Submission to Australian Treasury’s Measuring What Matters

Submission to Measuring What Matters

 The Australian government is to be congratulated on its initiative to expand budgetary reporting measures. Focusing traditional reporting on macroeconomic measures such as GDP has been premised on the understanding that a dynamic economy will necessarily lead to high levels of community and individual wellbeing. Researchers such as Pickett and Wilkinson, for example, have challenged this view, emphasising the importance to wellbeing of limiting social inequalities in wealth and income.

I therefore strongly support the following statement in Budget Paper 1 Statement 4 at page 123:

…the central challenge of progress reporting is bringing attention to the broader factors that underpin community well-being and longer-term economic prosperity…

Indeed, the very notion of ‘progress’ needs to be considered anew. Our society is facing significant challenges this century due to multiple environmental threats, of which climate change is just one. The 2021 State of the Environment report conveyed the growing consensus amongst scientists that:

Environmental degradation is now considered a threat to humanity, which could bring about societal collapses with long-lasting and severe consequences.

Environmental degradation is largely driven by consumption. Over the last century, resource and energy consumption have closely tracked GDP, so GDP can also be considered a rough indicator of environmental damage. Ecological footprint analysis suggests that humanity is already consuming and polluting annually at about 1.7 times the rate that natural systems can regenerate and remediate. Ecological economists such as Professor Robert Costanza argue that much economic growth over recent decades has been ‘uneconomic’, in that it has been achieved through the liquidation of natural capital that has been inadequately accounted. In the longer-term, community wellbeing will not be improved or even maintained by simply optimising traditional macroeconomic indicators. We must also track environmental health.

I therefore recommend that the choice of measures sit within a coherent conceptual framework with strong program logic. In particular, the indicators should reflect that a healthy natural environment is not merely of aesthetic and recreational importance, nor even just of fundamental importance to industries such as agriculture and tourism. Rather, as has long been understood by First Nations peoples, a healthy environment is critical to broader human wellbeing and the sustainability of our societies.  As we enter the sixth great global extinction event, it also behoves us to accord nature an ongoing right to exist, independent of its values to humanity.

The most significant challenge in the choice of environmental indicators is reflecting the extraordinary complexity of natural systems. The measures must go beyond simple accounts of natural resources. Taking an ecosystem services approach would provide one useful framework.

Similarly, the Planetary Boundaries framework developed by the Stockholm Resilience Centre could summarise the levels of some significant environmental threats. Researchers have recently used the framework to determine how Australia is placed relative to these ‘boundaries’.

The health of the natural environment and its capacity to support human society goes beyond the presence or absence of discrete material entities, such as individual species. The environment is best considered as highly complex systems and processes. Treasury would do well to seek the advice of expert natural environment scientists as how best to measure the health of these aspects.

Unfortunately, Australia’s has poorly resourced environmental data collection; we currently do not have a comprehensive system for monitoring of environmental health. This contrasts with the situation for national collection of data for weather and climate, earth science, and demographic and economic measures. This need has been identified in Australian government reports over the years, including the 2021 National Research Infrastructure Roadmap. This gap will need to be addressed if Australia is to adequately monitor our environmental health, including its capacity to sustainably support high levels of community wellbeing.

I would be pleased to expand further on the matters raised in this submission. I can be contacted on 0415 253 684.

Yours sincerely

Jonathan Miller

Director

8 January 2023

 About the author

I am a trained ecologist and have worked for the Australian and ACT governments on environmental and economic policy, as well as a parliamentary advisor. I now work independently to promote the need for the development of environmentally-sustainable and socially-just. I have established Steady State ACT as a vehicle for this work.

Submission to the Independent Review of the Environment Protection and Biodiversity Conservation Act 1999

About Steady State ACT

Steady State ACT is a non-government organisation which is committed to:

– raising awareness of the material limits to economic growth;

– raising awareness of the need to move away from economic growth policies and

– promoting the critical need to move to a steady state economy.

Steady State ACT is the ACT chapter of the international Center for the Advancement of the Steady State Economy. Its website is at www.steadystateact.org

Jonathan Miller is the Director of Steady State ACT. He has a background in public policy, ecology and economics and has worked with the Commonwealth and ACT governments on the environment, the economy and foreign affairs. He spent eighteen years working in the Commonwealth environment portfolio, including managing at different times natural environment heritage assessment and the Commonwealth threatened species, invasive species, wetlands and migratory species programs.

 Key points raised in this submission

  • The review should consider the operation of the EPBC Act in a broad context, recognising
    – the dependence of the wellbeing of Australians on the maintenance of our natural environment and
    –  the magnitude of the threats posed to the wellbeing of Australians by the degradation of the natural environment in Australia and globally.
  • The EPBC Act is failing in its role of protecting the Australian environment.
  • While there may be opportunities to reduce the time taken for EPBC Act approvals processes, a far higher priority is enhancing environmental protection under the Act.
  • Commonwealth environmental legislation should be broadened to
  • take into account the likely direct and indirect greenhouse gas impacts of proposed developments
  • conserve soils and inland surface and underground waters
  • redress Australia’s completely unacceptable levels of vegetation clearing.
  • Wherever possible, proposals should be assessed collectively for their impacts on environmental factors (such as matters of natural significance) or regions, rather than in isolation.
  • Consideration should be given to establishment of a separate authority to make decisions under the Act, to remove them from the direct political sphere.
  • Further advice in relation to the recovery planning and threat abatement aspects of the EPBC Act are in Attachment 1.

 Australia’s natural environment is critical to our wellbeing, it is degraded and faces major threats

While the terms of reference for this review are limited to the operation of the Environment Protection and Biodiversity Conservation Act 1999, it is critical that the operation of the Act be placed in a much broader context. First, the review should consider the relationship of the legislation to broad societal views on the environment and the economy. Secondly, the review should consider in the broadest manner the significance of the natural environment to the wellbeing of Australian society.

Neoclassical economics informs the basis upon which Australian governments operate: that our natural environment is an ‘externality’ from which resources are to be extracted for human benefit. Consistent with this paradigm, Australian governments give paramount priority to increasing gross domestic product, for which environmental protection will routinely be compromised. The very use of the term ‘approvals process’ makes clear that it is expected that development proposals will be approved. This has indeed been the outcome; as of 2015, almost 98% of proposals submitted under the EPBC Act had been approved[1].

A healthy natural environment is generally portrayed in the media as providing aesthetic or recreational benefits, but it is critical to sustaining human life. Humans are an animal like any other and we require a healthy habitat to provide for our needs. Arguably, a more biocentric, rather than anthropocentric, values system would serve humans better, as well as the myriad species with which we share Planet Earth.

With every year, this need for humans to see ourselves as within and dependent upon, rather than separate from, the natural world becomes increasingly clear. Our extractive relationship with nature has brought us to a point where global environmental damage threatens to significantly disrupt human civilisation this century. In 2009, leading climate change scientist, Hans Schellnhuber, estimated that under feasible climate change scenarios, Earth’s carrying capacity could be reduced to one billion people, in contrast with our current 7 billion. On the release of a 2019 biodiversity report, the United Nations warned that

Nature is declining globally at rates unprecedented in human history – and the rate of species extinctions is accelerating, with grave impacts on people around the world now likely.[2]

The report stated that one in four species globally were at risk of extinction.

World-leading energy expert, Vaclav Smil, has warned of the need for radical change to our economic models, and that the long-term survival of our civilisation will require placing limits on the scale of global economic activity.[3]

These trends and future threats are repeated in Australia. The Commonwealth’s 2016 State of the Environment Report found that[4]:

Based on the information available about vegetation extent and condition, and the small number of species for which there is some understanding of trends in distribution and abundance, the status of biodiversity in Australia is generally considered poor and deteriorating.

That report also determined that

In Australia, the key drivers of environmental change are population and economic activity.

Australia is the developed nation which is the most vulnerable to climate change[5]. The threats posed to Australia by climate change are well known and will not be canvassed comprehensively here, but they will potentially affect our natural environment, our economy, our national security, and our physical health and broader wellbeing.

Within this context, it is clear that the maintenance of our natural environment is of the highest importance. The most significant factor in conserving our natural environment is a broad understanding within the Australian society of this importance. This awareness appears to have increased dramatically over the last year, but is still not reflected in many decisions made by Commonwealth and state governments.

The EPBC Act is failing and needs to be improved

As this review’s discussion paper suggests, legislation is just one of several mechanisms the Commonwealth can use to conserve the natural environment, and the states and territories are major players in land and biodiversity management. So, the condition of our natural environment is not solely an indicator of the effectiveness of the EPBC Act, but the number of threatened species demonstrates that the Act is not working. As of 4 December 2019, 517 animal species were listed as threatened under the Act, including 54 which were extinct, with 1373 species of plants listed, of which 37 were extinct. These numbers reflect merely those species which have been through the administrative process and may well be significant underestimates of the true situation. Moreover, the fact that the Carmichael coalmine could be approved with its huge carbon footprint, significant use of Artesian water and its biodiversity impacts speaks volumes for the inadequacy of the Act.

This review was launched with an over-riding message that its priority was to find ways to ‘reduce green-tape’ and to speed up approval processes. It is the case that some approval processes take some time, and given that environmentally damaging proposals are nearly always approved, it could be argued that these long processes serve the interests of neither the environment nor the proponent. In many cases, the proposals should have been dismissed much earlier in the process. Given the parlous prospects for our natural environment, this is not the time to be further weakening environmental approval processes nor to be reducing community involvement, including powers to challenge approval decisions.

Commonwealth environment legislation should be strengthened to protect our natural environment, commensurate with its importance and the grave threats it faces this century. At the very least, the Act needs to be modernised to consider the direct and indirect greenhouse gas impacts of proposed developments. Currently, national environment legislation is mainly restricted to matters of national environment significance. The future of the Australian economy, human livelihoods, biodiversity and our broader national wellbeing are dependent on conserving our natural resources.  National environment legislation should encompass protection of all relevant natural elements, including soils and water. Australia has an appalling record in relation to land clearing, and Commonwealth legislation should also seek to prevent this. These changes would require further consideration of the settlement of such responsibilities between the Commonwealth and the states and territories.

The EPBC Act generally assesses each development application in isolation. This does not allow for assessment of the aggregation of impacts as they might apply to a region or to a species. The outcome is the ‘death by a thousand of cuts’, as developments incrementally impoverish the environment. Higher-level assessments are therefore supported wherever possible.

 

Other matters

  • Decisions about environmental approvals are often highly political. Consideration should be given to increasing the independence of decision-making, possibly by establishing an independent authority.
  • The discussion paper states that trends suggest that Australian GDP and Australia’s population will continue to grow. While the past trends are not disputed, future statements by the Review should make clear that future GDP to some degree, and population levels to a large degree, will be the outcomes of government policies. The future is not pre-determined and Australia can decide to reduce future impacts on the environment by its policies and actions.
  • The use of biodiversity offsets remains a highly questionable process. For example, improving the quality of remaining habitat for a species to make up for habitat destroyed still ends up with a net loss of habitat. A preferable outcome would be to retain and to improve the condition of both areas. The process has largely been used to legitimise loss of species habitat.
  • Further advice on matters related to threatened species and invasive species management are at Attachment 1.

 

(Attachment 1 is not provided in this post. It is posted separately as the ‘Submission to the Senate inquiry into the ‘faunal extinction crisis’.)

[1] https://www.theguardian.com/environment/2015/aug/12/australia-has-denied-environmental-approval-to-just-11-projects-since-2000

[2] https://ipbes.net/news/ipbes-global-assessment-preview

[3] Smil, V, 2019. Growth: From Microorganisms to Megacities.

[4] Jackson WJ, Argent RM, Bax NJ, Bui E, Clark GF, Coleman S, Cresswell ID, Emmerson KM, Evans K, Hibberd MF, Johnston EL, Keywood MD, Klekociuk A, Mackay R, Metcalfe D, Murphy H, Rankin A, Smith DC, Wienecke B (2016). Overview of state and trends of biodiversity. In: Australia state of the environment 2016, Australian Government Department of the Environment and Energy, Canberra, https://soe.environment.gov.au/theme/overview/biodiversity/topic/overview-state-and-trends-biodiversity, DOI 10.4226/94/58b65510c633b

[5] See for example: https://www.sustainablefinance.hsbc.com/reports/fragile-planet

Photo credit: Palm Trees by Melanie Shires

Submission to the Australian Senate inquiry into the ‘faunal extinctions crisis’

Photo: Jonathan Miller.

About Steady State ACT

Steady State ACT is a non-government organisation which is committed to:

– raising awareness of the material limits to economic growth;

– raising awareness of the need to move away from economic growth policies and

– promoting the critical need to move to a steady state economy (see Attachment 1).

Steady State ACT is the ACT chapter of the international Center for the Advancement of the Steady State Economy. Its website is at www.steadystateact.org.

Jonathan Miller is Director of Steady State ACT. He has science and forest science degrees, and has worked with the Commonwealth and ACT governments, and with non-government organisations, on the environment, the economy and foreign affairs. He spent several years managing the Commonwealth threatened species and invasive species programs.

 Summary

Key points raised in this submission

  • Earth is experiencing its sixth great extinction event. The underlying cause is that humanity is extracting resources faster than nature can replenish them, and is creating wastes faster than nature can remediate them. We are destroying our natural capital and the natural processes fundamental to maintaining both biodiversity and human economies.
  • The underlying drivers of Australia’s faunal extinction crisis are similar to those for global biodiversity loss:
  • the key drivers are population and economic activity
  • these drivers must be addressed if we are to stop native species going to extinction and to avoid significant long-term threats to human welfare
  • we need to start the transition to a steady-state economy.
  • Mitigating threatening processes across the landscape generally yields greater biodiversity gains than focusing on a multitude of single species recovery actions.
  • Emphasis should be placed on preventative measures, such as
  • maintaining healthy ecosystems, to prevent species reaching threatened status
  • funding effective biosecurity measures that prevent establishment of new invasive species.
  • The development of recovery plans and the listing of critical habitat, while potentially valuable activities, may divert resources from more effective actions.

    1. The status of faunal species and the reasons for their decline

 1.1 Global context

Australia’s faunal extinction rate needs to be placed in a global context. Earth has entered its sixth great extinction event[1]. Extinction is a natural phenomenon with a natural ‘background’ rate of about one to five species per year. Current extinction rates, however, are now 1,000 to 10,000 times the background rate, with dozens of species becoming extinct every day[2]. The Worldwide Fund for Nature’s 2016 report, the Living Planet Index[3], assessed the health of 14,152 populations of 3,706 vertebrate species. The report found a 58% decrease in the abundance of these species between 1970 and 2012.   It has been estimated that 30 to 50 percent of all species could be extinct by mid-century[4].

 1.2 Australia’s rich and distinctive wildlife

Australia’s biodiversity is globally significant; we are considered to have a ‘megadiverse’ biodiversity. A 2009 report[5] determined that 147,579 Australian species of all kinds had been described among a total estimated number of 566,398 species. In other words, it is likely that almost 74% of Australia’s species are not yet known to science. These figures also demonstrate the global significance of Australia’s biodiversity. The report determined that Australia was home to about 8% of the world’s 1.9 million described species, including 12% of vertebrate animals. Australia also has very high levels of endemism – numbers of species found nowhere else. Ninety-three per cent of our reptiles, 87% of our mammals, 94% of our frogs and 90% of our plants are unique to Australia. Australia has a significant role and responsibility in maintaining global biodiversity.

1.3 The parlous state of Australian wildlife

The Commonwealth’s 2016 State of the Environment Report found that:

Based on the information available about vegetation extent and condition, and the small number of species for which there is some understanding of trends in distribution and abundance, the status of biodiversity in Australia is generally considered poor and deteriorating[6].

Of the 511 faunal species listed on the Commonwealth’s List of Threatened Species in July 2018, 27 mammals, 22 birds, 4 frogs and one fish are listed as extinct. One fish is listed as extinct in the wild.[7] The equivalent list of threatened flora identifies 37 extinct species among a total of 1355 listed species.

The Commonwealth threatened species lists represent the endpoint of protracted technical assessment and administrative processes, rather than regularly updated, comprehensive point-in-time inventories of the conservation status of Australian species. For this reason, and the incomplete knowledge of Australia’s biota, the Commonwealth lists almost certainly underestimate the number of threatened species.

In March 2016, former Australian Government Threatened Species Commissioner, Gregory Andrews, noted that Australia had the highest rate in the world for mammal species extinctions.[8]

“Thirty-five per cent of all global mammal extinction since (the year) 1500 have been Australian (30 out of 84 worldwide extinctions)”. Twenty-nine of these have been since European colonisation.

Australia is a global hotspot for biodiversity, and a major contributor to the current global sixth extinction crisis.

 1.4 Direct causes of biodiversity loss

The 2016 State of the Environment report identified habitat clearing and fragmentation, invasive species and climate change as among the key pressures on Australian biodiversity.

These pressures can be abated to differing degrees. A number of invasive species, such as cats, foxes and rabbits, have become well-established across Australia. Other than in fenced exclusion ‘sanctuaries’ (such as those run by the Australian Wildlife Conservancy), actions to reduce the impacts of these widespread species can only have temporary or local effect, as complete eradication is not feasible and the invasive species readily recover in numbers or reinvade from adjacent areas.

There are, however, key threatening processes which are the outcome of current economic activities and government decisions. Habitat loss, fragmentation and degradation are being caused by activities such as native vegetation clearance for agriculture, expansion of urban settlements, and new and expanded infrastructure.

In the longer-term, human-caused climate change is likely to become the most significant disrupter of Australian biodiversity. Species may not able to adapt to the rapid projected rates of global warming, being unable to move their ranges sufficiently quickly southward and to higher elevations. It appears that the Great Barrier Reef’s Bramble Cay melomys recently became the first mammal driven to extinction by climate change.

Photo: Jonathan Miller

1.5 Drivers of biodiversity decline and species extinction

To understand the reasons for Australia’s biodiversity decline, it is important to go beyond the immediate causes, and consider the underlying drivers.

The 2016 Commonwealth State of the Environment report found that

In Australia, the key drivers of environmental change are population and economic activity.[9]

Like most other countries, Australia has adopted continuing economic growth, as measured by GDP, as a paramount national objective.[10]

While increased resource use and pollution are not strictly functions of economic growth, they are generally strongly correlated. When that economic growth is due to per capita GDP increases, consumers generally demand more material goods and services, such as overseas travel. Increases in population multiply the demand for consumer goods and services, as well as housing and infrastructure.

The impacts of population on the environment primarily are determined by the population level itself (rather than the population growth rate). The higher Australia’s population, the more native vegetation that needs to be cleared for settlement and infrastructure, the greater the disruption to our rivers and groundwater, and the greater the pollution generated, including greenhouse gas emissions.

It is often argued that as a large country, Australia can carry a much higher human population, but comparisons with other land masses need to take into account the aridity, infertility and the unfavourable climate of much of the Australian land mass[11]. Increasing our population not only leads to impacts on biodiversity, but also degrades the natural systems we rely upon to support our welfare and prosperity.  Australia needs a population policy and population strategy as overdue priorities.

Photo: Melanie Shires

Beyond the impacts of population growth, economic growth drives a number of the key pressures degrading Australian biodiversity, such as habitat destruction and fragmentation, and climate change.

It is healthy for a child to grow, but there comes an age when further physical growth is unhealthy. Similarly, there are limits to the healthy growth of an economy and its material throughput. We live on a finite planet and we are already exceeding its capacity to support our annual harvesting and extraction of resources, and its capacity to remediate our wastes. Climate change is just one consequence of this ‘overshoot’. Using Ecological Footprint analysis, humanity is currently using the equivalent of 1.7 ‘Earths’ to provide the resources we use and to absorb our wastes.[12][13] This means that we are eating into the world’s natural capital to meet our annual needs.

The extent to which humans are ‘crowding out’ nature and appropriating Earth’s resources is well illustrated by a calculation that in the year 2000, the total mass of all humans and livestock species made up 94% of the mass of all mammals globally, with wild mammals contributing just 6% of that biomass[14].

Arguably, Australia is also exceeding its long-term sustainable limits to growth. We are consuming and degrading our natural capital, and our high rates of species extinction are an inevitable consequence of this.

Australia’s high level of material consumption is strongly dependent on imports of consumer goods and petroleum. Fossil fuels have been critical to the Great Acceleration and our high standards of living, but we must move quickly away from fossil fuels to minimise the future impacts of climate change. It is not clear whether replacement power supplies can support continuation of our current high levels of material consumption indefinitely into the future, which has so far relied on abundant cheap energy. Put another way, Australia’s ‘human carrying capacity’ is almost certainly artificially inflated at present. In a future ‘low-carbon’ world, Australia’s population is likely to depend increasingly on Australia’s physical environment, and less on imports. This makes maintenance of a healthy physical environment all the more critical. The Australian Academy of Science argued that our population should be limited to 23 million[15]. In 1994, Professor (then Dr) Tim Flannery estimated that with currently foreseeable technology and present habits of consumption, Australia might support a long-term population of 8-12 million[16].

Photo: Jonathan Miller

Economic growth is more than just a government policy goal; it is a paradigm that dominates political thinking and media commentary. It is seen as an unchallengeable necessity. The primacy of this paradigm is reinforced by the dominance of neoclassical economics, which largely excludes environmental sustainability considerations, sidelining them as ‘externalities’. Environmental conservation is often presented as a secondary, aesthetic matter. Within such a framework, the consideration of development under the Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act) almost inevitably leads to approval and the further incremental degradation of Australia’s natural environment.

Environmental impacts are often long-term, incremental, cumulative and not readily apparent. Climate change provides an excellent example, where the degradation of a vital natural system function – climatic regulation – is being disrupted by the cumulative effect of daily actions and decisions of individuals and organisations.  Notwithstanding the significance of this threat, governments, individuals and corporations continue to make decisions that give primacy to short-term economic benefits. The causes for this disconnect are complex but reflect the cultural frame of our society which is strongly influenced by narrow economic thinking, and our limited spatial frame of perception that does not factor in Earth’s finite nature.

The false dichotomy of the human economic realm and the natural physical world in our thinking comes at great cost. Like all other animals, humans rely on our physical environment for habitat needs – which are the critical resources and services our economy and our welfare depend on. These ‘ecosystem services’ include but are not limited to food production, raw materials, water production, energy, soil formation, pollination, waste decomposition, water and air purification and recreational opportunities. Even if we are just to take a narrow utilitarian perspective, the value of these ecosystem services is greater than the global human economy. The value of ecosystem services in 2007 was estimated to be US$125 trillion/year, compared to the global GDP of US$75 trillion/year. The same study estimated the value of the loss of ecosystem services between 1997 and 2011 was in the range US $4- 20 trillion/year, due to land use change, which represented degradation of the physical environment and consumption of natural capital[17]. This natural capital is biodiversity, and the systems and processes that support that biodiversity

So, the degradation of our physical environment has very direct consequences on human welfare. Climate change is the most critical current example of humanity living beyond limits to economic growth, in this case polluting beyond the capacity of Earth’s natural systems to remediate greenhouse gas emissions. In 2009, leading climate change scientist, Hans Schellnhuber, estimated that under feasible climate change scenarios, Earth’s carrying capacity could be reduced to one billion people, in contrast with our current 7 billion.

In summary, Australia’s faunal extinction crisis is in part the inevitable result of our society’s priority on economic growth and population growth. The fate of both humans and non-human species depends on nations, including Australia, managing their populations and their demands on the natural environment, so as to live within nature’s productive, regenerative and remedial capacities.

Rainforest. Melanie Shires

2.    Steps for better biodiversity conservation

 2.1 The need for high-level,  long-term planning to ensure Australia is a truly sustainable society

Australians and Australian governments need to recognise that not only is the degradation of our physical environment causing the extinction of our native species, it also imperils the very future of our economy and our quality of life.

Securing the future of Australia’s wonderful animals demands far more than narrow attention to decisions on development proposals and recovery actions. We need to make long-term plans for our society that reflect the finite nature of our country and our planet. This would include a long-term target for Australia’s population and other policies to maintain our natural capital and ecosystem services. We also need to responsibly address the overseas and global impacts of Australian exports and the consumption of our imports.

Serious consideration of such matters makes clear the need to start the transition to a steady state economy as a matter of urgency.[18]

2.2 Give priority to dealing with threats to biodiversity

The EPBC Act includes significant provisions aimed at supporting the recovery of threatened species.

The 2016 Commonwealth State of the Environment report noted:

Evidence for the effectiveness of recovery planning for threatened species is variable.

Once a species has reached threatened status, it is generally very difficult to recover that species. Species rely on complex natural systems for their needs. Research into the causes of individual species decline, the identification of recovery actions, and the implementation of those recover actions require significant resources. A lot of money has been spent on captive breeding of the Orange Bellied Parrot and the Helmeted Honeyeater, for example, with very limited success. Yet, we have almost 2,000 nationally listed species. While Commonwealth funds provided for threatened species conservation should arguably be increased dramatically, a species-by-species approach to recovery is likely to only ever have limited success.

Until changes to the EPBC Act in 2006, recovery plans were required for all listed species. This created a huge workload that could never have been addressed with available funding, and hence redirected funds and staff time away from on-the-ground action to plan development. The plans developed a suite of species-specific actions, the vast majority of which could not be funded and were never implemented.

A more viable approach is to focus on the key threatening processes impacting on Australia’s biodiversity, as they degrade the health of natural systems, thereby impacting on a number of species. Invasive species such as cats and foxes have played, and continue to play, a major role in Australian faunal extinction. The eradication of invasive species in the Australian Wildlife Conservancy fenced reserves has been highly effective in securing populations of the threatened species. Outside such reserves, ongoing invasive species management can be very important to biodiversity conservation.

Photo: Jonathan Miller

2.3 Prevention is much more effective than ‘cure’

The adage that ‘prevention is better than cure’ is particularly relevant to biodiversity conservation.

A limitation of the EPBC Act is that it focuses on the status of species once they are threatened, rather than stopping species reaching threatened status. Given the difficulties of recovering threatened species, it is highly desirable to avoid or pre-empt actions and threats that might impact on the conservation status of species, particularly those species currently not considered to be threatened.

To prevent degradation of the conservation status of species, whether threatened or not, preventing native vegetation clearing and fragmentation are very important. The level of native vegetation clearing in Australia is unacceptable in a first-world country and stronger measures are needed to stop this. ‘Biodiversity offsets’ are used to legitimise developments that impact on local biodiversity, but their validity and effectiveness is highly questionable. While the negative impacts of a development are likely to be ongoing, any benefits of offsets generally rely on ongoing maintenance and the security of tenure of the sites, but there is very limited funding to enforce offset requirements under the EPBC Act.

The importance of prevention of ecological damage is highlighted by the benefits of effective biosecurity measures. Whereas established invasive species such as rabbits and foxes cause ongoing biodiversity impacts and financial costs for control measures, it is much more effective and less expensive to stop invasive species becoming established in the first place. The importance of biosecurity to our agricultural industries has long been recognised, but biosecurity threats to our biodiversity have received less attention and funding. The volume of trade into Australia makes it impossible to completely prevent the arrival of new invasive species, but it is highly desirable to increase funding for detection and eradication of new arrivals at the border and beyond.

The implementation of the Intergovernmental Agreement on Biosecurity in 2012 was a major step forward in improving the protection of Australia’s biodiversity. To be effective, the Australian Government needs to ensure adequate funding for the National Environment Biosecurity Response Agreement, which facilitates the eradication of newly arrived invasive species.

The incursion of Red Imported Fire Ant (RIFA) in south-east Queensland provides a salutary case study. The impacts of the RIFA are listed as a key threatening process under the EPBC Act, and place numerous species at threat. The huge super colonies formed by fire ants transform landscapes and their biodiversity, as well as inflicting painful and sometimes deadly stings to humans, and impacting agricultural production. In the USA, the ant causes $7 billion in impacts and control[19]. If not controlled, the pest could spread to most of the Australian continent, causing an estimated additional 140,000 medical consultations and 3000 anaphylactic reactions each year. It is to the credit of Australian governments that they have now funded a comprehensive eradication campaign, but this would have been much less expensive and more certain of success if the funding had been provided in the early 2000’s when the incursion was almost eradicated.

Ultimately, climate change might be the greatest threat to Australia’s biodiversity. Recent increases in the frequency of bleaching of the Great Barrier Reef give some indication of the threat posed. The future of both human society and our biodiversity are dependent on mitigation of the threats posed by climate change.

Alpine grassland. Jonathan Miller

2.4 Critical habitat identification and registration under the EPBC Act

There has been recent public comment about the lack of identification of critical habitat, as entered in the EPBC Act’s Register of Critical Habitat. While the responsible Minister is required to create or maintain the Register, there is no requirement to list critical habitat for any individual listed species or ecological community.

Ideally, critical habitat would be identified widely for listed species and ecological communities. In practice, identification of such habitat, and particularly its boundaries, is generally not a clear-cut process. Importantly, the Environment Department as a matter of good process and natural justice, needs to consult the landowners of candidate areas for critical habitat listing. This is potentially very time consuming, whereas the benefits of listing under the Act are limited; the EPBC Act only provides protections for listed critical habitat areas on Commonwealth land.

It is therefore important to recognise the trade-offs in resources between the work needed to lead to a critical habitat listing, and other activities undertaken by Environment Department staff working on threatened species.

3. Acknowledgements

 Steady State ACT acknowledges the following for their assistance in drafting this submission: Ian Penrose, Dr Anna Schlunke and Dr Geoff Mosley.

Attachment 1. What is a steady state economy?

 A steady-state economy has a constant (or mildly fluctuating) population and constant (or mildly fluctuating) per capita consumption.

Energy and material flows are reduced and kept within ecological limits and there are constant stocks of natural and human-built capital. This is done by:

  1. maintaining the health of eco-systems and the life-support systems they provide;
  2. extracting renewable resources like fish and timber at a rate no faster than they can be regenerated;
  3. consuming non-renewable resources like minerals at a rate no faster than they can be replaced by the discovery of renewable substitutes and
  4. depositing wastes into the environment at a rate no faster than they can be safely assimilated (this means a steady-state runs on renewable energy.)

Rather than aiming for growth, a steady-state economy aims for:

  1. sustainable size;
  2. a fair distribution of wealth, where there are limits to inequality;
  3. efficient use of resources: reuse, recycling, using circular processes instead of linear and
  4. a high quality of life.

Endnotes 

[1] See for example Cerballos G, Ehrlich P and Rodolfo D (2017). Proceedings of the National Academy of Sciences of the United States of America, July 25, 2017. 114 (30) E6089 – E6096

[2] Chivian, E. and A. Bernstein (eds.)  2008. Sustaining life: How human health depends on biodiversity. Center for Health and the Global Environment. Oxford University Press, New York.

[3] Worldwide Fund for Nature (2016). Living Planet Index. http://wwf.panda.org/knowledge_hub/all_publications/lpr_2016/

[4] Ibid. and Thomas, C. D., A. Cameron, R. E. Green, M. Bakkenes, L. J. Beaumont, Y. C. Collingham, B. F. N. Erasmus, M. Ferreira de Siqueira, A. Grainger, Lee Hannah, L. Hughes, Brian Huntley, A. S. van Jaarsveld, G. F. Midgley, L. Miles, M. A. Ortega-Huerta, A. Townsend Peterson, O. L. Phillips, and S. E. Williams. 2004. Extinction risk from climate changeNature 427: 145–148.

[5] Chapman A, 2009. Number of Living Species in Australia and the World 2nd edition. Report for the Australian Biological Resources Study.

[6] Jackson WJ, Argent RM, Bax NJ, Bui E, Clark GF, Coleman S, Cresswell ID, Emmerson KM, Evans K, Hibberd MF, Johnston EL, Keywood MD, Klekociuk A, Mackay R, Metcalfe D, Murphy H, Rankin A, Smith DC, Wienecke B (2016). Overview of state and trends of biodiversity. In: Australia state of the environment 2016, Australian Government Department of the Environment and Energy, Canberra, https://soe.environment.gov.au/theme/overview/biodiversity/topic/overview-state-and-trends-biodiversity, DOI 10.4226/94/58b65510c633b

[7] http://www.environment.gov.au/cgi-bin/sprat/public/publicthreatenedlist.pl?wanted=fauna (viewed 29 July 2018)

[8] Reported on the Australian Broadcasting Corporation’s website on 4 March 2016: http://www.abc.net.au/news/2015-08-19/fact-check-does-australia-have-one-of-the-highest-extinction/6691026

[9] Jackson WJ, Argent RM, Bax NJ, Bui E, Clark GF, Coleman S, Cresswell ID, Emmerson KM, Evans K, Hibberd MF, Johnston EL, Keywood MD, Klekociuk A, Mackay R, Metcalfe D, Murphy H, Rankin A, Smith DC, Wienecke B (2016). Overview: Overview. In: Australia state of the environment 2016, Australian Government Department of the Environment and Energy, Canberra, https://soe.environment.gov.au/theme/overview, DOI 10.4226/94/58b65510c633b

[10] This is a relatively new phenomenon, postdating the Second World War. The modern concept of GDP was developed in 1934 by Simon Kuznets, who ironically argued against using the indicator as a measure of national welfare.

[11] To reinforce this point, Antarctica is larger than Australia, but its unfavourable environment means that it cannot sustainably support a large population.

[12] Global Footprint Network website. https://www.footprintnetwork.org/our-work/ecological-footprint/

Sighted 24 July 2018.

[13] Australians have a far greater average ecological footprint than the global average. If all people had the same human footprint as Australians, humanity would need about five ‘planet Earths’ to meet our needs.

[14] Smil V, 2011. Harvesting the Biosphere: The Human Impact. Population and Development Review 37(4): 613-636 (December 2011).

[15] Australian Academy of Science, 1995. Population 2040: Australia’s Choice. Proceedings of the Symposium of 1994 Annual General Meeting of the Australian Academy of Science, Canberra.

[16] Flannery, T, 1994. The Future Eaters: An Ecological History of the Australasian Land and People.

[17] Costanza R, R de Groot, P Sutton, S van der Ploeg, S Anderson, I Kubiszewski, S Farber, R Turner, 2014.
Changes in the global value of ecosystem services. Global Environment Change 26 (2014), 152 -158.

[18] A steady state economy is a dynamic market economy that efficiently allocates goods and services but uses the lowest feasible rates of natural capital depletion to achieve a high quality of life. It features a sustainable population, a fair distribution of wealth and low resource use. (After James Magnus-Johnston in Positive Steps to a Steady State Economy. Edited by Haydn Washington for CASSE NSW. 2017).

[19] Information drawn from Invasive Species Council, 2017. Fact Sheet: Red Fire Ants