Protecting Victoria's Environment: Are we there yet ?

Protecting Victoria’s Environment Are we there yet ? This whitepaper reviews the use of scientific evidence in the policy document “Protecting Victoria’s Environment - Biodiversity 2037” prepared by the Department of Environment, Land, Water and Planning (2017). Name : Priya Narasimhan Student ID : 36579971 Word count (From Introduction to Conclusions) : 1512 Introduction Our economic and social development has come at a big cost to the numerous individual species of flora and fauna. Their disappearance is affecting the planetary balance in ways that are becoming a serious threat to the quality of our lives and livelihoods (Richardson et al, 2023). Victoria’s government has responded to this emerging crisis with a policy Protecting Victoria’s Environment - Biodiversity 2037 (Victoria. Department of Environment, Land, Water and Planning [DELWP], 2017) (henceforth referred to as “the policy” or “Biodiversity 2037”) to chart a 20 year plan to get us from where we are, which is a poor state of the natural environment, to a more healthy and biodiverse environment by 2037. Australia’s National Science statement (Australia. Department of Industry, Science and Resources [DISR], 2024) emphasises the place of science to develop evidence-informed policy and states that the government will incentivise the translation of science and research into sustainable industries. The Victorian government recognised the importance of these principles and the effect of the natural environment on our life and enacted the Flora and Fauna Guarantee Act in 1988 (Flora and Fauna Guarantee Act 1988). This legislation provides a way to protect and manage the conservation of threatened species and communities and for the management of potentially threatening processes. This key piece of legislation along with other legislative actions at national level (Environment Protection and Biodiversity Conservation Act 1999), have been used in the Biodiversity 2037 plan to march towards a “better” Victoria, where the net loss of biodiversity is halted and even reversed. The Australian Government APS200 (Australia. Dept. of Industry, Innovation, Science, Research and Tertiary Education [DIISRTE], 2012) [APS200] guide to using science in policy development in the public space recommends a systematic approach to incorporating science in policy design and evaluation. This policy provides guides to decision making frameworks, environmental accounting systems, recommends forming of collaborative community groups to include Aboriginal values and traditional ecological knowledge, a whole-of-government approach to implementation, as well regular forums and progress reporting structures to keep track of everything. The policy sets 2 overarching goals to ensure that ● Victorians value nature ● Victoria’s natural environment is healthy. Accepting the general wisdom of the overarching goals of Biodiversity 2037 is easy, but it is not clear if the targets being set have adequate scientific backing. In addition, some strategic decisions taken do not explain their rationale and refer to no scientific studies or evidence as to their merit. The details of the tools used to evaluate the process and collect evidence of progress are also not transparent. With each stage of the policy development in the APS200 guide, specific guidelines and strategies are suggested and this is the guide which I have referred to when analysing this policy document. The phases Anticipation, Formulation, Consultation, Adoption and Evaluation are used and referred to in the context and manner that they are explained in the APS200 guide. The next section details some of these key failings to follow a science informed policy. The “Strategies” section suggests how these shortcomings may be overcome in a future revision of this policy. Finally, the “Conclusion” wraps up the review with a reiteration of the take-aways. Assessment Biodiversity 2037 follows some of the recommendations outlined in APS200 Project and makes a number of references to scientific evidence delivered via government reports and investigations and peer reviewed journals, all of them referred into a substantial 32 page document, Supporting Technical Supplements (that serves as specific reference as well as general inspirational reference), listing more than 200 items. In the anticipation phase, evidence has been used effectively to communicate the urgency of the issue (references to lost species numbers, lost vegetation coverage, economic and health benefits of the natural environment to humans). However, there are missing gaps. Loss of species numbers is one line of evidence, but it is raw data. While it does indicate a worrying trend, additional lines of evidence to show specific examples of the impact of this loss, and perhaps cascading effects up and down the food chain and the interconnected ecosystem would have made a more compelling case. Moving up the pyramid in the DIKW model as explained by Nativi et al (2019) could have provided stronger direction to policy. A significant gap appears in the formulation phase, when analysing the evidence presented with respect to the goals set. Targets for some goals appear to have been set without adequate indication of which piece of research indicates the choice of those numbers. For example, how many Victorians act to protect nature now and is shooting for 5 million Victorians acting to protect nature by 2037 an adequate goal ? This same goal also suffers lack of evidential backing in the evaluation phase, as it is not clear how to measure this action of protecting nature. For example, a representative assessment including surveys or protected area employment and tourist center statistics may have given more clarity here. Similarly, in the evaluation phase, when setting the goals for a healthy natural environment, the policy document appears to pull numbers out of a hat when suggesting that 4 million hectares be free of pest herbivores, or that 1.5 million hectares be free of pest predators in priority locations. Once again, both quantities and quality of evidence pointing to the current numbers of these pests in specific locations, why they are determined to be a priority, and why that many hectares is a worthy goal is missing. The qualitative issues continue in the evaluation phase with no insight into the method of using “Change in Suitable Habitat” (CSH) to evaluate species net gain. It is not clear how the CSH model is created for each species, if it is peer reviewed, if it was compared against other approaches to estimate net gain. These points are all detailed with specific pointers to the location in the policy document, specific evidence used, and specific issue noted in Table 1. Table 1: A summary of statements from the policy document and analysis of evidence used to support them Strategies When studying this policy, evaluating goals, targets, enabling actions and planning guidelines in the light of being evidence informed was not easy. The Biodiversity 2037 policy tackles a very complex, and to some extent, emotional problem. Asking human communities to trade off potential economic and social improvements in their life, to save a few species of bird or small mammals that they rarely see, could be a tough ask. However, if asked to make this same trade off for bigger effects like the quality of air they breathe or the soil they grow their crops in, the answer might be different. Explaining the cascading effects of making the right choices and thus setting very broad goals is where the policy starts. Perhaps this is exactly where to start. To paraphrase Likens et al (2010), the ideological, political and social motivations play as big a role in policy success as the scientific evidence that it is supposed to based on. The relevance and urgency of this policy cannot be overstated. However, it fails to deliver the impact needed. In fact, the Victorian Auditor-General's Office, 2021 audited DELWP on the status of their progress in halting biodiversity decline and hence the effectiveness of this policy in supporting that goal and found that 4 years after the policy was adopted, DELWP has not succeeded in demonstrating improvement in any of the goals stated in the policy document. A big part of this failure stems from lack of key performance indicators and reporting. This lack of direction can relate back directly to the poor evidence integration, as analysed above, thus leading to poor policy construction. Table 2 below outlines 4 specific weaknesses found in the evidence integration of this policy document. Following the strategies presented in the APS200 guide, a short term and long term strategy is suggested to address each weakness. The overarching need at this time is for the government to commission further studies, long and short term research on the interconnectedness of species, use more peer reviewed scientific indicators, and design an extensive whole-of-system reporting structure that captures key performance indicators effectively. Table 2 : Short Term and Long Term strategies presented for identified weaknesses in evidence integration. Conclusion This whitepaper provides an overview of the motivations and overarching goals of the Biodiversity 2037 policy, followed by an analysis of the quality, quantity and transparency of the evidence used by the policy to give this direction. The policy suffers from a lack of specific direction when it comes to aspiring to certain improvement numbers or measuring them. Numbers are not justified with scientific backing and the current state of the environment is not captured with any specific numbers. It is hard to judge progress or improvement vs decline in such a scenario. The government should invest in more fit-for-purpose research, systematic reviews of current research, and peer reviewed and approved models of species estimation. In addition, deeper analysis of synthesised evidence should be used to sharpen the performance metrics and capture progress with extensive and precise reporting.