Our Ref: 21/3/9 

21 January 2004

Native Vegetation Inquiry
Productivity Commission
LB2, Collins Street East 
MELBOURNE VIC 3003

Dear Sir/Madam

Re: Submission on Impacts of Native Vegetation & Biodiversity Regulations Report

Thank you for the opportunity to comment on “Impacts of Native Vegetation & Biodiversity Regulations” (Productivity Commission Draft Report). The Corangamite Shire Council is supportive of improvements within the vegetation and biodiversity area throughout Victoria / Australia and welcomes the opportunity to participate in the development of improvements through submissions like this one.
 
Background to Corangamite Shire
The Corangamite Shire is located in the Western District of Victoria about two and a half hours from Melbourne. The Shire’s 4600km2 extend from the 12 Apostles coastal area in the south, to the township of Skipton in the north. To the east we are bound by the shores of Lake Corangamite and we extend west just beyond Terang. 

The towns of Camperdown, Cobden, Simpson, Timboon, Port Campbell, Princetown, Terang, Derrinallum, Skipton, Lismore and Noorat lie within Corangamite’s boundaries. Agriculture is the major industry in our Shire, producing milk, wool, beef, fat lamb and grain. There has also been a large shift in some areas towards timber production which has been met with a mixed response within the community. 

Tourism is also an important industry sector for Corangamite which offers the spectacular 12 Apostles, the Port Campbell National Park, in addition to fine fishing lakes and outstanding volcanic hills and craters. 

The topography of the Shire is variable. In the north there are relatively flat plains with a large number of lakes that form part of a system that has international significance (Ramsar). In the south the landscape is more undulating and experiences higher rainfall. In fact this area is one of the highest rainfall areas in the State.

General Comments
Council believes that this report has mainly focused on the downfalls of the current system as it relates to major land clearances and landowners. There appears to be very little information or feedback from organisations and local government agencies that have been responsible for the implementation of these regulations. These groups should be included further in the initial feedback process to assist in development and strengthening of this report which would then have assisted the regulations to be implemented with a “win win” result. Better responses from these partners in the development of this report would most probably have resulted in a very different document to the one we are currently commenting on. 

There appears to also be very little consideration given to areas of small pockets of vegetation or individual remnants and the issues that have arisen from these areas.   The regulations have been developed with a large range of objectives that do not reflect the diversity across Australia. This has allowed gaps to appear and potentially a net loss rather then a net gain in vegetation protection.
     
Council would like to emphasise the diversity in environmental conditions throughout the shire area, demand for and use of these resources is increasing dramatically. Diversity throughout regions is a key point (as mentioned above) that must determine the final recommendations put forward from this document. It would be a major flaw to adopt a blanket approach to vegetation and biodiversity especially for diverse areas like Corangamite that contain highly varied ecosystems.

Specific issues
•	Council believes that many of the downfalls with the regulations currently lie with the absence of the operational guidelines to assist local government in the delivery of such an important community benefit issue. These guidelines are currently not available and pose a major stumbling bock for the correct and confident implementation of the regulations. 
•	Local Government is required to implement these regulations with very little or no training and resources. This has therefore reduced the effectiveness of the implementation and the ability of the community to clearly understand the restrictions placed on the general community.
•	The report covers the implementation of regulations on a regional level, which may be above the local government level that currently implements these regulations. The regional level concept was not explained further nor who may have the capacity to deliver such a large and multi skilled role. This would be especially difficult given the same resources and training that has been available to local government for implementation. 
•	There has been very little information reflecting on the positive impacts that have resulted from the introduction of these regulations. These achievements have been highly varied and the true extent of this success will not be evident for some time into the future and potentially will never be known.

 
•	The retention of ecosystem communities and habitat is a justified objective. The report looks at why are we retaining vegetation (is it just for the sake of retaining native vegetation). It is important to ensure that all situations are assessed separately and in the context of the past vegetation that existed in that area and the potential habitat that is provided by that vegetation. It is the community’s right to have vegetation protected for future generations but it must not be at the cost of everything else.    

All actions from the productivity report should include an implementation plan that can be included within the regulations. This plan should be educational and incentive focused and not penalty based. People need to be rewarded for actions to allow for large scale acceptance of change.

Once again I thank you for allowing the Corangamite Shire Council to comment on this draft report and please note that Council does not wish to appear at any hearings. Please do not hesitate to contact me or our Planning and Environment Officer, Lyall Bond, if you have any questions in relation to the comments made within this letter.  We can be contacted on 5593 7100. 

Yours faithfully,

Sophie Segafredo
Manager Strategic Planning & Environment