Submission by Anthony Witham to the Inquiry into the Impacts of Native Vegetation and Biodiversity Conservation Regulations. 

The Environment Protection Amendment Bill 2002, which is currently before the Western Australian Parliament has already had an impact in the Broomehill and Tambellup Land Conservation Districts. Over the past nine months or so there has been a bull dozer continually pushing over “paddock trees”. This response from farmers is due to a perceived threat on increasing farm production potential that the new regulations pose especially on broad scale cropping using large agricultural machinery in areas that have been up until recently used primarily for grazing by sheep. The reason paddock trees are being removed is almost invariably reported by the landholders to be “you can’t get around the trees and/or between them with the boom spray”. There are a number of issues that can be considered in contributing to such an outcome.
Firstly the farmers by and large perceive the new legislation as creating the legal power to stop clearing, so as has occurred in the past, the scale and rate of paddock tree clearing has been greatly increased. This response has occurred even before it is clear whether or not permits or some other exemption will be able to be obtained for such activity. There is also the likelihood that most farmers would not want to involve themselves with going through a process that entitles them to clear paddock trees if there were to be one. The legislation has had many amendments and taken some time to be passed, causing concern and confusion amongst the farming public. Generally the farming community is becoming disenfranchised with government and bureaucracy as a consequence of a feeling the relevance of the farming community to Government and vice versa has been diminished during this period of economic rationalism. 
A second issue is that the perception paddock trees are not significant to the over all health of the environment. There is little argument on this point from much of the community except for some of those who are committed to protecting the natural environment or have the belief that paddock trees are an important part of the landscape for one reason or another. The whole Landcare movement is continually dogged by claims that environmental damage is only sentimental conjecture from green perceptions and that there is little scientific evidence to back up claims of degradation. Paddock trees are certainly a conspicuous causality of this attitude of deference to environmental concerns. 
There is also the issue of changing economic circumstances. Large areas of the Broomehill and Tambellup Districts are parkland cleared originally due to the belief that this was the ideal landscape to run sheep in. The comparative collapse in the wool market saw a change from sheep to cropping in areas that had been for grazing up until that point. Subsequently cropping has seen a shift into larger and larger capital items being used in response to an increase in the scale of the profitable cropping enterprise. The vast majority of farmers do not deem the parkland landscape suitable for large scale cropping operations. Even though sheep meat prices have seen flock numbers increase again, most farmers are retaining a large portion of their land each year for cropping in order to spread financial risk and maintain the favourable financial returns from cropping.
Having outlined the local situation concerning the large scale clearing of paddock trees, the Productivity Commission should not take the economic costs of legislation protecting natural vegetation and biodiversity too seriously just yet. It is very likely that extremely important services are being provided to the farming sector but the cost is external to the market. 
Ecosystem services may prove to be essential to the health of agriculture but the capital supplying these services may be diminishing due to inadequate preservation of areas operating under natural systems. In light of this it should be pointed out that current attempts at legislation to protect such areas and services couldn’t be considered to be either inhibiting or helping the productivity of agriculture for the long term since there is not the scientific evidence to back either case. 
Many farmers would like to maximise their land’s capacity to grow commodities that can be sold on the current market, and paddock trees are seen as inhibiting this goal. The farmer’s self imposed environmental constraints on how much land should be cleared are currently defined by either genuine environmental concern on the part of the farmer or a reaction to obvious degradation that has already occurred or is likely to occur (such as wind erosion, water logging and salinity). The more subtle cases of degradation such as the approaching critical point of soil biochemistry toxicity, or continually greater fluxes of pest insect populations are not being accounted for. There may be plenty of evidence to suggest that technology and management may be able to keep reacting to subdue environmental crises as they become more obvious but at what cost. Huge opportunity costs may be squandered as ecosystem services are continually ignored until the next environmental problem impinges on the current agricultural product. This path of ignorance followed by reaction may prove to be extremely inefficient in economic terms, whether all the costs are internalised or not due to the fact that huge inputs will be required to grow what is currently considered fairly low economic value items in terms of GDP.  
In the Broomehill and Tambellup districts we have no information how important biodiversity per sae is to maintain the stability of current production systems. Similarly there is no information on what areas of native vegetation is required by local ecosystems to be self-sustaining. We have already experienced the local extinction of the vast majority of native mammal species and there is no information on what the consequences of this will have on ecosystem services into the future if any. There are certainly principles that could be applied to the question of preserving biodiversity, such as the model that suggests complexity and diversity provides an innate stability to any system.  
The legislation brought forward by the CoE and the State is in the right direction but has not gone far enough to properly adopt the Precautionary Principle. Legislation may need to be very prescriptive if we are to avoid huge reparation costs being expended on propping up the environment in the future. Broomehill and Tambellup have something like on average 7% of the land covered in native vegetation. If it turns out that 30% is required in order to sustain the districts production values due to a billion dollar in-put from ecosystem services then clearly it would be better to protect as much vegetation as possible just in case. The EPBC Act has teeth but only for the limited circumstances where the ecosystems or species being protected have a high profile and or are under immanent threat of extinction. 
The Environmental Protection Amendment Bill 2002 will also have teeth and hopefully go far enough to protecting our natural resource base but I doubt it. Regulation is what is required until there can be a carrot developed from better scientific data outlining the need to maintain eco-system services. Until such time the cost of such legislation on the agriculture sector is completely arbitrary because the accounting system is may have serious flaws.
Anthony Witham
Community Landcare Coordinator
Broomehill and Tambellup         
15/7/2003