Forest Management Plan: EPA seeks public comment

The EPA released the proposed WA Forest Management Plan 2024-2033 (FMP) and related ‘referral’ information on 11th May 2023 for public comment. The EPA seeks public input on the level of assessment, if any, that the proposed FMP should be subject to.

Proposed Land Categories north of Collie (after Map 12, draft FMP).  (Click for larger map.)

HikeWest and many others submitted detailed comments to DBCA on the draft proposal during the earlier public consultation period. HikeWest has also outlined its concerns previously online. eg see “A not-so-historic plan to protect WA’s forests”.

The public now has only until 18th May 2023 (the end of the seven-day public comments period) to respond to the EPA and insist that the proposed FMP must be subject to the appropriate Public Environmental Review (PER) level of assessment. HikeWest will be responding.

Please consider submitting your comments to the EPA online here. HikeWest urges all to select the “Assess – Public environmental review” option in the online form. Your reasons for your preferred option can be very brief (no more than 500 words). HikeWest’s partial list of reasons below may help you identify some key issues.

HikeWest considers that the proposed FMP must be subject to the PER level of assessment for at least the following reasons:

  1. Public concerns ignored – The proposed FMP reflects that DBCA and Conservation and Parks Commission have ignored substantive, widespread prior public concerns expressed in submissions to DBCA during public consultation on the draft in 2022.
  2. DBCA is conflicted – DBCA is not only the originator of the earlier draft and the currently proposed FMP but is also a key stakeholder in the outcome, with an interest in achieving outcomes that suit DBCA’s, and/or the relevant Minister’s perspectives, rather than a properly distanced, independent and demonstrably objective view.
  3. Northern Jarrah Forest inadequately protected – There is no change to existing and previously proposed protection for the Northern Jarrah Forest from the previous ten-year plan. Under this FMP ~85% of the northern forest area will remain unprotected (ie outside of national parks) and highly vulnerable to new and ongoing mining (and associated logging).
  4. Small, disconnected National Parks – The FMP fails to provide for a network of interconnected national parks that is needed to provide and sustain viable forest ecosystems, especially in the Northern Jarrah Forest region.
  5. Illusory protection provided by Conservation Parks and other reserves – Existing and proposed ‘Conservation Park’ areas of known high conservation value are included in the Plan as if to imply they offer a secure future level of protection. Areas critical to the national conservation estate such as Julimar State Forest need to be elevated to national park protection status.
  6. Recreational need is inadequately addressed – A paragraph has been added to section 3.6.2 to reflect the importance of forest for recreation in areas close to major settlements. But neither section 3.6.2 nor 5.6.1 recognise for planning purposes the particular importance and proximity of the Northern Jarrah Forest for the Perth metro area where 80% of WA’s population is located. The FMP ignores the anticipated extensive loss of social amenity value of NJF due to mining, and the need for increased national park areas to reduce pressures for recreational and tourism developments on existing parks.
  7. The legacy of mining is not addressed -The FMP needs to address management of mined areas so that the enduring environmental and financial consequences of mining are identified as a State responsibility and are addressed appropriately.
  8. Impact of ongoing clearing of mature Northern Jarrah Forest on future carbon storage – The FMP proposes that “mitigation measures [will] include enhanced carbon stores through an expanded reserve system…” yet ignores the fact that over 60% of WA’s clearing of forests over the past decade has been for mining in the Northern Jarrah Forest, unrelated to the south west timber industry’s logging operations.
  9. Purpose of “National park” – The FMP (in Appendix 1a) wrongly emphasises the recreational (including tourism) use of national parks ahead of the conservation purpose; quote “National parks have national significance, and their purpose is to fulfil so much of the demand for recreation by members of the public as is consistent ……”  The definition requires changed emphasis to more unequivocally reflect that the intended primary role of national parks is for conservation, and that recreation and tourism objectives are secondary.

If the EPA determines that the FMP is to be assessed via the Public Environmental Review (PER) process, the EPA will then announce a public consultation period (possibly 12 weeks as occurred in 2013 for the previous 10 year Plan 2014-2023).

Please ensure you do your bit to try to improve the protection of our northern forest by responding to the EPA online by the 18th May deadline!

References and Other Reading

(Posted 13 May 2023.)

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