The Tasmanian Conservation Trust (TCT) is concerned that while no action has been taken for years regarding a WMP for the South Esk River (the report ‘Environmental Flows for the South Esk Catchment’ was completed in October 2007), the ‘Draft South Esk River Catchment Water Management Plan’ (South Esk Plan) has been developed in great haste, in absence of key data or recent data, based on flawed methodology and has involved virtually no consultation with non-consumptive users. Many of the relevant findings and recommendations of the September 2009 National Water Commission report ‘Australian Water Reform 2009: Second biennial assessment of progress in implementation of the National Water Initiative’ (2009 National Water Commission report) have been largely ignored.
It appears to the TCT the South Esk Plan has been rushed in order to meet timeframes for State Government’s proposed Midlands Water Scheme and the resulting plan is of very low quality.
In broad terms the TCT strongly supports the management plan and the FSC application. We have a series of comments but most of these are minor in nature and hopefully can be used to improve this excellent management plan.
The Tasmanian Conservation Trust believes it is premature and inappropriate to seek public input regarding the boundaries for the proposed Bay of Fires national park as Aboriginal concerns and existing management problems should have been dealt with first. The TCT does not oppose a national park and still sees it as one option for the area.
The TCT strongly encourages the State Government to put on hold its plans to develop a Bay of Fires national park and re-start negotiations with the Tasmanian Aboriginal community to determine if they want part or all of the Bay of Fires area transferred to their ownership and whether this might be consistent with the creation of a national park. The Government should also ask the Aboriginal community what management arrangements they would consider.
The Tasmanian Conservation Trust supports the recommendations made in the ‘Draft Integrated Assessment Report – Lauderdale Quay Development Proposal’ (Draft Report). The TCT believes the recommendations incorporate the most significant arguments put forward by the opponents of the proposal and provide a compelling case for the proposal not to proceed.
Apart from incorporating the additional recommendation suggested below, the TCT urges the Tasmanian Planning Commission to prepare a final report to the Tasmanian Premier which includes, unaltered, all of the recommendations from the draft report. Furthermore, the Commission should recommend in its final report that the Lauderdale Quay Development Proposal should not proceed.
The Tasmanian Conservation Trust believes that the above project, based on the information provided in the proponent’s referral documents, will have very significant and unacceptable impacts on several threatened species listed on the schedules of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and the proposed mitigation and off-set strategies for these species are unacceptable. The project will also have impacts on an area nominated for emergency listing as a National Heritage Place under the EPBC Act. We therefore recommend the application should be refused as totally unaceptable persuant to section 74B(1)(b) of the EPBC Act.
The Tasmanian Conservation Trust made a submission to the process of developing the 2010-2011 State Budget. Areas we provided advice on included:
The Tasmanian Conservation Trust opposes the ‘Draft Planning Directive No.2: Underground and Minor Aboveground Infrastruure’ (Draft Directive) as it has the potential to cause wide spread and serious environmental damage, differs from what the State Government proposed, and will cause confusion and uncertainty in the rural communities who are meant to benefit from it.
The Draft Directive clearly restricts third party appeals in relation to a range of infrastrucure uses. The TCT opposes further restrictions to third party appeals.
While the Draft Directive does not clearly state it, the Background Paper makes it perfectly clear that the Draft Directive will ‘exempt’ a range of infr. There are a number of very important differences between the exceptions proposed in the Draft Directive and those outlined in the template such as excepting minor road works that involves vegetation clearing or take place on heritage sites. This differs from what was originally proposed by the Minister and what we expected.
As well as resticting third party appeals, the Draft Directive excludes councils being involved in an advisory capacity or applying conditions. This will lead to a range of negative envrionmental outcomes.
The Tasmanian Conservation Trust believes that the above project will have very significant and unacceptable impacts on several threatened species listed on the schedules of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), the proposed mitigation and off-set strategies are inappropriate for such highly threatened species and the application should be refused as totally unaceptable persuant to section 74B(1)(b) of the EPBC Act.
The proposed operation would involve mining in the Dans Hill Conservation Area, which was created in 2003 specifically to conserve populations of Tetratheca gunnii and other threatened plant species. The Tetratheca gunnii Recovery Plan (page 9) states that land near Barnes Hill was purchased in 1999 to protect Tetratheca gunnii populations, with Australian Government funding through the Private Forest Reserve Program (PFRP), with the intention of including this land in the CAR reserve system. The TCT claims this acquired land is now part of the Dans Hill Conservation Area and part or all of it is within the proposed mining area.
While contractual arrangements in place at the time the land was purchased remain unclear (the TCT is investigating this situation), we believe the Tasmanian Government are obliged to ensure purchased areas are conserved in perpetuity.
We urge the Australian Government to investigate the purchase of land under that PFRP, which was included in the Dans Hill Conservation Area, and ensure the Tasmanian Government is strictly adhering to PFRP funding conditions and requirements under the National Reserve System Strategy 2009-2030 and previous versions.
If this proposal is given approval, the TCT suggests that the proponent should be required to repay to the Australian Government the purchase price of the land.
This is a submission on the review of management of the Tasmanian Scalefish Fishery. Key species are in decline and the proposed management changes are unlikely to solve that or other problems associated with this fishery.
Submitted to Dept. of Primary Industries and Water on 4.6.09
From the documents available on the Department of Primary Industries and Water (DPIW) web site it is clear that this scheme is at an early stage of development and as such the TCT will only provide brief comments in this submission. We will make a fuller submission when public comment is sought on the final preferred option.
Submission on the Review of the Biodiversity Provisions of the Forest Practices Code
Submitted to Forest Practices Authority on 2.6.09
Australia's Biodiversity Conservation Strategy fails to make any clear commitments on behalf of the Australian or state and territory government. The stated priorities, objectives, actions and resultsare generally broad or vague and there are no performance criteria to indicate what outcomes are expected on the short or medium term. The Draft Strategy therefore has limited capacity to assist governments and other stakeholders in setting strategic directions for biodiversity conservation programs. The TCT has made a submission outlining these and other problems with the strategy.
Submitted to National Biodiversity Response on 29.5.09
The Tasmanian Conservation Trust is strongly opposed to the Proposed Lauderdale Quay Development (the development) and urges the Resource Planning and Development Commission (RPDC) to recommend to the State Government that it not be given approval to proceed.
The TCT has a very good knowledge of the operations and funding of the FEP and as an independent conservation organisation we are in a good position to assess its effectiveness and efficiency. We conclude that the FEP is being both effective – within the physical, technological and financial limitations that they operate – and efficient with the funding it is provided by both the Tasmanian and Australian Governments.
As a co-author of the original nomination the TCT is pleased to see that the extraordinarily long process of assessing this highly valuable community is close to being completed.
The TCT realises there may be a number of other feral species present in the World Heritage Area (WHA) that have a higher priority for control or eradication than fallow deer (Dama dama) and superb lyrebird (Menura novaehollandiae) and that resources for management of introduced species may be very limited. However, what we recommend in this paper is not costly and should not compete with or limit efforts to address other species. The TCT will be providing additional correspondence to the WHACC regarding management of other invasive species in the WHA and we will do what we can to increase the overall budget for this important area of WHA management.
The Tasmanian Conservation Trust believes that the above project is a controlled action under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) on the basis that there is a high probability of significant impact on matters of national environmental significance, in particular listed threatened and migratory species.
Photo at top of this column by John Grist