Purpose of this Paper

This submission is from the Stock Routes Coalition, a partnership between twenty-two community and government organisations to advocate for better management of the stock route network in the eastern States.

Overview

The Stock Routes Coalition considers that the authors of the Strategy have understood well the ecological priorities in conserving biodiversity, and the Strategy usefully encapsulates valuable insights about what ought to be done to protect biodiversity and by whom.

However, there is no identified process by which the ideals and objectives identified can be implemented. The draft Strategy has very little reference to the perverse incentives, the institutional obstacles, the reasons why past strategies have been only partly effective and the steps that must be taken in terms of public administration to reverse the acknowledged decline.

In short, without a feasible path to implementation, the ideals of the Strategy risk being labelled as simply platitudes and the Action Plan as simply wishful thinking.

Specific Comments

Lack of a feasible path

To achieve effective change, the managers of a program must assemble:

à                    legal power;

à                    a plan or strategy to guide what needs to be done;

à                    skilled people;

à                    data and information; and

à                    adequate financial and other material resources;

within the one centre of activity in order to implement the program. Arguably the Strategy summons the legal powers, the first essential ingredient, via the individual members of the NRM Ministerial Council; and the NRM Ministerial Council serves as a national coordinating forum. Arguably also, the Strategy provides the plan, the second essential ingredient. But there is no mechanism or institutional arrangements by which the staff, information and resources are assembled. Notably, there is no connection with the budget processes of the States or the Commonwealth.

Evidence of this deficiency is that the environment (apart from climate) scarcely featured in the recent $42 billion stimulus program or the publicity surrounding the 2009 national budget. To the extent that climate was funded, most of the allocations focused on the energy aspects and promotion of coal, not on environmental adaptation.

Queensland's Regional Groups Collective (representing Queensland's 14 regional NRM bodies) is a member of the Stock Routes Coalition. It would no doubt agree with the actions identified under item 4.3 on page 34; but having seen the base grants for regional NRM reduced during the 2008 round of Caring for our Country, it would question how these actions can possibly be achieved.

Further, in the May 2009 national budget, funding for Land and Water Australia was axed. This decision sits awkwardly with the "Knowledge for all" priority for change identified in the Strategy. Land and Water Australia was a major source of scientific and technical knowledge about biodiversity and about how to integrate biodiversity with socio-economic, institutional and other disciplinary spheres of knowledge.

In short, the Strategy is disconnected from the processes by which public moneys are allocated. Given that the national and State budgets are the primary expressions of public policy by their respective governments, the Strategy must be reflected in budgets if it is to influence policy.

Lack of reference to the institutional obstacles

The Strategy is weak in addressing the institutional and practical obstacles to tackling the problems.  Stock routes are mentioned on page 9 and the importance of these corridors in dealing with climate variability is mentioned, appropriately. Taking the stock routes in Queensland and New South Wales as an example, here are some difficulties facing any person wanting to improve management of the stock routes in their district in order to facilitate the adaptation of biodiversity to climatic variability by providing healthy corridors for movement and refugia for local provenances of plants:

à                    responsibility for management is shared between landholders, local governments and the State government, (and in New South Wales, Rural Lands Protection Boards) all of whom claim that they do not have enough funds and all of whom blame the others for the shortcomings;

à                    the legislation in Queensland, which is modern, provides an incentive to local governments in the form of agistment fees to allow static grazing which is the most widespread cause of damage to biodiversity on the stock routes;

à                    there is an understandable reluctance by governments to pay the cost of fencing boundaries of public lands with adjoining private land for public interest reasons. As it is commonly not in the interests of landholders to erect or maintain boundary fences, there is no obvious way of achieving this critically important protective measure.

The Strategy does not offer any optimism that these institutional barriers will be remedied or any forum in which they can be confronted.

Similarly, there is scant attention paid to some of the perverse incentives, even those under Commonwealth control – drought aid, for example, which in some cases subsidises landholders to retain stock well past the date when they should have been sent to market.

Appendix 5 contains some useful material but at only a theoretical level. There is no treatment here of the institutional obstacles from the point of view of the people who have to make biodiversity protection work. It would be helpful to beef up this appendix or, preferably, the body of the report, by input from someone with strong experience in practical implementation or strong knowledge of decision-making in public administration.

Tragedy of the commons analogy invalid

The reference to the tragedy of the commons “(Hardin 1968)” on page 10 runs the risk of misunderstanding this phenomenon. Although superficially a minor editorial point, the issue is worth mentioning as it illuminates the need for a better treatment of institutional obstacles in the Strategy.

In his famous essay, Garrett Hardin misrepresented the ancient feudal commons as open access regimes[1]. He later acknowledged his error but even muddled the retraction. Common property regimes have been the main form of managing natural resources, throughout history. Common property is not necessarily badly managed: the feudal commons had been grazed sustainably for hundreds of years.

The relevance of this for our current purpose is that in Australia, there are no open access regimes. All land, water and biodiversity are under the ownership or management of a private landholder by allocation originally from the State, or by the State, or by the native title holders by law or default. Land assumed to be under an open access regime usually appears that way because the State or local government has failed to adequately resource its management prerogatives. This is certainly the case for stock routes.

Misplaced optimism

The optimism in many places in the document, notably the second paragraph on page 10, is contradicted by the admission late on page 10 of "report after report of the downward trend in our biodiversity". The Stock Routes Coalition observes that biodiversity on stock routes is declining steadily under the pressures of climate change, static grazing and the continued advance of weeds. The attempts in the document to place a positive outlook ultimately weaken the effectiveness of its message: the second paragraph on page 16 is an example. Another example is the phrase "more than $2 billion Caring for our Country initiative" in the first line of page 23. When this allocation is spread over a number of years and a number of States, the figure can be seen for what it is: paltry.

Lack of ecological literacy at the leadership level overlooked

On page 26 appear a number of initiatives aimed at improving society's knowledge of biodiversity. There are two deficiencies here. The first is that there is no reference to training for senior public servants, business leaders or politicians in ecological matters. The level of ecological literacy in the Parliament and the top ranks of the Australian Public Service is pathetic. This is a major reason for the low profile that conservation receives in public affairs and budgets. Our society cannot afford to wait 20 or 30 years for primary school children to reach positions of leadership: the threats to biodiversity are far too urgent.

A second, related issue is that it is insufficient for children to learn about biodiversity at primary school, if their subsequent education pulls in a different direction. Biodiversity must be given a much stronger profile at secondary school and in undergraduate years. It is possible for graduates to emerge from university without any significant exposure to science at all, let alone biodiversity.

Inadequate funding for knowledge-generating institutions

The chart on page 30 overlooks reality: competition for funds from the Australian Research Council is fierce and the effort involved in putting together a bid that has any chance of success is exhausting for those involved. The ARC suffers from fashions and some forms of pure research are not fashionable. CSIRO has been down-funded (except for recent allocations for energy) and has been obliged to look for commercial partners to the neglect of public good research. All universities struggle for funds and regional NRM bodies which might have partnered the universities have seen their core grants (from which they could fund discretionary research) reduced. LWA has been abolished. Which institutions in sight are going to drive this growth in knowledge?

Language studies not mentioned

The objectives of recording and disseminating Indigenous knowledge, pages 40,41, are worthy ones. Perhaps the best method of recording Indigenous knowledge is to perpetuate the language to allow the people to express their knowledge through the vehicle which was traditionally used for that purpose. However, Indigenous language studies are not systematically or adequately funded and there is a disconnection between the anthropological sphere in which such studies are conceived; and the biodiversity sphere which would be a beneficiary of the studies.

Agricultural landscapes don't feature

Like it or not, our planet is now largely a man made landscape; and in Queensland, agriculture is the dominant land use over more than 80% of the land area. Biodiversity conservation must recognise this reality and must present policies and strategies that will achieve conservation WITHIN production landscapes.

The Stock Routes Coalition

25 May 2009