BREC Response to DNR Regional Vegetation Management Planning Options paper dated 3rd April firstname.lastname@example.org
Following the release of Options paper on RVMP Process, alarm is expressed at the total lack of any form of transparent or accountable process, which has placed at risk over 60,000,000 ha of forest and woodland ecosystems. These not only represent a significant contribution to forest types throughout Australia, but they also contains one the greatest numbers of bushland and rangeland animals in Australia.
The Vegetation Management Act should be proclaimed including Of Concern Ecosystems. A process of making declarations regarding areas of high conservation and areas vulnerable to land degradation should be immediately commenced. These areas that have been identified by a prior processes involving public consultation such as planning schemes should be declared immediately.
Data sets such as biodiversity, refugia, degradation and salinity risks should be made available to major stakeholder groups at no cost. The government should consider staging the RVMP process across the state rather than starting then all at once.
It is essential that an immediate moratorium on further tree clearing in selected regions that are already experiencing high levels of clearing during the preparation of RVMPs.
It is essential given the poor protection provided by the VM Act that other processes to protect vegetation such as Local Laws, Planning Schemes, Catchment Plans, voluntary strategies, Coastal management plans, Regional Plans and Conservation strategies are still progressed.
Financial measures for vegetation protection should continue to be pursued including biodiversity and source water protection payments. The government should be prepared to borrow the money to pay for these measures rather than having to beg the Federal Government to protect Queenslands unique wetlands, rivers, forest, bushlands and rangelands.
Part 2 - Principles underlying regional vegetation management planning and the establishment of RVMCs
This part makes no mention of ecological values or processes and is highly production orientated
Nature is a stakeholder in this process and if its needs and requirements are not met we will pay a high price in terms of species loss and land degradation.
Part 3 - Terms of Reference
The VMA sections 11,13,69 and 70 are relevant in this regard.
VM Act Sec 11- "The Minister must prepare and make Regional Vegetation Management plans "
No timeframe or order is specified in the Act.
VM Act Sec 13. The Minister must consult with the following entities in preparing a RVMP
(a) an advisory committee established to advise the Minister about vegetation management,
(b) the relevant regional vegetation management committee and
(c) each local government whose area is affected by the plan
But Sec 69 & 70 both say the Minister only may establish committees not must.
So if VM Act Section 13 says the Minister must, then he MUST despite Sec 69 & 70 establish MAC VM and RVMCs BEFORE preparing a Plan. The current DNR proposal of establishing local groups first and only forming regional committees later is against the Act.
The terms of reference must explicitly contain the purposes of the VM Act as "outcomes for vegetation management", and are defined in the VM Act as achieving the Acts purpose.
VM Act Section 3
To regulate the clearing of vegetation on freehold land to -
Preserve the following :-Remnant E and OC Ecosystems, Vegetation in areas of high nature conservation and areas vulnerable to degradation and
Ensure that the clearing does not cause land degradation and
Maintain or increase biodiversity and
Maintain ecological processes.
The RVMP must, not should recommend areas of high Nature conservation values or areas vulnerable to degradation.
The RVMC needs a specified budget and the power to commission research.
In SEQ DNR should also meet with - BRMG Reference Group,SEQWQS Industry Community Advisory Group, BRMG Indigenous Reference Group & Turrbal Ass., SEQ Regional Landscape Strategy Advisory Committee,SEQ Regional Nature Conservation Strategy Advisory Committee, SEQ Natural Resource Strategy Group, Regional Conservation Councils, Moreton Bay Alliance, BCC Bushlands, Wetlands and Waterways Advisory Committee and Citywide Catchment Committee.
and involve them in decsion making about Regional Committees, working groups, selection process of members,Terms of Reference and public involvement strategies.
Part 4 - Boundaries
A modified form of the IBRA bioregions should be used
SEQ should be split into North and South
Mulga Lands split into East and West
Brigalow Belt into North, Central and South
Any future subregional planning should be done most preferably on a catchment basis in SEQ.
The 40 local working groups proposed by DNR are rejected, because it inevitably leads to inconsistent outcomes and approaches
The Bioregional Vegetation Management Committees should establish a public involvement process to define and establish sub regional planning areas.
Part 5 - Membership of RVMC etc
b) The list of skills required by RVMC members in the DNR options paper doesnt include knowledge of regional landscapes, regional vegetation management, wildlife or ecological systems.
The issue of aboriginal representation and involvement on RVMPs in SEQ should be referred to Chris Hubbert spokesperson for the Southern Qld Traditional Owners Association and relevant native title bodies must be notified prior to the preparation of any RVMP.
As the government and departments get the final say on plans the state government representatives should have NO VOTE on the committee.
Two Industry members
Two Conservation Members
Two Members LGA
Three advisory members from State Departments including EPA DNR
Up to three additional members should be selected through a public nomination process with the RVMC to be the selection panel.
b) Chair of Committee
Chairs of the committee should be selected in a process determined by the committee ie either elected or appointed by the RVMC after public nominations.
c) Nomination of selection process of Committees
Nominated by sectors and/or selected by RVMC after public nomination process. All committee member appointments should be confirmed by Minister.
Part 6 - Scientific/technical advice
All RVMCs need access to this sort of advice. The RVMC could determine to have a scientist as an additional member or they may just call on advice from time to time or even commission research. Each RVMC must have a budget for this advice.
All drafts of RVMP should have scientific/technical scrutiny and legal review.
Part 7 - Operations
a) Reporting Arrangements
The RVMC should issue minutes and progress reports to the public and interim discussion documents.
b) Decision Making
Should seek to reach general agreement but can make a majority decision with 75% margin with dissenting views being recorded and included in draft and final reports.
c) Consultation Role of RVMP
The RVMC should seek the active wider involvement of the wider public not just run some flimsy consultation process.
d) Advisory Role of RVMC
The minister should issue a report responding to the advice from RVMCs
RMVP should have their principles endorsed by stakeholders before drafts are prepared.
Part 8 - Sitting Fees
Sitting Fees and reasonable expenses eg travel, phone and accommodation should be provided to members of RVMCs.
Reasonable expenses should be met for members of any sub regional working groups.
see also http://ozecol.org/RVMP