Response to Draft Report by Environment Australia
Environment Priorities and Coordination Group
5 November 1997
Overview and Main Points
Environment Australia welcomes the Industry Commission's endorsement of the principles of ecologically sustainable development in its draft report.
The basic thrust of the draft report's recommendations for change are in accord with Government environment policy. The duty of care principle is seen as offering a powerful tool to set and assist achievement of ecologically sustainable land management objectives. The principles relating to markets for natural resources and nature conservation on private land are seen as encouraging removal of perverse incentives as well as adoption of positive incentive measures for conservation.
Generally the report recommendations focus on legislative and regulatory principles and procedures, and market and incentive mechanisms. However, while much of this is valuable, we note that there are no recommendations about government measures to address specific land use problems in locational or physical terms, what actual outcomes should be sought, nor what particular standards should apply.
Following in this response to the draft report are detailed comments on various aspects as well as factual amendments. The report sought further information or views on a number of aspects. Where Environment Australia has views on these questions they are referred to in the body of this submission. However, the major points made in this submission are as follows.
- The duty of care proposed to be applied to landholders is of great value, provided it is based on a broad concept of environmental duty and is linked to clear standards for compliance. In this circumstance the principle is valuable both as a practical means of clarifying land managers' responsibilities, which is already in use in some environmental legislation, and as a general moral principle underpinning measures such as legislation, codes and standards.
- The report has not endorsed the proposal in Environment Australia's submission that there is a need for assessments in economic or ecologically sustainable development terms of patterns or forms of land use in Australia, to establish whether changes are needed. Such assessments are necessary to bring together and evaluate the improved information which the report seeks in chapter 16, when establishing the basis for codes of practice and mandated standards. In other words, assessments are needed to use information to establish whether forms of activity as presently undertaken are unsustainable, and what changes are needed.
- The report advocates the development of codes of practice by landholders and other stakeholders, and standards organisations, without a specified role for environment agencies or other bodies which often have the greatest expertise in the area of ecologically sustainable land management, but which may not be regarded as 'stakeholders'.
- On the proposal for single pieces of legislation within jurisdictions, this will raise issues of great complexity, and will involve a great deal of work, in each jurisdiction. At the same time, single legislation to cover ESLM is not necessary to establish a common set of principles in legislation relating to this area.
- Environment Australia does not support the role proposed for the Australian Bureau of Statistics, as responsible for developing standard classifications and consistent measurement protocols for the collection of state of the environment data. As this submission refers to below, there are Commonwealth-State processes under way dealing with this, involving agencies centrally concerned with state of the environment issues.
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