At the risk of over-emphasising the issue of cattle grazing in the Alpine National Park, I’ve compiled some comments about the recent referral under the EPBC Act of Victoria’s so-called grazing trial (some other relevant pieces are here and here). These comments are the main elements of a submission that James Camac, Libby Rumpff, Georgia Garrard, Jane Catford, Yung En Chee and I sent to the federal environment department (SEWPaC) about the referral.
But first, I’ll provide some context. The coalition took a policy to the state election in late 2010 that cattle grazing would be permitted in the Alpine National Park after the previous government stopped it for economic and environmental reasons. Rather than honouring this election promise directly when elected, the state government decided to return cattle to the park under the pretext of a scientific trial to assess the effects of cattle grazing on fire risk. Based on activities to date, the scientific content of this so-called trial is questionable.
Given the presence of federally-listed threatened species and communities at the grazing sites, the federal government determined that the return of cattle should be referred under the Environmental Protection and Biodiversity Conservation Act. That referral has now been submitted by the Victorian Department of Sustainability and Environment (DSE), with a plan to return cattle in late 2012. Under the EPBC Act, the federal minister is required to consider impacts on Matters of National Environmental Significance, which include federally-listed species and communities.
We make five main points about the referral:
- The assessment of flora and fauna at the proposed sites is inadequate;
- Despite inadequate information in the referral document, significant negative impacts of the cattle grazing seem likely;
- The absence of a research plan means that details of actions at the proposed sites have not been provided or justified;
- The currently incomplete environmental management plan appears to contain most of the information about how environmental impacts will be managed, but the plan is not provided with the referral documents so its adequacy cannot be assessed; and
- There are scientific alternatives for assessing impacts of cattle grazing on fire risk that do not require introduction of cattle to the Alpine National Park; these should be investigated thoroughly prior to allowing possible impacts on Matters of National Environmental Significance.
These points mean that potential impacts of the cattle grazing on Matters of National Environmental Significance are likely to have been overlooked. Additionally, based on current scientific knowledge, documented threats to Matters of National Environmental Significance and the availability of potential alternatives to address the research questions, it is hard to see how the proposed activities can be approved. We expand on our points below.
1. The assessment of flora and fauna at the proposed sites is inadequate
The document “Fauna and Flora Desktop Assessment” on Matters of National Environmental Significance, which was an attachment to the referral, clearly states the inadequacy of the fauna and flora assessment (Section 2.7). It notes the data that were used are limited in extent, other data are likely to exist that could not be compiled in the limited time allowed by DSE, and that “where data is available, it is limited and patchy” (p. 14). According to significant impact guidelines 1.1 for the Environment Protection and Biodiversity Conservation Act 1999, when determining whether an action is likely to have a significant impact on a Matter of National Environmental Significance, the “self-assessment should be as objective as possible and based on sufficient information to make an informed judgement” (p. 3). The failure of a state government department to compile available information rigorously and collect further relevant and necessary information in a timely manner before submitting a referral under the EPBC Act should be questioned.
The level of rigour used to assess potential impacts on listed species and communities does not seem to meet the standards required of other referrals under the EPBC Act. At a minimum, the following should be required: field surveys for compiling species’ lists, targeted surveys for listed species, and rapid assessments to assess vegetation and to ground-truth mapped vegetation types.
The referral document implicitly acknowledges that impacts cannot be assessed properly until further flora and fauna surveys are undertaken. The document states that “the EMP and associated risk assessment will be updated following analysis of the survey results. Analysis of this information will assist in determining site-specific mitigation measures that are appropriate to effectively manage impacts from cattle grazing to the identified species and communities” (p. 12). If further relevant information can be compiled to help determine site-specific management, it should be provided as part of the referral so that the adequacy of any management can be viewed publicly and assessed by the federal minister.
The referral document titled “Matters of National Environmental Significance Risk Assessment” (Attachment 7 Part b) also lacks important information. The document does not describe the information that was used to conduct the risk assessment. Subjective risk assessments of this type are prone to bias (Burgman 2005), which is best reduced by clear and comprehensive descriptions of the factors that underpin the categorizations of risk: the data, other information and the basic logic that is used. Without such descriptions, it is impossible to evaluate the veracity and plausibility of the assessments.
The incomplete nature of the flora and fauna assessment means that impacts on Matters of National Environmental Significance are likely to be overlooked in the referral document.
2. Despite the inadequate information in the referral document, significant negative impacts of cattle grazing on Matters of National Environmental Significance seem likely
Despite the limited survey work, nationally-listed flora, fauna and ecological communities have been recorded in or adjacent to the proposed sites. Detrimental impacts of cattle grazing on some of these are known to occur through consumption and trampling (e.g., Attachment 7 Part B). One example of this is the Leafy Greenhood Pterostylis cucullata, which is likely to be present at all the sites (p. 39 of Attachment 5 Part A). The national recovery plan for this species, which was prepared by DSE (Duncan 2010), recognizes grazing and trampling by cattle as a major threat in Tasmania; cattle grazing is likely to be a significant impact wherever it co-occurs with the species.
The possibility of impacts of cattle grazing on the listed species does not seem to have been properly addressed in the referral documents; impacts of cattle grazing are mentioned for only two species in the Fauna and Flora Desktop Assessment (Austral Toadflax Thesium austral and Maroon Leek-orchid Prasophyllum frenchii). Even in these cases, the comments are very brief, and information on the need and ability to manage possible impacts is absent. Despite this cursory treatment of impacts of cattle grazing, the residual risks (Attachment 7 Part B) are assessed as high and very high for nationally-listed species and communities even in the presence of the unclear “management controls”. In some cases, these management controls were not predicted to reduce high and very high risks posed by the cattle grazing to numerous nationally-listed species and communities (see Attachment 7 Part B, Long-footed Potoroo on p. 1, Smoky Mouse on p. 2, Alpine She-oak Skink on p. 4, Alpine Tree Frog and Spotted Tree Frog on p. 5, Bog Willow-herb on p. 7, Bogong Eyebright on p. 8, Alpine Sphagnum Bogs and Associated Fens on p. 10).
Given the presence of nationally-listed species and communities coupled with poor knowledge of their precise locations, it seems likely that impacts will occur, though they might remain undetected. This is especially true for some of the fauna species that have very cryptic habits that make them difficult to detect when present, but that are likely to occur at the sites (e.g., some of the listed frog species and the Spot-tailed Quoll). The same issue is also likely to apply to some of the difficult to detect plant species, such as orchids.
The study sites comprise a mostly very remote area of almost 280 km2. A comprehensive flora and fauna assessment of this entire area, or even a fraction of it where cattle are proposed to be placed, has not been undertaken. Therefore, the claim in the Fauna and Flora Desktop Assessment that impacts are unlikely to occur seems overly-confident given the limited ability to determine locations of many species over such a large area, and the likely difficulties of monitoring and controlling cattle movements. At a minimum, comprehensive evidence needs to be provided to support the claim that the proposed environmental management plan can avoid significant impacts on Matters of National Environmental Significance when:
- the precise location of nationally-listed species cannot be determined reliably;
- only “a sample of cattle in each research site will be fitted with tracking collars” (p 10, Matters of national environmental significance risk assessment);
- the planned location of cattle grazing has not been determined; and
- possible impacts of cattle grazing on most species has not been considered.
3. The absence of a research plan
The referral document claims that the cattle are part of a scientific trial. However, the plan for this research has not been provided with the referral document, and it appears to be still in preparation. The continued absence of a research plan one year after cattle were introduced to the Alpine National Park is difficult to reconcile with claims that these activities are part of a scientific trial.
Such a research plan would detail the activities that would occur at the research sites, including the exact locations of grazed and ungrazed areas, the location, type and condition of any fencing, which environmental attributes will be measured, and how measurements will be made, analysed and used. The plan should justify the need and validity of stratifying site selection by elevation and aspect. In the absence of these details, it is not possible to precisely assess the impact of the activities on Matters of National Environmental Significance, or the rationale for choosing the particular sites and activities.
The absence of a detailed research plan also means that the ability of the proposed activities to estimate the fire management benefits of cattle grazing cannot be assessed. Indeed, even the attributes of the environment that are supposedly at risk from fire have not been identified.
A study of impacts of cattle grazing in New South Wales (Professor Mark Adams’ HighFire project) has so far not been able to reliably estimate the effect of cattle grazing on fire, and concludes that “the combined effects of fire and grazing may take decades to be fully apparent” (http://www.bushfirecrc.com/projects/b6/highfire-project). Assessing the likelihood that research will yield useful results is a standard aspect of experimental design and could be undertaken with the available information. Such an assessment has not been conducted. Without detailed information about potential benefits, it is difficult for the federal minister to weigh them against the likely environmental impacts. However, given results to date from Professor Adams’ HighFire project, it is hard to see how the proposed activities will provide comprehensive data or rigorous conclusions about the effects of cattle grazing on fire risk, especially in the absence of a research plan that shows otherwise.
4. The environmental management plan is incomplete and is not provided
The referral document refers to a draft environmental management plan (EMP) that will detail how impacts on Matters of National Environmental Significance will be managed. This draft plan is, by definition, incomplete, but it is also not provided in the referral. Therefore, it is impossible to assess whether impacts on Matters of National Environmental Significance will be reliably identified by the EMP if such impacts occur, or whether any proposed management actions are likely to be sufficiently comprehensive to manage possible impacts. This is another example where the referral document seems incomplete.
5. Scientific alternatives to determine the effect of cattle grazing on fire risk have not been considered
A large body of national and international scientific literature already exists about fire behavior and its response to fuel load, fuel type and environmental conditions. On the basis of this information, detailed models of fire risk have been developed. One of these models (Phoenix RapidFire) is already used by DSE for strategic fire planning and tactical fire management. This model could be used to assess likely impacts of cattle grazing of different intensities on fire risk by examining how changes in vegetation would influence fire behavior in alpine environments. Such a model could be used to identify the possible impacts of cattle grazing on fire risk, without the need for field trials. It could also estimate the magnitude of changes in vegetation and fuel loads required to achieve useful changes in fire behavior. Such a study would help to determine the need for field trials of the effects of cattle grazing. This simple example illustrates that there are alternative scientific approaches for assessing impacts of cattle grazing on fire risk that do not have any potential impacts on Matters of National Environmental Significance. Alternatives such as this or other options that avoid at least some impacts on Matters of National Environmental Significance (e.g., locating the study outside the Alpine National Park) should be rigorously assessed and documented prior to considering the proposed activities. According to the referral document, no alternatives were considered.
In summary, the referral document seems incomplete, but the information provided suggests that significant impacts on Matters of National Environmental Significance are likely. Until alternatives are considered, Matters of National Environmental Significance are assessed properly, and the planned activities and management methods are described in detail, a thorough assessment of the impacts of the proposed activities is not possible. Further, the benefit of the proposed activities, as measured by the quality of information provided about the effect of cattle grazing on fire risk, cannot be assessed until the research plan is finalized and its ability to estimate the effect of cattle grazing is determined.
Both the negative environmental impacts and the potential positive benefits of the proposed activities have not been assessed properly in the referral document. Based on the availability of potential alternatives to address the research questions, and threats to nationally-listed species and communities, it is hard to see how the proposed cattle-grazing activities can approved under the EPBC Act.
Burgman, M. (2005). Risks and decisions for conservation and environmental management. Cambridge University Press, Cambridge.