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Details of earlier submissions can be found here.

To Coordinator General, Office of the Coordinator General, Queensland May 2013

Wildlife Queensland is opposed to this project. Our principal concerns include but are not necessarily limited to:

• Additional threats to the health of the Great Barrier Reef Marine Park
• Impact on the species that inhabit these waters
• Water quality
• Increase in shipping
• Potential economic impact on the tourist and related industries

Any action taken to increase the threats to the Great barrier Reef World Heritage Area and its environs must be rejected or at least put on hold and reconsidered only when mitigation measures based on science to address the additional threats to an already stressed system are in place.

Outcome: No response to date

To State Development, Infrastructure and Industry Committee, Parliament House, Queensland - April 2013

This Bill on the whole will only exacerbate the downward trend in the decline of our biodiversity. It is a retrograde step for the environment and the greatest rollback of environmental protection ever witnessed. What is even more frustrating is it breaks an election commitment of Premier Newman to retain the existing level of protection that existed under the Vegetation Management Act 1999.

Major concerns

There are several major concerns from Wildlife Queensland’s perspective. These include but are not necessarily limited to the following:

• The potential for massive additional unnecessary clearing of Queensland’s vegetation. The possibility of broad scale clearing could undoubtedly emerge posing threats to Matters of National Environmental Significance triggering the Commonwealth EPBC Act.
• It will weaken protection of vegetation in a number of catchments throughout the state excluding the three Great Barrier Reef catchments still protected under legislation.
• The additional relevant purposes for which clearing applications can be made could see the reintroduction of broad scale clearing in a major way.
• The lack of scientific and economic rigour with the declaration of high value agriculture areas, irrigated high value agriculture areas and environmental clearing is a distinct possibility.
• The introduction of simplified ‘regulated vegetation maps’ will lead to inappropriate clearing of vegetation.
• The removal of near threatened species adds to the potential of the conservation status of such species being diminished.
• The removal of all the wild river provisions from the VMA will decrease the rigour under which clearing is assessed.
• The enforcement and compliance provisions have been weakened immensely with the expansion of defences and the removal of conditions under which forfeiture of leases can occur.
• There are concerns about the Ministers capacity and ability to make self assessable codes for a range of activities
  

There may be one positive. Wildlife Queensland advises that a self assessable code for the use and harvesting of mulga (Acacia aneura) for fodder would not necessarily be opposed.

Outcome: No response to date

To Senate Standing Committees on Environment and Communications, Parliament House, Canberra, ACT - April 2013

Wildlife Queensland strongly supports the inclusion of an additional matter of national environmental significance (MNES) in the EPBC Act to protect Australian water resources from the impacts of certain mining activities.

However Wildlife Queensland is of the opinion that further amendments are required.
The Bill should apply to any form of mining and associated industry that has the potential to impact negatively on our water resources.

Wildlife Queensland appreciates the difficulty in applying legislation retrospectively however the current exemptions are for too broad. Exemptions should not apply to any unapproved mining projects or to approved projects where works have not commenced. Existing bilateral assessment agreements relating to controlled activities that have the potential to impact significantly on water resources should be varied in order to comply with the ‘water trigger’ requirements.

Wildlife Queensland also would encourage the Government to amend this Bill to prohibit the devolution of approvals bilaterals to the States and Territories.

There is also an opportunity to address another gap in the EPBC Act. In the act MNES are only triggered if there is significant impact. Significant impact is not defined and it should be.

Outcome: No response to date

Department of Environment and Heritage Protection - March 2013

Wildlife Queensland supports the need for the review for the existing framework would expire and threatened species (ie extinct in the wild, endangered, vulnerable or near threatened) would not be afforded any protection.

Wildlife Queensland gives only qualified support to the policy objective. Wildlife Queensland strongly supports that threatening processes are effectively managed and the current conservation status of all protected plant species in Queensland is maintained or enhanced. Wildlife Queensland is not opposed to the sustainable take, use or trade of protected plants provided such activities are in accordance with all legislative requirements and ‘sustainable’ is adequately and appropriately defined. Wildlife Queensland is concerned over what is considered to be ‘a significant regulatory or administrative burden’.

Option 1 is preferred but could be enhanced to ensure compliance with the Nature Conservation Act. Wildlife Queensland would not necessarily be opposed to some change. A reduction of some permit or authority numbers and categories would not necessarily be opposed. Except for the removal of the requirement to undertake flora surveys, other refinements that would enhance efficiency may be supported.

Should option 2 be adopted then funding to the Queensland herbarium for surveys to address the existing knowledge gaps is essential.

Wildlife Queensland totally opposes option 3.

Department of Sustainability, Environment, Water, Population and Communities - February 2013

Wildlife Queensland strongly supports the establishment of the Marine Reserve Network and in particular the Coral Sea Marine Reserve.

Wildlife Queensland commended the Federal Government for the increase in the extent of the Marine National Park Zone for the north-western Osprey Reef. However other requested gains for conservation were not approved and there was a slight loss of some protected zones.

Wildlife Queensland has particular concern for the lack of protection afforded to sharks.

The fact that the term ‘sustainable use’ not ‘ecologically sustainable use’ occurred in several places was called into question.

The necessity for mid-water trawling in certain zones was queried. Furthermore commercial and recreational fishing needs to demonstrate that such activities are an ecologically sustainable use of the natural resources. The failure to condition shipping in sensitive environmental areas was raised.

A major concern for Wildlife Queensland was the statement ‘the intention to ban mining and oil and gas exploration’ and not an unequivocal ban. This has to be clarified. Wildlife Queensland has been generous in praise based on no mining.

Comprehensive research and monitoring programs to address knowledge gaps and outcomes are required to ensure the management strategies in use are appropriate. Furthermore the development and implementation of a robust compliance program was advocated to minimise illegal activity.

Finally the draft management plan was silent on the proposed management agency. Wildlife Queensland seized the opportunity to again recommend the Great Barrier Reef Marine Park Authority as being the logical choice an organisation with a well deserved reputation for marine park management. Additional resources would be required.

Outcome: No response to date

Comments on the Environment Protection and Biodiversity Conservation Amendment (Retaining Federal Approval Powers) Bill 2012 - January 2013

Wildlife Queensland cannot emphasise strongly enough our support for the amendments to the EPBC Act. As indicated biodiversity is in decline and in spite of the 1996 National Strategy for the Conservation of Australia’s Biological Diversity and the more recent Australia’s Biodiversity Conservation Strategy 2010-2030 several species continue to be lost and the conservation status of many species to decline with the resultant adverse impact for the environment. There is a crisis and this needs not only to be recognised but addressed. This Bill is but a small but essential step in attempting to ensure minimum adverse impact to our environment and its biodiversity.

If matters of environmental significance are likely to be impacted through development there must be a second independent opinion as to whether or not such developments should proceed.

The Commonwealth Government through their powers under the EPBC Act play a pivotal role in protecting matters of environmental significance and particular species. At times this is done by rejecting the proposed development such as in the case of the Traveston Dam. In other cases, the Commonwealth further conditions approvals given too freely by States for development that will boost the economy at the uncosted expense to the environment. The Commonwealth Government has been forced to step in and afford protection even to the iconic koala in Queensland and New South Wales.

This independent review triggered under the EPBC Act is particularly necessary in Queensland where there is no upper house of review. Furthermore it is needed in Queensland where unfortunately the current Government shows little care for the environment, appears to possess a clear lack of understanding for the need for a healthy environment and is certainly taking no steps to arrest the decline in biodiversity. The only steps being taken are to expedite development approvals and weaken environmental laws.

The Commonwealth Government has an obligation to afford protection to our biodiversity not only for its inherent right but for the enjoyment of today’s generation and the future generations. This will not be achieved by handing the responsibility for approving proposed actions that significantly impact on matters protected under the EPBC Act to a State or Territory. Wildlife Queensland urges support for the Bill.

Outcome: No response to date

Health and Community Services Committee - December 2012

The Amendment Bill impacts on three pieces of Queensland Legislation namely:

• Nature Conservation Act 1992
• Forestry Act 1959
• Brisbane Forest Park Act 1977

Wildlife Queensland is not opposed to increasing appropriate visitation to national parks but is strongly opposed to the amendments that facilitate the development of commercial tourist infrastructure within national parks. The demand appears to be driven by a sector of the tourism industry that has been advocating such access for several years and rightfully denied. Other strategies can be used to lift visitation and boost regional economies more effectively. Wildlife Queensland has some reservations about the superficially benign amendments dealing with service facilities. Wildlife Queensland opposes the amendments to the Act.

The amendments to the Forestry Act are designed to facilitate the mining and related industries at the expense of the environment. There is the potential for possible loss of control of government owned land by the lack of a strong compliance and enforcement program. These amendments do not have Wildlife Queensland’s support.

Wildlife Queensland supports the repeal of the Brisbane Forest Park Act as it is no longer required to guide the management and operations of the subject land.

Outcome: Submission acknowledged, no results to date.

Department of Sustainability, Environment, Water, Population and Communities - December 2012

In summary the Federal Government is to be commended for this significant initiative. It is appreciated that a balance is required between conservation and use. However some minor amendments would transform a good management plan to an outstanding management plan. Wildlife Queensland encourages the Federal Government to take that step. It can be achieved by the following:

• Move the western boundary of the National Park Marine Zone covering Osprey-Shark- Vema reefs 10 kms west
• Move the boundary of the National Park Marine Zone in the Southern Coral Sea south to 22° S reimbursing any commercial fishers impacted
• Commercial fisheries must be ecologically sustainable with trigger points defined
• Recreational fishing to be ecologically sustainable with consideration of bag and size limits and no take species where applicable
• Commercial and recreational boating traffic to be regulated and rerouted if necessary with adequate navigational aids provided
• An effective compliance and enforcement program in place underpinned by a robust educational program for all marine reserve users
• Additional Research and Monitoring be undertaken to address existing knowledge gaps.

Management of this multi-zoned managed area be undertaken by the Great Barrier Reef Marine Park Authority with the additional necessary resources.

Outcome: Submission acknowledged, no results to date.

Senate Standing Committees on Environment and Communications - December 2012

General comments highlighting issues including funding expended has not addressed the problem adequately, species at risk and ecological community loss continue to escalate, a planned approach is required to define targets shared by all Governments and a way forward agreed. Wildlife Queensland offers the following recommendations for consideration.

• Establish a shared vision of all Governments
• Develop and implement a strategy that directs funding to achieve the most effective outcome for biodiversity conservation
• Give priority to establishing a National Reserve System acquiring priority ecosystems in priority bioregions
• Consider funding systematic fauna surveys to address knowledge gaps
• Allocate limited funding on preventing large number of species from becoming at risk rather than large sums of funds on single species.
• Ensure that private sector driven conservation is an essential component of the biodiversity conservation strategy with some financial assistance if and when required
• Implement capacity building and educate the broader community about the values and benefits of biodiversity conservation.
• Develop expertise in addressing problems arising from climate change
• Feral animal and invasive plant control programs must be maintained. High standards of biosecurity must be maintained.

Wildlife Queensland knows the current approach is simply not working. Business as usual is not the way to go. Funding has to be not only directed at research on flora and fauna and acquisition of land but to programs what may appear marginal to the objective. Such programs include education and capacity building, incentives for private sector biodiversity conservation as well as biosecurity.

Outcome: no results to date.

Agriculture, Resources & Environment Committee – August 2012

A joint submission with various like minded groups advocating that the Amendment Bill introduced by Mr Shane Knuth MP is unjustified, unethical and legally flawed should be rejected.

The Bill is intended to reduce the risks of people catching infectious diseases from Flying foxes. As long as people do not handle flying foxes, having roosts near residences is safe. The extreme measures proposed in the Bill would result in widespread animal cruelty.

It was recommended that the Queensland Government adopts a one Health policy that recognises human health and environmental health are interlinked

Outcome: No results to date.

The Research Director, State Development, Infrastructure and Industry Committee
– August 2012

In June 2012 the Queensland Parliament referred this inquiry to the State Development, Infrastructure and Industry Parliamentary Committee. Wildlife Queensland took the opportunity to make a submission by the closing date 3 August. Following an appearance before the Committee Wildlife Queensland forwarded additional material as requested later in August. The thrust of the submission was that rural leasehold should be retained with the Delbessie Agreement in place. However the Agreement needs to be strengthened. Expansion of the Protected Area Estate including national parks must continue and the cardinal principle of management maintained. Nature based tourism has its place but it must be secondary to the cardinal principle of management. New categories of nature refuges must be created so some are exempt from mining by amending the Nature Conservation Act. The Stock Routes Network Management Bill 2011 should be enacted unchanged to afford greater protection to our biodiversity while its primary purpose is to meet the needs of travelling stock. There is also a need to ensure the rights of landholders and leaseholders are protected. During the brief appearance before the committee Wildlife Queensland elected to focus on nature refuges and the Stock Routes Network knowing other conservation groups would more than adequately address other areas of interest.

Outcome: The Committee is required to report back to Parliament by 30 November 2012.

The Chair, Animal Welfare Advisory Committee, Department of Agriculture, Fisheries and Forestry – July 2012

To honour an election commitment the LNP Government is reintroducing lethal Damage Mitigation Permits for protecting orchards against flying foxes. This is occurring in spite of the fact that the proposed means have been declared inhumane and cruel by the Governments Animal Welfare Advisory Committee and two species involved are listed under the Commonwealth EPBC Act. A submission was made in an attempt to minimise environmental harm and address animal welfare issues. The issues raised in the submission included suggested quota limits, establishing other approaches to crop protection have failed, means of take and code of conduct, minimising suffering to targeted species and the young left behind, effectiveness , the need for monitoring and a review of the effectiveness in protecting the crop. Minister Powell encouraged active interaction with staff and opportunities were provided to have input. The Wildlife Regulation will be altered to accommodate this inappropriate practice.

Outcome: Wildlife Queensland condemns the reintroduction of lethal DMPs. It is our understanding that some points made have been incorporated in the guidelines. However until the new regulations are gazetted and permits issued the amount of environmental harm that will occur as well as animal welfare issues will remain a matter of conjecture. One thing that is certain is flying foxes will be killed.

EIS project manager-Nathan Dam, Significant Projects Coordination, Department of Employment, Economic Development and Innovation – June 2012

Wildlife Queensland forwarded comments on the EIS to the Coordinator General on this project. Wildlife Queensland has opposed this development in the past and its position has not changed. The business case for the construction is inadequate. There is a reliance on dated data and information. The company indicates a willingness to provide offsets for the environmental damage and harm that will occur but such offsets are not specified and in fact have yet to be finalised. Harm will occur to threatened species and plant communities. In particular there are population estimates of the critically endangered boggomoss snail that are challenged by Dr John Stanisic, a leading and recognised snail expert. The potential impact on groundwaters and the Great artesian Basin are not adequately addressed. Dealings with Traditional owners have been called into question. There are other broader issues that require further consideration. At the very least a supplementary EIS is required prior to any ordered decision making process being initiated.

Outcome: None to date.

EIS project manager-Nathan Dam, Significant Projects Coordination, Department of Employment, Economic Development and Innovation – May 2012

Wildlife Queensland wrote to Hon Tony Bourke requesting a statement of reasons under the Administrative Decisions (Judicial Review)Act for his decision to approve these two projects. Wildlife Queensland had to establish its credentials to make such a request. Under the relevant legislation Minister Bourke must respond within the specified time period. The purpose for this action is to explore if matters raised in submissions were adequately addressed and to determine if there is scope for further action.

Outcome: The statement of reasons was received but Wildlife Queensland elected not to take any further action. However Connors Dam is not proceeding following a decision by the newly elected LNP Government.

Mr John Cotter, Chairman Queensland Gas Fields Commission – May 2012

Comments were made to the Commissioner on the role, function and powers of the New gas Fields Commission. Wildlife Queensland recommended that the Commission must provide an independent oversight over the industry. It must have the necessary powers to seek information and obtain data from all sources. In its operation and function it must be transparent and accountable. It is necessary to report to the public. Naturally it must have or have access to the necessary expertise to function effectively and efficiently.

Outcome: While the powers and functions will not be finalised until later in the year when legislation goes through the parliamentary processes the powers fall into seven broad categories:

• Ability to assess the potential for co-existence
• Powers to get information
• Powers to publish and communicate information
• Ability to seek external advice
• Powers to review regulatory frameworks and legislation
• Dispute resolution
• Leading practice/management.

Wildlife Queensland’s submission was one of 55 submissions forwarded for consideration. The likely outcome reflects many issues that were raised in the submission.

The Commission is also recommending that the scope of the Commission should be widened to include all onshore gas fields, transmission pipelines and related activities due to synergies with CSG.

Business Entry Point, Environment Assessment Branch, Department of Sustainability, Environment, Water, Population and Communities – March 2012

Wildlife Queensland forwarded a submission on these guidelines. These guidelines appear to address many of the concerns raised by Wildlife Queensland. There is strong support for 5.7 Alternatives to the Proposal. The company has stated that a number of sites had been or are currently under consideration. Justification for this site is called for. In addition the detailed requirements outlined will certainly enhance the information base on which to base a decision. There is also strong support for cumulative impacts to be addressed. Overseas literature has indicated that the design of the turbines can have a significant influence on a range of matters including but not limited to bird strike, noise and light impacts. Details on such matters including consideration of alternative designs should be addressed. Wildlife Queensland notes reference to the use of offsets. Wildlife Queensland is opposed to the use of offsets as, in spite of the qualifications in the guiding principles, the use of offsets permits too much development in areas where development should not occur. It is suggested that it would be extremely difficult to locate and secure appropriate offsets to compensate for the environmental damage this proposed development could cause.

Outcome: Final guidelines yet to be released.

MPS Submissions - Coral Sea, Department of Sustainability, Environment, Water, Population & Communities – February 2012

Wildlife Queensland commends this initiative but recommends that this opportunity be seized to deliver the world’s largest highly protected marine area.  This opportunity must not be allowed to escape without the most desirable outcome. There is community support for such action. The economic cost and social impacts are minimal. What is required is:

• Expansion of the Marine National Park to include all reefs
• Enhanced protection of Australia’s largest Trough System and the Southern Coral Sea
• A ban on all fishing.

Outcome: Wildlife Queensland was one of over 450 000 submissions.  The draft plan is still under review.

Referral Business Entry Point, EIA Policy Section (EPBC Act), Department of Environment, Water, Heritage and the Arts – January 2012

Wildlife Queensland commented on the proposal to the Commonwealth Department of Environment, Water, Heritage and the Arts advocating opposition based upon
acknowledge gaps in flora, fauna and the potential impact of the proposed development. In particular, threats to endangered species especially the northern quoll and several plant species as well as threatened plant communities were highlighted. In addition there were potential threats to migratory species. The proposed project also triggered at least three key listed threatening processes under the EPBC Act.

Outcome: The Commonwealth Government required an EIS to be prepared and declared it a controlled action under the EPBC Act.

The pursuit of effective conservation strategies should be underpinned by sound policies.  Wildlife Queensland has a number of current policies on major issues that contribute to the achievement of the objects of the Society as set out in its constitution.

Current policies include:
• Biodiversity conservation
• Coastal Development
• Endangered Species
• Forests
• National Parks
• Operations Spotter Catcher
• Population
• Vegetation Management
• Water Cycle Management
• Wetlands Protection
• Wild-dog & Dingo Management
• Wildlife Management
• Zoos

A copy of any of the above policies is available to members by contacting Policies and Campaigns Manager.  Should non-members be interested please contact our Policy Division to discuss the issues.