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Submissions archive

Invasive Species Management Act

The Victorian Government is planning to introduce a new Invasive Species Management Act. This joint submission from the VNPA and Invasive Species Council asks for shared responsibility by both the Minister for Agriculture and the Minister for Environment, and an independent expert panel to make recommendations on listings of invasive species, among other things.

We have also asked for public consultation on an 'exposure draft' of the proposed Act.

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Wildlife (Game) Regulations 2012: Regulatory Impact Statement

In making this submission the VNPA has great concern that the general assumption throughout the Regulatory Impact Statement is that the regulations will only impact hunters and shooters.

Hunting regulations and prescriptions, gun ownership, wildlife protection and pest management are all significant concerns of the broad community across Victoria.

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VEAC's Development of the Marine Investigation Discussion Paper

This submission outlines the critical areas that the Victorian Environmental Assessment Council (VEAC) should consider in the development of the Marine Investigation Discussion Paper.

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Alpine Resorts Co-ordinating Council's draft Alpine Resorts Strategic Plan 2012

In this submission the VNPA is concerned that the alpine resorts are not giving due emphasis to environmental management, despite clear legal obligations.

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Joint submission with the Australian Conservation Foundation on the Mallacoota Open Ocean Access Development (Bastion Point boat ramp development)

March 2012

The Victorian National Parks Association continues to support a low-key upgrade of the existing boat ramp and surrounding area at Bastion Point, without a breakwater, and is disappointed that such an option continues to be dismissed.

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Joint submission with the Australian Conservation Foundation to the Future Fisheries Strategy: Proposals for Reform.

March 2012

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Submission to Growth Areas Authority, Growth Corridors Plan, Draft Conservation Strategy and Sub Regional Species Strategies

December 2011

This submission includes comments on both the Draft Corridor Plans, Conservation Strategy and the Sub-regional Species Strategies.
1.0 Strategic and Process Issues.
2.0 Southern Brown Bandicoots Sub Regional Species Strategy.
3.0 Growling Grass Frog Sub Regional Strategy.
4.0 Golden Sun Moth Sub Regional Species Strategy.
5.0 Other Issues.

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Submission to the 'Investigation of fuel and bushfire risk management using strategic cattle grazing'

December 2011

In making this submission the Victorian National Parks Association is greatly concerned that the Department of Sustainability and Environment's referral document is short on crucial information and that the scientific trial has not yet been designed, despite havingbeen publicly proposed for more than a year.

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Submission in response to the Draft Code of Practice for Fire Management on Public Land

December 2011

The VNPA response to the draft Code of Fire Practice is based on the understanding that the situation in Victoria (the likelihood of an increased frequency of severe fire) will be very difficult to manage from both a public safety viewpoint, and from a biodiversity protection viewpoint.

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Proposed marine investigation terms of reference

August 2011

The VNPA believes the Victorian Government's proposed terms of reference for its marine inquiry need to be expanded to include the state's entire marine environment.

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Unlocking Victorian Tourism

A report by the Victorian Competition and Efficiency Commission called Unlocking Victorian Tourism makes a number of important recommendations that, if implemented, should prove very useful.

However, it also makes recommendations that could permanently compromise Victoria's magnificent and hard-won system of national parks and reserves.

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Protection of blue gropers in Victorian waters

In March 2011 Fisheries Victoria asked for comments about a proposal to prohibit the take of Eastern Blue Groper (Achoerodus viridis) and Western Blue Groper (Achoerodus gouldii) by all fishing methods in Victorian waters.

In its submission the VNPA has strongly supported a 12-month immediate protection notice for this species as well as the development of a longer-term conservation program.

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Mangroves in Westernport Discussion Paper

The VNPA's comment on a science-based discussion paper published by the Department of Sustainability and Environment that will help increase communtity awareness about mangroves in Westernport and inform a future strategic planning approach.

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VEAC Metropolitan Investigation Discussion Paper

A joint submission by the Victorian National Parks Association, Environment Victoria and The Wilderness Society in response to the Victorian Environmental Assessment Council's Metropolitan Melbourne Investigation Discussion Paper.

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Broadcast Australia's residential development proposal for the corner of Sydenham and Taylors roads, Sydneyham

The VNPA believes that the clearing of this site as proposed should not be allowed and that all areas of critically endangered Temperate Grasslands of the Victorian Volcanic Plain should be retained.

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Growth Area Framework Plans - initial submission

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Submission to the West Wimmera Shire Council on remnant vegetation removal September 2010

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Joint Submission to East Gippsland Forest Management Zone Amendments - September 2010

The VNPA, the Wilderness Society Victoria, the Australian Conservation Foundation and Environment East Gippsland have collectively many decades of active involvement in forest management issues in East Gippsland. This new draft zoning proposal represents the most significant reassessment of changes to the informal reserve system since the inception of the East Gippsland Regional Forest Agreement in 1997.

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Submission to the Victorian Environmental Assessment Council (VEAC) - Remnant Native Vegetation Investigation: Discussion paper - August 2010

This submission responds to the themes in the VEAC report in detail, and also outlines a number of other potential themes or strategic directions. The VNPA would like to encourage VEAC to ensure that the final report contains enough detail in its recommendations to ensure that they can be actionable and measurable.

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Submission in response to the proposal of Origin Energy Limited to carry out petroleum exploration - July 2010

This submission is in response to the proposal by Origin Energy Limited to carry out both land-based and marine petroleum exploration (seismic survey) within the Bay of Islands Coastal Park (Victoria) and offshore marine environment.

The VNPA is strongly against any form of petroleum exploration or extraction in marine and terrestrial national parks. The VNPA was not consulted during Origin's community consultation process.

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Submission in response to the Draft Fire Operations Plans - August 2009

The VNPA supports Victoria's Fire Operations Plan's zoning system, across all land tenures, as the basis for determining strategic management burns in Victoria. However, there remain serious concerns with the implementation of that system.

Download submission plus attachments


Planning for Nature Conservation in Melbourne's Newest Sustainable Communities - submission, July 2009

VNPA final submission to the Urban Growth Boundary/Protected Areas,
Outer Metropolitan Ring/E6 Transport Corridor, Western Grasslands Reserves and the Biodiversity Impact Assessment Report Environment Protection and Biodiversity Conservation Act 1999:

Chapter 1: Overview and Summary

Chapter 2: Strategic Assessment Process and Institutional Issues

Chapter 3: Conservation Priorities in Growth Areas - summary

Chapter 3.1: Wyndham Growth Area

Chapter 3.2: Melton-Caroline Springs Growth Area

Chapter 3.3: Sunbury Growth Area

Chapter 3.4: Whittlesea/Hume and Merri Creek Corridor

Chapter 3.5: South East Growth Area

Chapter 3.6: E6 Transport

Chapter 4: Recommendations for Ecological Communities and Species



Submissions to the Victorian Bushfires Royal Commission - May 2009

The 2009 Victorian Bushfires Royal Commission is investigating the causes of the 2009 fires, and the preparation, planning and resourcing of fire management. The Royal Commission will also report on the provision of emergency services and "any other matter the Commission deems appropriate". Most importantly, it will make recommendations on the "use, planning and management" of land.

Download VNPA Preliminary submission

As part of its preliminary submission the VNPA also submitted three attachments:

  • Attachment 1: Catering for the needs of fauna in fire management: science or just wishful thinking? Michael F. Clarke, Department of Zoology, La Trobe University.
    Download attachment
  • Attachment 2: Submission to the Inquiry into the Impact of Public Land Management Practices on Bushfire in Victoria.
    Download submission
  • Attachment 3: Critique of the main conclusion in the Victorian Parliamentary Environment andNatural Resources Committee (ENRC) inquiry.
    Download critique

In February 2010 the VNPA also made a supplementary submission to the Commission addressing planned burning.

Download supplementary submission

There are two attachments to the supplementary submission:

In April 2010, the VNPA responded to the formal recommendations to the Commission by their Counsel Assisting. In this submission, the VNPA could only refer to evidence already before the Commission. Primarily, the VNPA asked for the setting up of a science-based process for refining planned burning over the years ahead.

Download VNPA response to Counsel Assisting


Response to Draft Hog Deer Management Strategy - December 2008

The strategy reads as being more concerned with hunting opportunities than biodiversity protection, and is not at all convincing in its claim that increasing hunting opportunities for Hog Deer, including opportunities on private land, will result in good biodiversity outcomes. Essentially, management support for environmentally damaging species will increase their impacts on natural systems.



Submission Tidal Turbines proposed at the entrance to Port Phillip Heads - September 2008

The project proposes to establish 45 tidal turbines and 2 km of marine cable over an area of 169 ha.  The cable will connect the turbines to the Pt Lonsdale electricity grid.  Victorian National Parks Association believes this project is likely to have a significant impact on the immediate and surrounding marine ecosystem.

Download VNPA submission


Desalination Plant EES - September 2008

VNPA believes that the Environmental Effects Statement for the desalination plant is being rushed through without sufficient checks and balances needed to assess the true impact.   The desalination plant will emit around 1,117,950.00 tonnes of carbon dioxide annually equivalent to putting 284,465.00 cars back onto Melbourne’s roads.  The plant will also have a significant impact on the marine environment.

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Draft Fire Operation Plans 2008-2011 - August 2008

Many proposals in the Department of Sustainability and Environment's draft ‘Fire Operation Plans’, released in August this year, are alarming. The plans include hundreds of kilometres of firebreaks, burns stretching over vast areas, burns in Reference Areas, Wilderness Areas and wet forests classified as unsuitable for fires, and even re-burns of areas scorched in 2003.

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Land and Biodiversity at a Time of Climate Change Green Paper - July 2008

Released for public comment in April 2008 the Victorian Government's Land and Biodiversity at a Time of Climate Change Green Paper is a precursor to the final Land and Biodiversity White Paper, which is expected out in 2009 and should set the agenda for how the State Government manages biodiversity into the future.

Download VNPA submission
Download Victoria Naturally Alliance submission
Download environment groups' submisssion


Expansion of Mineral Sandmining in Victoria - April 2008

There are a number of proposals to mine mineral sands in Victoria apart from the Douglas Mine which commenced operations in 2006 (see picture of Douglas mine). Two proposed mines are in the process of assessment by an Environment Effects Statement. We have concerns about impacts on flora and fauna, especially at the Ouyen proposal, and about the use of water resources at the Donald proposal.

Download Ouyen sandmine submission
Download Donald sandmine submission


Anglesea Borefield Submission - March 2008

A proposal to extract groundwater from beneath the Anglesea Heathlands to supplement Geelong's water supply could have detrimental effects on wetter habitats within the heathlands including parts of the Great Otway National Park.

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Draft Victorian Coastal Strategy 2007 - January 2008

The draft Victorian Coastal Strategy sought comment last year. The final VCS will propose a plan to ensure adaptation to climate change, protect significant environmental features, give clear direction for future marine use and identify sustainable development opportunities.

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Construction of strategic firebreaks in Victoria's Central Highlands - December 2007

The impacts of proposed firebreaks are both extensive and complex in nature with many uncertainties. The justification for the proposal is not well supported, especially in the wetter forest types. For these reasons the proposal deserves full environmental assessment including detailed public submissions and an independent panel hearing to consider the entire project.

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Parliamentary fire inquiry - May 2007

Following the massive fires in 2006-7, the Victorian Parliament set up an inquiry into fires and land management. The VNPA made a submission on the impacts and effectiveness of various forms of fire prevention, including their effects on flora and fauna.

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Submission on the Supplementary Environment Effects Statement for the proposed Channel Deepening Project in Port Phillip Bay - May 2007

The submission period closed for the Supplementary EES. The VNPA strongly opposes the Channel Deepening Project because the Bay’s assets are too precious and the risks too high.  The very many risks are cumulative so the chances of something going seriously wrong are great.  The multiple possible impacts on a large number of areas and environments, and the unpredictable interactions in the system, make for many uncertainties and a strong possibility that unforeseen (or even foreseen) disasters will occur.

Download VNPA submission to SEES


Submission on the Port of Hastings land use and transport strategy - December 2006

Submission for the Port of Hastings land use strategry closed in December 2006. A large-scale port development such as that proposed in the Port of Hastings Land Use and Transport Strategy (PoHLUTS) is inappropriate for Western Port Bay. The proposed development will extensively impact the marine and terrestrial environment, both which have high ecological values. Due to circulation patterns in Western Port, a large port development also increases the risk of widespread damage to the entire bay through turbidity, oil and chemical spills, as well as marine pests.

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