This submission responds to the draft proposal to list adverse fire regimes as a key threatening process under the national EPBC Act.
The Invasive Species Council and Bush Heritage Australia welcome the advice by the Threatened Species Scientific Committee (TSSC) to finally list ‘Fire regimes that cause biodiversity decline’ (adverse fire regimes) as a key threatening process (KTP). We commend the TSSC on the quality and comprehensiveness of the KTP assessment.
We strongly endorse the listing of this KTP – not only because it clearly meets the criteria under the EPBC Act and is one of Australia’s major environmental threats, but because it interacts strongly with other threats, including invasive species such as invasive pasture grasses, predators and ungulates and climate change. Our organisations also have a strong interest in strengthening the threat abatement system, including through comprehensive listing of KTPs. As the first potential listing of a KTP for many years, the adverse fire regimes KTP provides an opportunity to implement an exemplary planning process, and to potentially link with regional planning processes proposed in the Samuel review of the EPBC Act.
In this submission, we address the question of whether there should be a national threat abatement plan (TAP) to address the threat of adverse fire regimes.
Given the national significance and complexities of this threat, there can surely be no doubt that some national plan or strategy to abate this KTP is warranted, noting:
● The scale of the threat is vast, impacting most terrestrial ecosystems.
● The intensity of the threat is extremely high, impacting hundreds of threatened species and ecological communities.
● The needs and opportunities for national coordination and leadership are also very high given the evident gaps in current abatement efforts and the shared challenges across jurisdictions.