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Submission to the Estimates Committee Community Hearings
Submission to the Estimates Committee Community Hearings
Thank you for giving us the opportunity to appear before you.
The National Parks Association of the ACT has nearly 400 memberships and has been active for 45 years in promoting environmental and conservation issues. Its first mission was to establish a national park for the national capital and since achieving that goal we have worked hard to conserve and protect the capital’s natural environment.
The cuts in the Budget - while disturbing – are compounded alarmingly by the proposed administrative changes arising from the Functional review. The new arrangements offer very little savings but significantly reduce the authority and capacity of environmental agencies to carry out reasonable regulatory and administrative protection of the ACT’s environmental assets, including clean water, air and management of our parks and reserves.
Impact of new arrangements arising from Functional Review
From early reading of the proposed changes there is considerable cause for concern because there is:
- No identifiable EACT officer involved in transition planning at a senior level (The only amalgamation project identified for merging EACT with its new area is ‘Consolidation of Land Management Functions’.)
- No identifiable environmental expertise at a senior officer level
- No observable capacity to support regulatory functions of EACT at a suitably senior level
- It will be back to the good old days when a junior officer in Urban Services was charged with imposing environmental regulations on a more senior office in the same department,
- For example internal regulatory functions include dealing with air water or noise pollution and will lead to junior officers of TAMs attempting to deal with infringements by its own road construction area.
- External regulatory functions include regulating ACTEW’s operation of water and sewerage services under the Land Planning Act, and the licensing of such services under the Environment Protection Act. Junior officers will be expected to deal with potential infringements by a commercial organisation without an environmental champion at a senior level. Reduction in water quality and effluent discharge may be an outcome.
- These examples flag a serious potential for conflict of interest at senior management level of TAMs and an undermining of the regulatory regime which protects our environment.
- No environmental champion in the bureaucracy.
- Without a specific role to protect the environment currently enshrined in the role of Conservator and carried out at agency head level, housing developers will be free to remove trees and vegetation; road builders will be able to pollute water courses and activities harmful to both urban and rural environments will not be able to be checked.
- The public will lose confidence that there is someone in a senior position capable of making sound professional judgements in regard to contentious environmental issues such as road building, hazard reduction burns and water pollution.
- This also means no bureaucrat able to respond to public concern and media attention as Dr Cooper has today responded in CT to concerns about burning off in the Lower Cotter catchment.
- Will this increase public pressure on the Assembly to resolve issues previously sorted at agency level?
- Difficult environmental decisions, such as the kangaroo culling exercise at Googong Dam, will be lost in the bureaucratic processes resulting in increased public pressure on the Assembly to respond to issues previously addressed at agency level.
- Staff will have lost the means to raise concerns at a senior level within the system and have them resolved before they become a serious issue. For example, incursions by wild horses into Namadgi National Park after the 2003 fires were dealt with quickly and without public fuss in the past because the agency head was quickly informed of the issue and able to authorise action.
- Critical initiatives will be lost or undermined, eg the recent merger of ACT Forests with National Parks required leadership, good will and patience on both sides. This process still has a long way to go but the reason it has proceeded without public clamour about lost jobs or diluting of the environment skill pool is because of the leadership being exercised at senior levels.
· No advocate for environmental funding in the Budget process.
o A clear example of the long term damage from a reduced presence in the Budget process is the lack of ongoing funding for the maintenance of the new 44 kms of fire trails provided for in the current Budget. Without substantial maintenance over the next 30 years these trails will fall into disrepair and contaminate streams, erode into grasslands and destabilise stands of trees.
- It is difficult to se how, in the current climate, such funding would be found – and defended through the full Budget process. Put simply, the proposed structure does not allow for the expertise to understand and argue for priority for environmental funding.
- No separate environmental representation in Cabinet
- A significant body of public opinion will not be represented in Cabinet
- This creates the potential to overlook problems and walk into political hot spots with little prior warning or capacity to respond speedily and effectively
- Potential for the Assembly to become involved in minor issues eg tree preservation issues and minor licence breaches.
- A final example of how poorly thought through this functional review is – and how dangerous:
- Estimated savings from rationalising accommodation, consolidation of human resources, finance and information technology services will yield $1.29m
- BUT integrating policy functions will save $2.5m; that’s a lot of policy officers no longer doing the job
- Conclusion: policy development is being de-funded.
- This is not about savings; it is about the centralisation of the policy development process into the hands of a few public servants.
The actual Budget allocation of funds to the nominal environmental entities shows a lack of support for crucial activities.
- Further 10% cut in staff and funding flagged in general papers but no recognition that there has been about 20% reduction in staffing in EACT over the past two years.
- We were already considerably concerned about loss of on the ground staff in the park; it will get worse. As will the illegal shooting, feral animal and weed control programs etc
- Bulk of new money went to capital works for fire management: $9m over the next 4 years.
- Capital works for conservation cam in at $587,000. (Predator free sanctuary at Mulligan’s Flat, $350,000 and works at Tidbinbilla associated with threatened species, $.237m). There is no ongoing funding in this area.
- New money for conservation research, monitoring or climate change response is for threatened species research: $35,000.
- What new money there is misdirected to an extra 44km of fire trails and upgrading of existing 55 kms:
- This is a focus on last century fire management through large scale tanker capacity to get to remote bushland. It ignores the more effective and efficient strategies including quad bike operations, remote area fire fighting capacity and aerial fire fighting.
- Such trails will do considerable damage to the environment now and have enormous potential to continue to damage the environment over the next 30 years.
- Yet they may well be in the wrong place for the next fire, ineffective because they have been allowed to fall into disrepair by the time the next fire comes and no longer required because of more effective fire fighting techniques already in use.
- Actual on-going funding is not allocated against environmental outcomes and hence unaccountable and unsubstantiated.
- Where they are flagged we can see the nature of the cuts. For example, it is clearly stated that the Office of the Commissioner for the Environment will cease to report on Road Transport Regulations and Services; Public Transport; and Government Services. (page 300 Budget Page 4)
- References in the Budget papers are also deeply confusing:
- $41.786m is allocated for Environment, Sustainability, Heritage and Forestry services (p 297 Budget Paper 4). This is noted on page 325 as including the removal of the Arts budget of $12m and adding the Office of Sustainability $5.6m; Forestry $2.5m and Office of Environmental Defender $0.4m
- Yet the Environment and Heritage reference in the Budget is elsewhere referred to as $23.9m (p 325 Budget Paper 4) so if we add the Office of Sustainability, Forestry and Office of Environmental Defender as above, we get $32.4 a significant shortfall on $41.78.
- This seems to us to constitute an unacceptable lack of clarity in telling the public what will be spent on environmental programs.
- No breakdown of costs against function, contrary to last year’s budget.
What’s missing? Quite a lot of core business funding, for example:
- No response to climate change, eg additional funding for research into appropriate response to invasion by species migrating into the area in response to habitat changes in their traditional areas.
- No funding for implementation of the Namadgi Management Plan and the Lower Cotter Management Plan