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Green Wedges Coalition - a vision for Melbourne REVIEW OF THE WILDLIFE ACT 1975

GREEN WEDGES COALITIONi SUBMISSION – 30 JUNE 2021

Emerging issues The Green Wedges Coalition is pleased to have an opportunity to contribute to this review of the Wildlife Act 1975. We understand that the current stated purposes of the Act are:

(a) to establish procedures in order to promote— (i) the protection and conservation of wildlife; and (ii) the prevention of taxa of wildlife from becoming extinct; and (iii) the sustainable use of and access to wildlife; and

(b) to prohibit and regulate the conduct of persons engaged in activities concerning or related to wildlife.

Our submission is concerned with addressing ‘emerging issues affecting wildlife protection and conservation, sustainable use and access’, one of the issues identified in the Guide to

stakeholders and community members.

Our concern is the impact that current trends in future land use and development is having on

wildlife in excess of 276,000 hectares of privately owned land in the Greater Melbourne area.

(Source: The Department of Environment, Land, Water and Planning)

The map of Greater Melbourne area above shows the extent of the Green Wedges as a whole taking into account both privately owned and public land. In total there is some 600,000 hectares of Green Wedges of which, as mentioned above, of which 276,000 hectares is privately owned land.

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The dimensions of this issue become very evident when it is understood that this privately owned land comprises nearly 46% of the Green Wedges in the Greater Melbourne area. Protection and enhancement of the natural environment in Green Wedges is a major issue for metropolitan Melbourne as the health of these natural ecosystems is vital to protecting and enhancing the natural vegetation communities that provide the habitat to sustaining wildlife populations. It is a vital first point of contact of 5 million people that live in the Greater Melbourne Metropolitan area with Victoria’s wildlife. The map belowii shows the distribution of vegetation across the Greater Melbourne Metropolitan area classed in vegetation heights ranging from 0.3 - >15 metres. This is vegetation communities and scattered trees that are essential to the sustainability of native wildlife.

This map is for illustrative purposes only and is used because community groups have limited access to data

and this map is available in the public domain. . High level detailed vegetation data is available down to

parcel/lot level from the ‘Spatial Datamart’ at Department of Environment, Land, Water and Planning

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(DELWP). A major study has been completed for the Melbourne Metropolitan area that has involved: RMIT

University; the University of Western Australia; CSIRO; and, The Clean Air and Urban Landscapes (CAUL)

Hub.

It is quite evident to the Green Wedges Coalition that the native vegetation is being increasing lost to

urban development in the Green Wedges. Evidence for this loss of native vegetation is supported by a

research undertaken on trends in vegetation cover in Melbourne from 2014-2018iii.

An Urban Forestry Strategyiv produced for Melbourne highlights the need to greatly increase tree and shrub canopy cover. The issue is that much more emphasis needs to be placed on the protection and enhancement of indigenous native vegetation communities as they provide the habitat critical for the sustainability of the native wildlife.

Urban pressures in the Green Wedges There is new rural residential development by stealth, as such development is not supported in the Green Wedges zones. For example, some proponents are preparing flimsy Farm Management Plans to justify a dwelling. In addition, older dwellings are continually being demolished to make for dwellings that have a much larger footprint which requires more vegetation removal. Other major urban pressures are from places of worship, schools and tourism development. These are permitted Section 2 uses in Green Wedge zones and as such are subject to the requirement for approval of a planning permit application. The issue for the Green Wedges Coalition is that when approved they are often of an excessive bulk and scale that destroys and fragments the existing indigenous vegetation communities in the Green Wedge zones. In terms of future land use and development, considerable attention needs in to be given to ensuring the effectiveness of planning tools for the protection and enhancement of wildlife values are actively applied. The Green Wedge Zone (GWZ), the Green Wedge A Zone (GWAZ) and Rural Conservation Zone (RCZ) all include In their purpose the importance of environmental values and the decision guidelines need to be more rigorously applied. The Environmental Significance Overlay (ESO) and Vegetation Protection Overlay also need to be rigorously applied. The ESO and VPO provide critical triggers for detailed attention to environmental values in the planning application process.

Net Gain versus No Net Loss Plan Melbourne 2017-2050 in regard to the environmental and biodiversity assets in the Green Wedges

specifically identifies the need to ‘Maintain and enhance the diversity of indigenous flora and fauna habitats and species to achieve net gain in the quantity and quality of native vegetation’ (p90). In contrast the native vegetation provisions in the Victoria Planning Provisions (VPP) has as its purpose ‘To

ensure that there is no net loss to biodiversity as a result of the removal, destruction or lopping of native vegetation.’

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By definition, with a policy of no net loss for protecting and enhancing native vegetation we will not achieve improvements in habitat critical to the future of native wildlife across Victoria. .

Offsets versus onsets The VPP native vegetation provisions also allow for offsets where the original native vegetation can be cleared provided it is replaced in accordance with the Guidelinesv. A study lead by RMIT University under Australian Research Council (ARC) funding is looking at the concept and methodology for the application of ‘onsets’ resulting in enhancing onsite biodiversity. It projects the benefits as replacing the pervasive practice of biodiversity offsetting with an approach that will lead to onsite biodiversity gains.vi In terms of future land use planning and development the provision for and concentration on offsets enables the clearing of existing native vegetation communities and is often accompanied in the Green Wedges by increased urbanisation by facilitating excessive bulk and scale of built form and associated infrastructure.

Exemptions from the requirement to obtain a permit for vegetation clearing There is an extensive list of exemptions in Clause 52.17 Native Vegetation. The Green Wedges Coalition is particularly concerned about the exemption for domestic stock grazing. Uncontrolled grazing is a major issue for the loss of indigenous and other native vegetation.

Grazing encompasses any animals covered the definition of ‘Animal husbandry’ in the VPPs that

encompasses ‘Land used to keep, breed, board, or train animals, including birds’ and would include cattle,

sheep, horses, racing dogs, pigs, etc.

Achieving protection and enhancement of native vegetation communities on private land is complex as

there are many types of private land use.

The only effective way of protecting native vegetation, whether planted seedlings or natural regeneration,

from grazing animals on private land is by some of fencing, either of individual plants or areas for

regeneration.

The Decision guidelines for the Rural Conservation Zone (RCZ) and Green Wedge Zone (GWZ) require for

‘Rural issues’ that the responsible authority as appropriate must consider (inter alia): The environmental capacity of the site to sustain the rural enterprise. The need to prepare an integrated land management plan.

It is within the power of municipal councils under their planning schemes to require a land management

plan in relation to any proposed rural enterprise involving Animal production to address the issues of

whether a site has the environmental capacity to sustain a rural enterprise.

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An example of a Land Management Plan is to be found on the Nillumbik Shire website that says that ‘These

plans should generally accompany planning applications that seek new development and /or the

introduction of new land uses on land in rural or environmentally significant areas’.

In addition, the Green Wedges Coalition is concerned that pig farming that was originally defined as

‘Intensive animal husbandry’ in the VPPs and was prohibited in the RCZ and GWZ has now been classed

under the more general heading of Animal production. Pig farming risks the serious degradation of natural

resources including indigenous vegetation, soil erosion and offsite effluent pollution. Clause 53.16-2

specifies conditions under which pig farm planning applications are exempt from notice and third party

review. This means that a pig farm could be established without the knowledge of surrounding land owners

and without any right to object.

Waterways and Connectivity

Plan Melbourne identifies that: Existing green spaces need to be protected and new green spaces need to be created to improve landscape connectivity and resilience.

The vital importance of landscape connectivity for nature conservation is well recognised and documented

internationally. It is vital to connecting otherwise isolated parks and reserves. This is essential to enable

genetic diversity to make species more robust to changes in environmental conditions. Connectivity

increases the size of habitat availability and most significantly in this era of climate change enables species

to migrate to from increasing hostile changes conditions to more suitable habitat for their survival.

The waterway corridors are of major importance as wildlife corridors.

Waterways are now well recognised as Green Infrastructure. But it is the view of the Green Wedges

Coalition the protection of these waterways is not accorded the priority by the State Government they

require.

Biodiversity sensitive urban design

While the focus of the Green Wedges Coalition is on the 17 outer municipal councils that control the Green

Wedges in the Greater Melbourne Metropolitan area, we are also concerned about the impact of urban

consolidation on biodiversity and wildlife in the urban areas of the inner and middle ring municipalities.

We support the concept of biodiversity sensitive urban design being by researchers at RMIT University and

the University of Melbourne …to incorporate existing ecological knowledge into a framework that can be

used by planners and developers to ensure that biodiversity conservation is considered in the decision

making process. .vii

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Summary In the Independent Review of the Wildlife Act 1975: Issues Paper, the question is asked what should the Act

do?

The Green Wedges Coalition considers that much more emphasis should be placed on enhancing existing

indigenous vegetation communities as the key to the protecting our wildlife. Any revision of the Wildlife Act

needs to facilitate this crucial relationship.

If we don’t achieve net gain of our indigenous vegetation communities then wildlife will continue to be lost.

We consider, as a significant case study, the urgency of the task is well demonstrated by the continued and

accelerating loss of the biodiversity caused by the pressures of urbanisation of the 276,000 hectares of

privately owned rural land in the Green Wedges that virtually forms a green belt surrounding the inner and

middle ring municipalities of the Greater Melbourne Metropolitan area.

This urbanisation is caused by allowing urban uses in the rural areas and the excessive bulk and scale of

built development and its associated infrastructure.

We also consider that there is lack of coordinated attention given to importance of waterways as green

infrastructure and their vital role as wildlife corridors/biolinks. The present approach by Melbourne Water

while well intended lacks the whole of Government approach required to achieve the appropriate priority

and funding.

We see the review of the Wildlife Act as providing a much needed opportunity to facilitate change across all

of government and the community to the importance of protecting and enhancing all existing indigenous

terrestrial and riparian vegetation communities as the vital habitat for the future health of Victoria’s

wildlife.

Rosemary West

Coordinator Green Wedges Coalition

(Incorporated as the Green Wedges Guardian Alliance Inc A0046546X)

28 June 2021

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Attachment 1

Endnotes i The Green Wedges Coalition is comprised of 164 community groups from around Victoria. The Green Wedges were originally put into place in 1971 and formally recognised in 2002 in the planning document Melbourne 2030. Since our group formed, we have worked tirelessly to protect Green Wedges from inappropriate development. As a result, we have extensive experience in working with planning issues, drawing upon federal, state and local planning legislation and developing a practical understanding of how the regulations interact and operate ‘on-the-ground’. In its charter, the Green Wedges Coalition recognises that:

This vision for Melbourne, handed down by our parents’ generation, has helped make ours into one of the most liveable cities in the world. At a time of unrivalled prosperity, rising community awareness and appreciation of the value of green city spaces to our personal wellbeing, we regard maintaining the green wedges for future generations as a yardstick for our generation’s commitment to developing a sustainable city in a sustainable world.

We represent the lived experience of planning decisions that affect our daily lives, and we have tracked the ongoing

effects of inappropriate development and the impacts on communities for almost two decades.

ii Source: The Nature Conservancy and Resilient Melbourne (2019) Living Melbourne: Our Metropolitan Urban Forest.

The Nature Conservancy and Resilient Melbourne, Melbourne iii Hurley, J et al. Urban Vegetation Cover Change in Melbourne 2014 - 2018, Centre for Urban Research, RMIT

University, Melbourne, Australia. iv The Nature Conservancy and Resilient Melbourne (2019) Living Melbourne: Our Metropolitan Urban Forest. The

Nature Conservancy and Resilient Melbourne, Melbourne. v Search the Native Vegetation Credit Register – User Guide. Department of Environment. Land Water and Planning,

2019 vi See website https://cur.org.au/project/onsets-not-offsets-for-real-biodiversity-gains/

vii Reference: Garrard, G E et al Biodiversity Sensitive Urban Design. Conservation Letters, March/April 2018.