Submissions and Letters |
Draft Commonwealth Flying-fox camp management PolicySubmissions Close Friday 30 January 2015
According to the Australian Dept of the Environment (DoE) "The intention of this draft policy statement is to ensure that there are no significant impacts on these EPBC Act listed flying-foxes due to actions to manage their camps." You can download a copy of the consultation draft policy HERE. We believe the draft policy in its current form would have the opposite effect of that intended, and would increase the number of dispersals and decrease the ability of DoE to assist in the recovery of these threatened species (which they have a legislated responsibility to do). We encourage all interested parties to email their submissions before 30 January 2015 to speciespolicy@environment.gov.au. If you have questions or would like to provide feedback on this page or the template submissions you can visit us on Facebook or contact us by email here.
|
What is wrong with the Draft Policy?
The Department of the Environment (DoE) has the responsibility to protect Australian native species - particularly threatened species, and this policy is intended to have the objective of ensuring there are no significant impacts on those species. Below (Item A) you will find a link to a template submission you can download so you can send your own submission. Items B through J provide a breakdown of some of the issues with this draft policy. Please contact us if you find any errors or omissions.
A. Overview
It is our view that as currently worded, the draft policy can not possibly achieve the stated goals and that if promulgated in its current form the policy will achieve the following outcomes:
B. Best practice implications
The draft policy says that if actions are undertaken with best practice mitigation standards, approval from DoE may not be required - even when the camp in question is on the list of "nationally important flying fox camps.
- Click to show/hide the issues
C. State & Territory regulations
The draft policy suggests that approval is unlikely to be needed if the action is taken at non-listed camps and carried out in accordance with State or Territory regulatory requirements.
- Click to show/hide the issues
D. The Decision Tree Flowchart
The draft policy provides a decision tree flowchart outlining the process, but this chart has several issues.
- Click to show/hide the issues
E. Additional items the policy should consider
There are important areas which the current draft policy does not adequately address. In summary these items include:
- Click to show/hide the issues
|
F. National list of important flying-fox camps
The draft policy says there is a need to maintain a network of flying-fox camps and foraging habitat across both species national range, and that a network of nationally important camps has been identified for the two mainland species of flying-fox listed under the EPBC Act (reproduced in Attachment 1).
- Click to show/hide the issues
G. Promoting alternatives to camp dispersal
The draft policy states “The Department does not, promote the clearing of camp habitat or camp dispersal as a preferred management tool.”
- Click to show/hide the issues
H. Minor and routine actions
In relation to actions that are considered minor or routine the policy exempts “Noisy events of limited duration such as fireworks displays or outdoor performances”.
- Click to show/hide the issues
I. Planning requirements
The requirements for planning dispersal actions outlined in Part 3 (page 6) should be included in the best practice mitigation standards .
- Click to show/hide the issues
J. Best practice standards need to be enhanced
The draft policy provides details of the proposed “Best practice mitigation standards” in Attachment 2, but in our view these are not comprehensive enough to be called best practice standards. We suggest at least the following amendments (Note some of the items related to the plan were copied from the items in part 3 of the draft policy - also see comment "H.Planning requirements, above).
- Click to show/hide the issues
|
Resources
For additional reports and information sources that you can refer to when drafting your letters or submissions, see our Resources page