Environment protection and biodiversity conservation ACT 1999 – submission by AESP national office to the department of environment and heritage, Nov 1999

1 November 1999







November 1999

To: Director, Legislation Implementation Task Force, Dept. of Environment and Heritage

The Consultation Paper for Regulations and Guidelines under the EPBC Act states that the EPBC Act is the first comprehensive attempt to define the environmental responsibilities of the Commonwealth. The Paper seeks views on the Government’s proposals for developing bilateral agreements with the States and the content of administrative guidelines on whether an impact on a matter of national environmental significance is significant.

Australians for an Ecologically Sustainable Population Inc draws to attention that population growth has significant impact on a matter of national environmental significance. The ‘matter’ is the environment that determines standards of living and quality of life for the bulk of Australians – mostly city dwellers. That environment is impacted significantly by long term population growth. In fact every aspect of environmental degradation throughout Australia has been caused by, and is being caused by, humans and their actions.

More humans = more impacts and significant overall impact. An example: Sustained population growth along with consequential increase in motor vehicle usage in recent decades has resulted in downgraded air quality. NSW State of Environment Report states that 400 deaths per year are linked to air pollution. Is that acceptable because humans are not an endangered species? Not endangered but certainly a vulnerable species.

An example of the extent of the environmental impact of people individually and collectively: The ecological footprint* of each person as stated in the Total Environment Centre’s 1999 “Greenprint for Sydney” is 5.6 – 6.75 ha at 1991-92 consumption levels. A year 2000 footprint of 10 ha per person is suggested. For Australia’s present population of 19 million, a calculation using 10 ha per person amounts to 190 million ha current ecological footprint. Net overseas migration for the year ended 31 December 1998 was 127,400 (ABS). At 10 ha per person that equals an ecological footprint of 1.27 million ha. If continued for ten years it would impact on 12.7 million ha. – hardly INsignificant. Immigration clearly has significant national environmental significance.

* Ecological footprint … is the estimate of the total area of productive land and water required on a continuous basis to produce all the resources consumed and to assimilate all the wastes produced by a population. It includes area for CO2 sequestration (trees).

The discussion paper states that the requirement for approval under the EPBC Act is triggered by an action which has, will have, or is likely to have, a significant impact on a matter of national environmental significance. Cumulative population growth via immigration results from an annual ACTION by the Minister for Immigration and Multicultural Affairs through his/her department. Population growth affects practically everything – ultimately significantly (ecological footprint). Because the population and its impacts accumulate incrementally and over decades is no reason for disregarding their existence.

The Department of Immigration and Multicultural Affairs (DIMA) should be required to fully take into account the potential long term environmental impacts of year by year decisions on immigration. For example, Sydney is bursting at the seams with 4 million people. The complex environment that determines quality of life is under stress yet every year many thousands more migrants are permitted to flood in. The broad social environment in which a great many people live is under stress. One example – health systems in crisis (Medicare) – population expands but the availability of hospital beds is not keeping pace. Sustained incremental population growth ultimately has significant environmental impacts of national significance.

” CSIRO believes Australia can carry its present population – or a higher one – in an economically, environmentally and socially sustainable way only if the nation is prepared to change the way it does things (writers emphasis). Australia lacks the necessary knowledge and understanding to manage effectively its current population at current living standards. Every extra person and every unit increase in consumption increase the need to rectify this situation quot;

(Australia’s Population ‘Carrying Capacity’: one nation – two ecologies, page 137).

DIMA is ill-equipped to make decisions or submissions on matters that have far reaching environmental consequences. DIMA should be required to refer proposed actions on immigration to the Minister for Environment under the EPBS Act. It is perfectly correct and desirable for an action affecting World Heritage Properties, Threatened Species, Wetlands, etc to require approval under EPBS. Administrative guidelines should also make it clear that DIMA is not immune from the requirements of the EPBC Act. Annually, the Minister for Immigration and Multicultural Affairs triggers actions that eventually have significant impact on matters of national environmental significance. Population growth and related environmental degradation is like smoking and health – direct linkage is obvious to all but those who do not want to see.

The discussion paper does not address an annual action by a Commonwealth Government Department (DIMA) with significant, national, accumulative, environmental impacts affecting the most important community of all – the Ecological Community of Humans.

Humans are not separate to the environment – we are part of it.

Geoff Grace


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