-----Original Message----From: Meredith & David Parker (personal contact details deleted) Sent: Saturday, 16 January 2010 9:00 AM To: Irving, Jason (DEH); Tyne, Ted (PIRSA) Cc: admin@arkaroola.com.au Subject: Comments on proposed development plan for the Flinders Ranges. Dear Dr Ted Tyne and Mr Jason Irving re Seeking a Balance - Conservation and resource use in the Northern Flinders Ranges I am writing to express my concerns about the document Seeking a Balance, the rezoning project methodology, the Proposed Management Zones for the northeastern region of the Northern Flinders Ranges as indicated in the document Seeking a Balance, and in particular, the possibility of mining in the Arkaroola Wilderness Sanctuary. Like our current global environment issue, carbon-based energy dependency and climate change, short term economic gain can have long term environmental consequences. I took my first Ridgetop Tour in the Arkaroola Wilderness Sanctuary in 1977, and experienced the sanctuary's unique environmental, biodiversity, wilderness, landscape, geoscientific, and tourism features. I am totally opposed to mining in any form on the Arkaroola Wilderness Sanctuary, because it will have a dentrimental impact on its scenic landscape, environmental uniqueness, wilderness nature and long term tourist potential, and believe that the process used to identify the proposed management zones was flawed. On a recent trek along the Kakoda Trail in the Owen Stanley ranges in Papua New Guinea, I experienced the huge visual impact of a mineral exploration access track that had been cut along an adjacent mountain range. I would hate to see such supposedly "low impact" infrastructure being approved for our Flinders Ranges, and in particular Arkaroola Wilderness Sanctuary. As stated in the document Seeking a Balance, the Flinders Ranges has some of the most recognisable and loved landscapes in South Australia, with outstanding environmental, cultural, and tourism values. Much of the Northern Flinders Ranges lies within the Development Plan's Environmental Class A Zone, the prime objectives of which are to conserve the natural character and environment of the area and to protect the landscape from damage by mining operations and exploring for new resources. The proposed management zones 2A, 2B and 3 permit to some level damage by mining operations and mineral exploration, and therefore runs counter to the primary objective of environmental Class A Zone. The the document Seeking a Balance is beautiful to look at, and uses a number of images that represent the natural beauty of the region, but it is deceptive and short on detail or evidence to support the rezoning proposal. For instance it does not have a map of Environmental Class A Zone, and has images of landscape, such as Sillers Lookout, that are not protected from mining activities within the plan. The rezoning project conducted by DEH and PIRSA commissioned an independent landscape assessment by Scenic Solutions. This assessment involved public surveys to establish and rank landscape values based on images of a range of landscapes through the Northern Flinders Ranges. It is claimed by Scenic Solutions that although scenic beauty is a subjective quality in that it involves human likes and dislikes, it can be measured objectively and rigorously, and that the results can be used to predict the likely scenic quality rating of a given scene, and are replicable by anyone applying the same methodology. I agree that scenic beauty is a subjective quality, but it cannot be measured objectively and rigorously. Of course the subjective responses can be measured objectively, but the results are only a subjective measure of scenic beauty, and involves human likes and dislikes. The public survey conducted by Scenic Solutions will only provide a subjective measure of the scenic beauty of the targeted landscape, and will be tainted by the respondants cultural and ethnic background, living environment and landscape experiences. Given that many actual and potential tourists will have come from different cultural and ethnic background, living environment and landscape experiences, their appreciation of the Flinders Ranges landscape would be quite different to those measured by Scenic Solutions' landscape assessment. It would appear from the document Seeking a Balance that the rezoning was based on environmental, biodiversity, wilderness, landscape, geoscientific, tourism, prospectivity values. However there are no details on how these values are measured and combined to derive the proposed zones, and given the flawed nature of the landscape study methodology, it would appear that the zoning is also flawed. I therefore request that you take a more cautious approach to rezoning in the Flinders Ranges, strengthen rather than weaken the the existing Class A Environmental, and withdraw the Management Zoning proposals mooted in Seeking a Balance. Yours sincerely, David Parker