Is WA on the right track to fully protect the South West forests?
May 31, 2023

Update on the development of WA’s next 10-year Forest Management Plan: a summary of two key issues.

Western Australia’s Forest Management Plans (FMP) are the overarching State Government plans that guide how the South West forests are managed across 10-year time frames. The next FMP will come into effect in 2024 and will be the first to exclude logging in native forests and to have management of forests for conservation as a primary objective.

In this time of climate and biodiversity crisis, it is crucial that the FMP 2024-33 be completely watertight in terms of forest protection and enhance the conservation system to protect the forests’ many intrinsic values, support their resilience and mitigate  against the worst impacts of climate change into the future.

The FMP will be assessed by the Environmental Protection Authority (EPA)

Early in May 2023, the EPA called for public submissions on the level of assessment that should be set for the FMP. Over a 7-day period, 653 submissions were received by the EPA, with 636 (97%) of them calling for the highest level of assessment, known as a Public Environmental Review (PER).

On the 28th May, we were informed that the EPA has decided to assess the FMP, but it will not be conducting a PER. Instead, it will be assessing on referral information with additional information and targeted consultation. 

The EPA has said that in view of the consultation that has already occurred on the draft FMP through the Dept of Biodiversity, Conservation and Attractions (DBCA) process in late 2022, targeted consultation is appropriate, as opposed to a full Public Environmental Review. This decision is not appealable.

While it is true that consultation has been conducted already, there are key differences between DBCA and EPA consultations. For example, consultation done under the Environmental Protection Act would have allowed for the health and climate change implications of prescribed burning to be considered. These important matters are substantially outside the scope of the CALM Act and therefore were not a focus of previous DBCA consultation.

The preliminary environmental factors that the EPA has said it will assess against are social surroundings, flora and vegetation, terrestrial fauna and inland waters. Given the substantial emissions from prescribed burning every year, and the significant potential climate impacts from other activities, greenhouse gas emissions must be added to this list.

Another concerning matter is the EPA’s reference to the concept of ensuring ‘best practice’. It is vital that EPA assessments look specifically at whether the impacts of an activity are acceptable or sustainable on a case-by-case basis, not in terms of how they stack up in a relative sense to other more or less impacting activities.

Clear and binding conditions
Assessing on referral information is not as comprehensive or robust as assessing through a Public Environmental Review, but importantly, it still provides the pathway for the EPA to make recommendations for Ministerial Conditions to be imposed on the final FMP.

Without clear and binding conditions, FMPs are not independently enforceable, and as the last 10 years have shown, this is a disaster for forest health, wildlife, biodiversity and community trust.

WAFA’s recommendations to the EPA
WAFA has been offered a meeting with the Chair as a part of the targeted consultation in late June.  Amongst other things, WAFA will be submitting that:

  • GHG emissions be added to the assessment factors;
  • consultation be carried out appropriately with various expert groups and individuals;
  • the ‘best-practice’ concept be removed from the approach in favour of precise impact assessments;
  • and for a suite of Ministerial Conditions to be recommended to keep delivery of the FMP on track for its 10-year period.

The additional protection of at least 400,000 ha of forests

Those who have been following closely will know that ensuring the FMP delivers on the Government’s promise to protect at least an additional 400,000 ha of forests has been complex.

Most recently, we identified serious inconsistencies between the Draft and Proposed FMPs, where key commitments have been edited out, leaving a gap of up to 320,000ha in the promised additions to the conservation system. For more details, see our fact sheet Ensuring the FMP delivers on the promise to protect at least another 400,000ha of forests

We have raised these issues with the EPA, Ministers and advisors over the past couple of weeks, and the Environment Minister’s office has now unequivocally reiterated to us that the Government remains firmly committed to delivering both the 320,000ha promised under previous FMPs, and the minimum of an additional 400,000ha that the Premier promised to protect in 2021.

For this commitment to be locked in, the FMP must unambiguously commit to a timebound, collaborative and enforceable process for securing the expanded conservation system.

Article by Jess Beckerling
WA Forest Alliance director
29th May 2023

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