The Hon. Carmel Tebbutt MP

Minister for Climate Change and the Environment

Governor Macquarie Tower

Level 30, 1 Farrer Place

SYDNEY  NSW  2000

 

Dear Minister

 

Re: Recovery plan for the koala (Phascolarctos cinereus)

 

Friends of the Koala is a voluntary wildlife rehabilitation group of some 350 members which is licensed by your Department to rescue, rehabilitate and release koalas in the local government areas of Ballina, Byron, Kyogle, Lismore, Richmond Valley and Tweed. In the year 1 July 2007 to 30 June 2008 we recorded 549 koalas across the Northern Rivers. 277 animals were either dead on arrival or brought into care. 45 koalas were released back into the wild.

 

Friends of the Koala engages in a range of activities which aim to protect and restore koala habitat in the Northern Rivers and to educate the community about the fragile plight of the Region’s remaining koala populations. We are also establishing research linkages with several universities. The group was founded in 1986. Our mission is conserving koalas, particularly in the Northern Rivers Region of New South Wales, in recognition of the contribution the species makes to Australia’s biodiversity. As you also may be aware, the koala is an icon species and a major tourist draw card for north-eastern NSW.

 

Minister, we are writing to congratulate you on approving the Recovery Plan. We acknowledge that this planning approach dropped in priority some years ago, soon after the Draft Plan was on public exhibition during 2003. The Plan’s completion, we conclude, is testimony to the government’s belief that there are measures which can be taken to save the State’s koalas.

 

In offering our congratulations we also take the opportunity to make a few general observations about the Plan and also about the particular situation of the Northern Rivers’ koala populations as we know it.

 

Friends of the Koala appreciates that the Plan’s gestation has been lengthy and that considerable effort has been made to take account of recent research and legislative changes. We are also aware that some of the actions have been completed or are in progress.

 

In our analysis of the costing provided, nearly two thirds is considered in-kind as many of the actions are to be undertaken as part of the core duties of the Department. This is a matter of concern because we suspect the Plan’s roll-out may be held up by inability or reluctance to satisfactorily re-organise internal priorities. As an agency partner we are only too well aware of the continuous cost-cutting and re-structuring which has occurred within DECC over the past decade or so. This together with the integration of the former NPWS with other departments has considerably weakened the overall conservation objectives and outcomes of the agency as a whole.

 

The exquisite timing of your launch is noted. At the national level, evaluation of the 1998 National Koala Conservation Strategy has been completed and is being disseminated. The steering committee is currently revising the Strategy, and writing an accompanying implementation plan to address the issues raised in the evaluation which will be available for public exhibition and comment in 2009.

 

Across New South Wales local government is under direction to prepare comprehensive local environmental plans (LEPs). Indeed on the Northern Rivers, Lismore City Council has already forwarded its Draft LEP to the Minister for Planning for approval for public exhibition. Regrettably the Draft, which was prepared without any full or comprehensive public consultation, does not include the significant areas of koala habitat we consider important in environmental protection or management zones. Ballina Shire Council has also forwarded its Draft Plan for registration.

 

The reason for raising this is that if the Recovery Plan is to achieve its outcomes it must operate at the local scale and it is therefore reliant on local government embedding areas of conservation importance for koalas into their planning processes. Assistance and direction from state government agencies to councils to achieve these outcomes must be forthcoming immediately.

 

Acknowledgement of the shortcomings of State Environment Planning Policy 44: Koala Habitat (SEPP 44) and its urgent revision are very welcome indeed. None of the local government authorities which we service have in place approved Comprehensive Koala Plans of Management (CKPoMs) although Lismore has a shelf document for the south-eastern part of the local government authority. It is encouraging to see that the coastal councils of Ballina, Byron and Tweed are identified as priorities for future preparation of CKPoMs or equivalents.

 

We believe that all the local government areas in the Northern Rivers need to have funding incentives extended to them to either commence, progress or complete CKPoMs. Without such funding incentives being provided, councils are unlikely to progress towards shire-wide comprehensive plans due to other financial priorities and therefore the opportunity for strategic, regional conservation outcomes to identify koala habitat, threats and management actions at the local scale will be lost.

 

The missed opportunity of only two CKPoMs in place with 13 years of SEPP44 is matched, in our view, by the inadequacies of other state-wide legislation such as the private native forestry regulations and codes of practice (introduced in August 2007) and the un-regulated routine agricultural maintenance activities (RAMAs) allowed under the Native Vegetation Act 2003.

 

In our experience downgrading the threat of private native forestry (PNF) from being “…a particular threat…” in the 2003 Draft to “…may pose a threat…” in the 2008 Plan on the basis of a basically self-regulating code of practice is nothing short of naïve. Under the code, pre-logging surveys are not required and the koala prescription only gets triggered where Wildlife Atlas records exist. It is then up to the contractor to implement the prescription. Removal of koala key feed trees such as Tallowwood is as equivalent to clear felling for koalas as they rely on these key feed trees being available across their home range. We understand that government is in the process of drafting a new Forestry Management Act for PNF and we strongly recommend that a review of the effectiveness of the present threatened species measures (including for koalas) in the Code of Practice is urgently required. This must include on-site auditing and monitoring of compliance with the code and effectiveness of prescriptions with respect to impacts on individual koalas and their habitat.

A local example of the impact of RAMAs is the removal of eucalypt windbreaks which surround macadamia orchards. You will be aware that the Northern Rivers is the centre of the State’s macadamia industry. The windbreaks planted by orchardists to protect young trees may provide the only koala habitat for miles around. Many orchardists have no compunction about clearing mature windbreaks when they have outgrown their farm-management usefulness, even when trees are occupied by koalas.

 

We also need to point out the importance for koalas of the Forests and Parks estates in northern NSW. An estimated 2.5 million hectares of the State are at risk from Forest Dieback (and suspected links with global warming). Although light mention of this is made in the Plan, koalas are likely to be subject to further stresses from the impacts of climate change that may effect habitat quality. Further research is required to monitor these threats.

 

We applaud the provision of information on landscape-scale planning and habitat variables and the interactions between them in the Plan. In our view there is little understanding about these important issues outside of scientific and academic circles, yet there is an urgent need for the identification of key habitats and mosaic of linkages across the landscape, both protecting existing areas and promoting new corridor linkages. For these and other reasons we believe a Koala Summit is well overdue and should be held sooner than later.

 

A very disappointing aspect of the Plan in our view is its cavalier treatment of disease in koalas. Whilst we note the acknowledgement given to local variation of threats we are still surprised at the emphasis given to anthropogenic factors. You will be interested to learn that on the Northern Rivers nearly 60% of koalas brought into care suffer from a range of diseases including but certainly not limited to chlamydiosis. While mention is made that not all strains of Chlamydia are natural infections of koalas, koala retrovirus (KoRV) and other diseases are ignored.

 

Friends of the Koala enjoys a very close relationship with the Australian Wildlife Hospital at Beerwah in Queensland which employs a large and specialised wildlife veterinarian team working at the cutting edge of veterinary diagnostics and treatments under the leadership of Dr Jon Hanger. On the basis of the assistance given us we claim access to arguably the best standard of veterinary intervention and supervision for koalas available to any voluntary wildlife rehabilitation group in New South Wales.

 

Some ecologists may not see the long-term survival of koalas being threatened by Chlamydia or even KoRV, however wildlife rehabilitators and the veterinarians who support them work with the impact of disease on a daily basis and must reconcile the small number of animals which are released back into the wild on the Northern Rivers despite extremely high standards of husbandry practice. It is very difficult for us not to relate factors such as fertility loss and trauma brought about by pre-existing disease conditions with population declines. Further pressures for urban and industrial expansion, agricultural expansion and intensification and forestry within north-eastern NSW will only see the impacts of stress and trauma related disease increase unless a significant attempt is made to coordinate habitat protection and minimise other threats at the local scale.

 

Another point of disappointment is that the Plan does not specify the koala populations that the Department has identified for active management, monitoring and conservation, other than those of  Coffs Harbour and Bellingen. Relatively little scientific work has been done on populations in the Northern Rivers. Why that is the case is something of a conundrum. Is the explanation as simple as the Region’s distance from Sydney?

On the basis of the numbers of animals being reported and admitted to Friends of the Koala, we believe that the Northern Rivers’ populations are of State and even National significance. Therefore it is of great concern to us to read that particular emphasis is to be given to surveying those populations previously studied. None of those previously studied populations fall within the area serviced by Friends of the Koala.

 

In conclusion Minister, Friends of the Koala supports the notion of localised koala recovery based on involvement by stakeholders and we are anxious for some clear guidance as to how this is to be delivered. Where will the leadership and resources come from? Will there be an information session about the Plan in the region? Is there to be a regional steering group with representatives of the partners identified in the Plan, i.e. DECC, the catchment management authority, local government, community organisations such as wildlife rehabilitation groups, land managers? Is there, for example, an intention to use the Northern Rivers Regional Biodiversity Management Plan (presently being finalized by DECC Coffs Harbour) as a focus?

 

In our view, work which supports broadly agreed objectives and priorities at the local and regional level is more likely to contribute to the maximisation of koala management and conservation outcomes than work which is uncoordinated or unknown to other local and regional stakeholders.

 

We would like to extend to you and your family a very cordial invitation to visit us on the Northern Rivers, perhaps over the Summer holidays. It is a beautiful part of the world and we would very much enjoy showing you our modest Koala Care Centre and to talk to you further about the work we do and the issues that are of particular concern to us here in recovering the koala populations of the State’s north-eastern corner.

 

Now that the Recovery Plan has been launched we eagerly await the next step. The welfare of the Northern Rivers’ koalas must not be further jeopardised by political and bureaucratic decrepitation.

 

We thank you for your attention to the matters we have raised and look forward to your prompt and detailed response.

 

 

Yours sincerely

 

 

 

 

Lorraine Vass

President

10 December 2008

 

 

encl. 2007-8 Friends of the Koala Annual Report

         Treetops. September and December 2008