We note the review is in its early stages and no proposed amendments have yet been circulated. We welcome the opportunity to provide high-level submissions at this stage as to principles which ought to guide the content of prescriptions in the new Code, particularly those for species listed under the Flora and Fauna Guarantee Act 1988 (Vic) (the FFG Act). Many points made here were also discussed in Environmental Justice Australia’s meeting with the Code Review Team in May 2022.
In this submission we outline:
- The required standard of protection to which the prescriptions must be directed;
- What should be considered in order to determine prescriptions that meet the required standard; and
- What outcome, on the ground, must the prescriptions achieve.