Continuous Improvement v Arrested Development

Having managed to send, within the specified time-frame, comments on the EPA’s draft Protection of the Environment Operations (General) Amendment
(Native Forest Bio-material) Regulation (7.3Mb), aka; ground rules for my next probable arrest, it was interesting to receive a receipt from an apparently new “Continuous Improvement Unit” in the EPA.

While trusting the CIU is a step up from the usual “NMT’, the ‘needs more training’ unit that dominates FCNSW for example and there is certainly much room for improvement, perhaps more important would be a ‘get your act together’ unit.

For example and while the comments were generally supportive of the proposal under a different management system, I included the following comparison of maps showing ‘forests predisposed to decline’ (Jurskis and Wamsley, 2012).

The top map shows areas north of Wallaga Lake in the Batemans Bay region and the one underneath south of Wallaga in the Eden region.


Immediately apparent is lack of red or forests with ‘high predisposition’ in the Southern region that, leaving aside the differing classification system, could and surely must be a polygon tagging error. Coincidentally these maps also include the location of the proposed $40m highway realignment through Dignams Creek, where the redline turns blue on the Batemans Bay map.

Exactly what the CIU will make of this is anyone’s guess although I did suggest, given there’s no evidence to demonstrate otherwise, that koalas may now be functionally extinct in the SEC bio-region.

Like the argument that the highway realignment requires a Species Impact Statement, taking this step raises the bar a bit with NSW gov’s koala recovery plans, as the ball goes into the Federal Government’s court.

Of course I too have minor obligations with the Fed’s and the first step – the online shop – seems to be operative so it’s back to the local arrested development, the fence.





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