-----Original Message----From: Katherine Moseby (personal contact details deleted)
Sent: Monday, 7 December 2009 8:39 PM
To: Irving, Jason (DEH)
Cc: Tyne, Ted (PIRSA)
Subject: seeking a balance comments
Hi Jason
I read with interest the "seeking a balance" document produced by DEH
and PIRSA trying to address the balance between mining and
conservation. It is great to see that the issue of what areas are,
and are not appropriate for mining and exploration activities is
receiving attention. I have a few comments and questions that I was
hoping you could answer.
1) The document does not seem to state a percentage of land systems
or habitats that should be protected from exploration and mining
activity. The CARRS target of 15 or 20% appears to apply for
protected areas but these are not necessarily exempt from mining and
exploration. Shouldn't a target also be adopted as a % of each IBRA
bioregion protected from development? Did DEH and PIRSA consider what
percentage (or minimum %) of the northern flinders land system should
be fully protected?
2) There is very little detail in the document outlining how the
values were determined ie biodiversity values, landscape quality etc.
If you simply used biosurvey database info then this method is flawed
due to lack of data. Was connectivity used at all? Or proximity to
currently protected areas? Current wilderness values? I would like to
know the methods used in this document and what published research
supports it. At first glance it appears that yellow footed rock
wallaby habitat formed the basis of much of the biodiversity scaling.
I would also be interested to know how the mineral prospectivity was
determined.
3)The NRM board recently produced a SEB document outlining priority
areas for new conservation activities under the SEB legislation. This
was based on a number of factors including the percentage of each
bioregion currently conserved, connectiveness, proximity to small
conservation reserves, threatened species and communities currently
not protected or poorly protected in parks etc. Was this document
used or looked at when producing "seeking a balance"?
4) It seems a bit like this document is being "rushed through",
perhaps due to the current issues with Arkaroola Sanctuary? Is the
aim to repeat this for the whole state to ensure high conservation
assets are fully protected from development? If so then it is
important that this initial document gets it right so it can be a
blueprint for future work. Is there agreement between DEH and PIRSA
that some areas should not be mined or explored? If so, on what basis
should these areas be chosen? I say this in light of recent
exploration activity in Yumbarra and Yellabinna Reserves,
particularly in areas where nationally threatened species were
present. At present there are no areas in those reserves that are
identified as "no go"
zones despite the presence of threatened species in limited areas of
the Reserves.
5) The importance of wilderness areas ie areas remote from tracks and
infrastructure is extremely important for protection from weeds,
feral animals that use roads (e.g. foxes) and fragmentation issues
(edge effects etc). Areas that currently have limited access should
be acknowledged at potential refugia areas and access should remain
limited. Unfortunately, intensive exploration activity often opens up
new areas that are then accessed by 4wd recreation vehicles,
introduced species etc. Once opened up it is almost impossible to
fully close areas again. I think the value of wilderness areas as
future tourist attractions as well as biodiversity hot spots is also
misunderstood and underestimated. Mining often leaves a long term
legacy of waste and infrastructure, it is unlikely that anyone would
wish to walk the Tasmanian overland track if it continually crossed
roads
and afforded view after view of recent or old mining activity.
What
value
was given to wilderness areas in this report?
6) Access zone 2b appears almost identical to Access zone 3 and seems
to afford no additional protection. Stating that proposals will be
assessed on a case by case basis is a bit of a cop out as this is
what happens anyway.
What is the exact difference between the zone 2b and 3?
7) Some of the protected areas are very small, some only a few square
km.
How was the minimum size of protected areas determined and what
buffer zone was allocated to them? It may still be possible to effect
a small patch of threatened slender bell fruit without physically
impacting it ie was any consideration given to water flow and
potential contaminants flowing downstream? Or prevailing wind etc.
Thanks for the opportunity to comment on this document. I look
forward to your reply. Regards
Katherine Moseby
(personal contact details deleted)