Flawed Gippsland Lakes Strategy

The Draft Gippsland Lakes Environmental Strategy prepared by the Gippsland Lakes Ministerial Advisory Committee is flawed as it was not based on the international standard for risk management – ISO 31000.

The Gippsland Lakes are Ramsar listed wetlands of international significance. If you’re developing a strategy, policies or a system to manage and mitigate environmental impacts of such an important ecosystem, it must be in line with world’s best practice, based on a reputable international model of risk management.

The strategy does not outline how environmental impacts were identified, assessed and what mitigation strategies will be implemented according to an order of risk heirachy. There is a list of wish-wash aspirational objectives that do not indicate who is responsible for what and have no completion dates. There is no monitoring, auditing or certification of the process by a third party independent body. This clearly goes against the fundamentals of process integrity and continual improvement.

The strategy is only a rehash of existing documentation dumbed down to devaluate signficant environmental issues. For example, the only place you’ll find the word mercury in the entire document is in the reference page. G Fabris and other scientists back in 1999 identified the rising levels of mercury in bream found in the lakes yet there is no mention of the associated health risks or mitigation programs to tackle mercury washing down from disused mines upstream in the catchment. Furthermore there is no mention of the new dolphin species Tursiops australis (the Burrunan dolphin) or that mercury poisoning killed 9 of them in 2008-2009. There is only one paragraph on dredging of the artificial entrance with no mention of the severe impacts caused by the influx of salt water into the lakes. There is no mention of the european shore crab, an exotic invasive species that has entered the lakes and has decimated native species of sandworm and freshwater bivalves.

This entirely flawed process can only come down to the fact that the committee is stacked with members of the business community such as land developers, tourism operators and the ports manager who have commercial interests and steer away from the complex issues of the lakes and the science behind sound environmental management.