous vegetation from one area has had to fund the saving of indigenous vegetation in other areas. In other words the government has so little regard for the natural environment that it will not fund the saving of such areas, but instead it will allow large areas to be effectively sold and cleared to fund the saving of other areas.
2. Planting out bare ground to replace an area allowed to be cleared.
This fails completely because biodiversity cannot be traded without a loss in value therefore leading to a ‘Net loss’.
Professor Hugh Possingham from the University of Queensland’s Centre for Ecology stated on the ABC’s Saturday Breakfast with Geraldine Doogue, 17Dec 2005: that “Biodiversity is not fungible, it is not possible to trade it from one place to another and hope to retain its value; biodiversity is dependent on where it is in the landscape (place) and when it is (time)”. Biodiversity is space and time dependant.
He also said that “My main concern is really about the fact that if you don’t involve reconstruction of habitat, if you just say ‘I’m going to conserve this 1,000 hectares if you let me destroy that 1,000’; in the end that just means we destroy half of everything, which isn’t at all acceptable. If you were going to turn 1,000 hectares into bare ground, or urban development, then you should have to turn bare ground into 1,000 hectares of native vegetation. Show me somebody’s who’s done that; show me somebody that reconstructed an ecosystem from scratch. Nobody’s done that. Ever! But terrestrial ecosystems, we’re not even sure we can reconstruct. If they are reconstructable, then that could take 500 years. So how are you going to do that?” it is true that “some things are mobile, some things will recolonise, but we already know many things will not recolonise places. That’s part of the problem; most of our threatened species are particularly poor dispersives.” He went on to say “The reptiles, the small mammals, we know the ones that are most threatened have poor dispersal capacity, and so they may not get there at all. So I think that is a fantasy, there is no record in Australia at the moment, of somebody reconstructing an ecosystem from scratch”.
‘Hence the Framework’s offsets are scientifically unsound’.
The policy of allowing vegetation to be destroyed and traded out is a smokescreen solution that has now become a part of the problem.
The failure of Bush Broker:
Market-based approaches may deliver financial rewards to business, but it is not a given that they will produce an improved natural environment.
“Bush Broker is a new scheme in which landholders can enter into agreements to permanently manage and maintain native vegetation on their property. To qualify for this scheme, vegetation must be permanently set aside through a covenant with the Trust for Nature or under an agreement under legislation. Native vegetation credits can then be registered then traded to third parties to offset proposed clearing at a separate site” (Whose Rights and Who’s Right? Valuing Ecosystem Services: International Landcare Conference, 8-11 October 2006). This leads to a net loss as the area that generated the credits already exists, the cleared area that uses the credits disappears, and therefore Bush Broker is a way of forcing the natural environment to sell a part of itself to save some other area, as has been described previously.
Bush Broker works in conjunction with the Victoria’s Native Vegetation Management – A Framework for action, a regulation that is detrimental to the natural environment. Bush Broker works against the primary goal of the Framework by concentrating vegetation within pockets (extent) rather than a reversal across the entire landscape. Biodiversity works at a landscape scale. Biodiversity concentrated into localised pockets leads to extinctions because species need to be present across and be able move through the whole landscape, for example, recolonising areas where local extinctions have occurred. Also Bush Broker is not required to match the vegetation or habitat that has been destroyed with like for like, it is a system of tradable environmental credits. Such credits may work with simple systems such as carbon but the natural systems are made up of a multitude of species that are connected in complex relationships that cannot be broken down to a simple unit of credit, then traded and reconstituted at a new location. As Professor Possingham has said, you cannot trade biodiversity across time and space and retain value.
Bush Broker is therefore playing its part in reducing the quantity and ecosystem quality and also the spatial aspect of biodiversity, simplifying the abundance of the natural world by reducing diversity. Even though Bush Broker is a process that fails the natural environment it is looked upon with favour because it fits into the economic belief systems that dominate present thinking.
The failure of Precinct Plans:
The Precinct Plans contain the ability to over throw vegetation protection by the application of permits to do so. Nothing more needs to be said, they will simply end up in VCAT and it will be business as usual.
It is wrong to assume that conservation will allow the biodiversity found within the City of Greater Bendigo to go peacefully into that dark night of extinction. It will not!
There is a price to pay for all things and the wonton disregard for the inevitable destruction of the natural environment brought on by the Minister’s indifference or perhaps ignorance, exhibited within the three zone proposal, to needs of biodiversity will make sure that we inform the citizens of Bendigo that it is the Government and specifically the Minister who is to blame.
We wish to present our submission to the Advisory Committee process.
D. Stuart Fraser
Convenor
