Dr Ted Tyne
Director, Mineral Resources
Primary Industries and Resources SA
GPO Box 1671
Adelaide SA 5001
Margaret Sprigg
PMB 106
Port Augusta, SA 5710
29 January 2010
Jason Irving
Manager Policy and Planning
Department for Environment and Heritage
GPO Box 1047
Adelaide SA 5001
Dear Dr Tyne & Mr Irving
“SEEKING A BALANCE — Conservation and resource
use in the Northern Flinders Ranges”
OVERVIEW:
It was with real enthusiasm as one of the owners of the Arkaroola Wilderness Sanctuary that I looked
forward to the release of Seeking a Balance which attempts to scientifically weigh and evaluate the
various values of this region and in particular those of my home.
I don’t doubt that this document is the result of an honest effort to find a solution to the dilemma of the
competing and conflicting interests of mining and conservation in the NE Flinders Ranges. However,
after reading copies of many submissions from members of the public, I am more firmly than ever
confirmed of the opinion that mining and conservation cannot co-exist in this fragile environment.
Additionally, it has been very pleasing to note the number of professionals, particularly geologists who
know this country well, who have called for a moratorium on mining within the Sanctuary.
I am not at all against mining, however, as one senior Australian senator states, ‘Some places are just too
precious to mine, and Arkaroola is definitely one of those.’
South Australia is a State that has vast and exceedingly rich uranium resources. It has the biggest
uranium mine in the world being developed at Olympic Dam and the world’s richest deposit at
Arkaroola’s neighbouring Beverley, and these are still early days in the search for uranium.
Arkaroola has exceptional landscape, ecological, heritage and wilderness values created courtesy of its
amazing geology. Its educational, scientific and research values are widely documented and well
known. But the risks associated with mining the centre of Arkaroola pose an enormous threat and
unacceptable risk to the environment, while Arkaroola’s responsible, sustainable ecotourism would be
seriously degraded, impacting on community economic and social values.
The conflict between mining or environmental preservation as I see it, comes down to the simple
question of the community valuing more a questionable short-term gain from destructive mineral
exploitation, or preferring the ongoing and sustainable benefits from retaining this extraordinarily
valuable and barely (European) modified mountain environment.
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A recent PIRSA brochure advertising its Geoscientist Assistance Program… to maintain, develop and
diversify the skills of geosciences graduates and experienced geologists, displays the Arkaroola Ridgetop
area, signifying the well known, long existing link between Arkaroola and geological training in this
State. Arkaroola and the Mt Painter Inlier are far more important as a complete intact package for
geoscience teaching and research than a mine that provides only short term economic benefit.
I am deeply concerned that a document professing to search for balance between conservation and
resource use, actually proposes zoning for differing levels of mining and exploration access. And,
unfortunately this document appears deeply biased toward mineral exploitation within the Ridgetop
area of the Arkaroola Wilderness Sanctuary. It also sets the scene for Marathon Resources (with its
appalling exploration record), or some successor, the opportunity to apply to access and mine almost all
of the area currently under this EL – bar a small area around Split Rock.
I am also extremely concerned about the comment towards the end of Seeking a Balance: ‘As new
information comes to light over the years ahead…….the management zones will be further refined to
ensure that the unique environmental and landscape values of the region are protected’. Despite the
encouraging sound of this paragraph from a protection point of view, I am concerned about the ability
for zone boundaries to be changed. This gives absolutely no assurance to future directions of zoning for
either the mining industry, or to Arkaroola from a conservation and/or ecotourism perspective.
For over four decades Arkaroola has carried out the conservation and protection work of a National Park
at NO cost to either the Government or the Taxpayer in a geologically and environmentally special area
unlike anything under the Australian National Parks system. However, these proposed zones, far from
offering any sort of continuity of that protection for the unique values of the region, appear to indicate
that the SA Government puts a low priority on the environment, biodiversity and scenic values of this
amazing area; and on the values and principles that my family have worked so hard to forge and uphold
since 1968.
COMMENTS ON SEEKING A BALANCE:
Cultural and Tourism Values Of The Northern Flinders Ranges:
It seems difficult to reconcile that while Cultural Values have been given a brief two-sentence comment,
there is no map indicating known areas of Adnyamathanha cultural importance. Somewhat similarly,
and despite the statement that tourism is of high importance, it also appears to have been over-looked.
For instance, the Arkaroola Wilderness Sanctuary’s Ridgetop Tour’s highlight, Sillers Lookout, a wellknown and well-recognised South Australian Tourism Icon and landmark, lies in Zone 3: Standard
exploration and mining access. It appears that scant lip-service only has been paid to these two values.
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Comparative Maps & Photographs:
Seeking a Balance is a particularly attractive looking brochure, and its pictures appear to support the
tenet that this initiative is about landscape, wilderness and tourism, though the picture of Sillers
Lookout is probably about 20 years old (that type of vehicle is no longer used); the photograph of the
Mawson Plateau was worrying until I realised it was back to front, and what is the purpose of a picture
of a vehicle near a stone tank in the Vulkathunha-Gammon Range National Park when this is already a
protected area?
The final Zoning proposal map is apparently derived from the three preceding ones, yet only applies to
a subset of the others, i.e. the NE corner of the Northern Flinders Ranges (NFR). This begs the question,
is it reasonable to take scant data for the whole region yet only ‘cherry-pick’ one portion?
Despite listing seven Value categories, maps are only provided for three, though Geoscience (teaching
and research) which is already encouraged, and sponsored by Arkaroola, is noted as being ‘conditional’
across all the proposed zones.
The lack of provision or availability of mapping detail and data sets for the maps is troubling. That this
data was not available was a complaint by a large number of responders including myself, who wished
to understand the background information behind the maps provided, and the methodology used.
The comparisons of Landscape Quality and Biodiversity Values with Mineral Prospectivity, Mineral
Occurrences and Mines, is not reasonable. i.e. comparing known biodiversity hotspots (e.g. actual
sightings or collection points) with Mineral Prospectivity (potentially mineralized areas) is not valid. For
a level playing field Biodiversity Prospectivity and Mineral Prospectivity should have been compared.
The methodology used is therefore highly biased toward minerals and mining.
Biodiversity should be based on suitable and available habitat, NOT a dot on a map where a species has
been found. If species habitat (biodiversity prospectivity) had been used then it is likely the second map
would much more likely resemble the third. This is particularly so as the higher biodiversity values
reflect biosurvey sampling while the low values reflect lack of sampling, not necessarily lack of species.
Without long term and systematic sampling it is impossible to make comparisons between species
collected and what ‘unknowns’ are actually out there, living in the landscape. Instead, extrapolation
from existing vegetation/habitat type would better give an indication of biodiversity prospectivity
compared with mineral prospectivity.
Landscape Quality:
I am not at all confident about the reliability of extrapolations from data gained from the on-line survey.
In the Outback many invitees were unable to participate due to difficulties with internet access speeds
and downloading large amounts of data. Only two people from Arkaroola were able to access it, and
three other colleagues from elsewhere were unable to complete the survey. It is also believed that
personal perceptions are very subjective and would have heavily impacted on the results.
Advice from other participants in the photographic survey indicated they thought the process was
highly flawed, with variable photographic quality, rather than variable landscape quality. The negative
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impact of drought, of dryness and aridity also meant that the northern Flinders were barren compared
to the southern areas at the time. It is very likely this would have had an inequitable impact on the
rating of the photographs and in particularly a very negative affect on the northern Flinders area; this is
substantiated as a finding of the survey in that a lack of vegetation (i.e. drought) in pictures received
lower ratings from responders.
If the results of this survey had been used in the National Landscapes initiative, the Flinders Ranges
would never have been accepted as an iconic landscape with Arkaroola an integral part of its northern
reaches. Yet the iconic photographic vistas of the Ridgetop area: Split Rock, Freeling Heights and Sillers
Lookout have been attractors for 25-30,000 visitors per annum to Arkaroola, it should be reasonable to
presume that these ‘satisfied customers’ value these landscapes, and that the Tourism Dollars that they
spend in the region are important economically and socially - as well as helping fund Arkaroola’s private
conservation programs (e.g. plant and animal pest control, biosurvey work, etc).
It is interesting and perhaps telling that Dr Andrew Lothian (Scenic Solutions, 2009) felt impelled to
remark in his conclusion that surveyed comments indicated, ‘the threshold for permitting mining “in the
National or State interest” must be set very high. With better placed alternative resources available
(which appear to meet the third development control principle) it would seem difficult to sustain a cause
for mining in the Mt Painter area.’
Biodiversity Values:
Even without knowledge of how the mapping and ranking of the data was derived and what species
were accounted for, this evaluation does not appear reasonable (to someone who has lived in the area
for a long time), but it is not possible to argue the case due to lack of information provided. As habitat
and species range were apparently not taken into account, these values are flawed. There are
threatened endemic species, such as the spidery wattle, Acacia araneosa , whose range is only partly
protected. This tree is only found on 10 sq km of Arkaroola and the Vulkathunha-Gammon Range
National Park (half on each). It is currently under threat across ALL of its range, due to drought, yet
most of the area where it grows on Arkaroola is in the Zone 3: Standard mining and exploration access.
This seems extremely short-sighted for a DEH-originating document.
Similarly it is confounding that DEH would support and produce a document that flies in the face of its
own NatureLinks, and No Species Loss policies. That instead of accepting the sanctuary-wide
connectivity of the various zones of the Arkaroola Wilderness Sanctuary that are already part of DEH’s
east to west Northern Flinders Range NatureLink zone (of Public, Private and Aboriginal lands), the
department has done an about face, and fragments the existing intact sanctuary into small blobs that
would make habitat management almost insurmountable and threaten species viability. Why the very
department touting the need for connectivity of biozones would encourage fragmentation is
unconscionable.
Much has been said about the habitat of the yellow-footed rock-wallaby being fragmented and lacking
in bio-corridors between gene pools, however this is not the only species affected. The habitat of the
short-tailed grasswren (Amytornis merrotysi) frequents the ‘spinifex’ and woodland area north of Split
Rock but its habitat occurs from south of Mt Painter to past Sillers Rock, so its habitat crosses all
proposed zones, from 1-3. Much of this area also coincides with the wattle, Acacia confluens, though
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common across the Ridgetop area, does not grow beyond it. Why is there not a greater level of
protection for these species?
Similarly, there are ‘minute’ buffer zones around geological monuments that are useless for species and
habitat management, and other apparently absurd protected regimes such as East Painter Gorge which
has a small level of protection (Zone 2B) for its northern side yet its southern side is open for Zone 3:
Standard mining and exploration access. How anyone could imagine it is possible to viably protect
yellow-footed rock-wallabies on one side of a narrow gorge and allow for a possible transportation
corridor on the other is ridiculous. I hope that in this case, Elery Hamilton-Smith’s theory will prove
incorrect; in his review of Worboy’s book (2001) he says, ‘Less and less sensitivity to environmental
issues is being demonstrated; commercial and other political interest override environmental
considerations.’ I certainly hope that the Government’s final results to Seeking a Balance will show this
is not so.
Interestingly, this is the same Dr Graeme Worboys (connectivity conservation expert) who was brought
to Arkaroola to assist with the Northern Flinders Ranges Project by DEH in early 2009. He made it clear
that as there has been very little biological survey work on Arkaroola, the absence of a data from a point
does not meant there is nothing there. It is for that reason it is imperative that adequate, connected
potential habitat is preserved in order to maintain species viability, particularly in this region, barely
modified by European influence, and where little is known of what species might be present.
Arkaroola by its own choice pursued and was issued with a dispensation decades ago from the Pastoral
Board to have a ‘Nil Stocking Rate’. In the Arkaroola Pastoral Lease Assessment Report (2000) the land
condition of the Ridgetop area was consistently scored at the maximum rating of three: No Action
required, while the whole of the Arkaroola Wilderness Sanctuary received a 2.58 rating, the second
highest pastoral rating in the State of South Australia and greater than those of the National Parks (the
highest rate was gained by a pastoral property on the western plains of the State). Lack of weediness
was also noted. After all these years why would the State of SA risk losing these rare ‘wins’?
It is Arkaroola’s short pastoral history (scarcely three decades which impacted only on the southern
portion of the property), and long term lack of stock due to my parents management strategies, that
native plants are in excellent condition, considering more than a decade of drought. Additionally, there
has been little ingress of weeds which I believe would be unstoppable if mining was allowed, and
Arkaroola’s weed seed control program was discontinued. Why was DEH’s invited experts’ opinion on
the necessity of conservation connectivity completely over-ruled?
Mineral Prospectivity, Mineral Occurrence and Mines:
Rightly, or wrongly, this map appears to be the key to the document’s purpose. This map
overwhelmingly gives the uninitiated the feeling that to not mine the Arkaroola and surrounding region
would be a crime. It certainly is far more colourful and attractive than the two insipid preceding maps!
However, again without knowledge of the different rankings of prospectivity, this map is not only
meaningless, but very open to misinterpretation. Mining, historically, is known to have been generally
unsuccessful, most were small ‘pick and shovel’ efforts, accessed by camel and/or donkey, mainly
speculative and most heart, and back-breaking failures. However, to look at this map, one could be
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forgiven for presuming that all the exploration and mining efforts of the country should be concentrated
within this small area.
The map has been poorly conceived such that it is impossible, at its low level of resolution, to interpret
the differences between the individual items of the Legend: i.e. Deposit, Diggings, Mine, Occurrence
and Prospect. On Arkaroola they so overlap it is not even possible to distinguish between a lowly
‘prospect’ and slightly more impressive ‘deposit’. Quite a number of people have advised me they
believe that this must have been intentional. Though I doubt this, the map certainly confuses more
than it enlightens.
More importantly, without supporting data and cross referencing, it is impossible to gain any
understanding of what type of minerals have been found where, and what the environmental
implications might be for their exploration, mining and extraction. Even more so in this case, than the
preceding maps, this does not assist in presenting a sound basis for major decision making processes
and eventual policy development.
I believe that there is much more value to be gained for South Australia by this area remaining intact
and free of mining. It should however, continue to still be available for low impact research and
education as originally perceived by Sir Douglas Mawson as ‘the world’s greatest outdoor geological
museum’ and later by my father, Reg Sprigg, as ‘Nature’s Laboratory’. Geological studies of this region
will assist the unlocking of Arkaroola’s secrets and those of the adjacent plains, hidden under the covers.
Zoning and Conditions:
Clear description of the various Proposed Access Zones for exploration and mining are less than
apparent.
In Access Zone 2 what would constitute high impact activities; i.e. what specifically would not be
allowed in these areas? It would have been better if this had been spelt out. What type of
infrastructure might be permitted in Zone 2a? Tracks, ventilation shafts or other? How would Zone 2a
mines be accessed? Haulage tracks cutting across the terrain? If this were the case, how would exotic
pests be kept out? What would happen to the vast amount of mullock from underground mining?;
where would it be stored? - nearby, or off sanctuary? What of the huge negative impacts on the
environment? and where would the water come from for mining and processing?, and what impacts on
the biota? It would have assisted greatly if these questions had been addressed in Seeking a Balance.
Zone 2b allows for “low impact activities” such as the construction of temporary access tracks with
stringent conditions and rehabilitation. However, exploration history in the Arkaroola Wilderness
Sanctuary particularly in the 1960’s and 70’s has clearly indicated this fragile landscape is extremely slow
to respond both naturally and to exploration rehabilitation. And reclamation does not equate to
rehabilitation. Even Marathon’s more modern efforts will require the right combination of rain events
etc. in order for recovery to occur and the impacts to fade.
If more high impact exploration by EL holder Marathon Resources is allowed to prove up their Mt Gee
deposit it will require further extensive drilling of this National Geological Monument. I certainly hope
that this area never earns the ‘swiss cheese’ label I have heard threatened. This is not the way to treat
such an amazing geological monument. What will happen with the proposed geological monument
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familiarly known as Wallace’s Reef in the Kingsmill Gorge area?; a barrier reef constructed by unknown
organisms to a height of 800 metres thick (the Great Barrier Reef is only 1/8 this) at the end of Snowball
Earth?
Proposed Management Zones:
Naturally we welcome the fact that the Mawson Plateau has been designated Zone 1: No access. But as
this area is naturally inaccessible to all but foot traffic this is hardly unexpected, and although previously
prospected, it has been found to be of scarce interest to the minerals exploration industry. I am also
aware that others have been diligently working for a long time towards having this declared off-limits
for mining.
Regarding the proposed management zones generally, I have been advised by Dr Tyne that these zones
do not extinguish the Class A Environmental guidelines of the Development Plan (consolidated 2003),
and that these still exist; i.e. the Proposed Zoning of Seeking a Balance simply overlay them. Yet these
proposed zones appear to be completely at odds with the guidelines. Part of the Class B Environmental
Zone has elevated protection (which I am certainly not arguing with), while a significant portion of the
Class A area is down-graded in value to be available for Standard mining and exploration access
(coincidentally most of the Marathon EL) region. We find this reversal of importance particularly
disturbing.
The proposed zones are completely at odds and incompatible with the Development Plan guidelines
which is of deep concern to me. The proposals of Seeking a Balance give absolutely no appearance of
increasing levels of protection for the Ridgetop area of Arkaroola, where so many of our visitors take
four wheel drive tours or flights. Yet this currently and historically is the most important focus of our
ecotourism business, and was zoned for protection by my parents with all general access tracks
peripheral to this region - bar the Ridgetop Track (the access track for Exoil in the 1960s).
Impacts from mining are likely to negatively impact on all facets of our sustainable ecotourism business
and conservation work in the Ridgetop and surrounding Class A Environmental Zone area. We have
been informed by many visitors that they would think twice about visiting the Arkaroola Wilderness
Sanctuary if it had a uranium mine at its heart. And as quite a number of overseas visitors equate
Arkaroola with Flinders Ranges, it could have a much larger economic impact on the whole greater
Flinders region if mining were allowed to proceed here.
This reasoning should be taken into account not only for Arkaroola’s sake but for a number of other
businesses within the ranges when considering the impacts on tourism generally in this state if ‘Mining
at Any Cost’ were to occur, and the Class A Zoning is found to be ‘toothless’.
“The prime objectives o f the Environmental Class A Zone seek 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 unless it is in the National or State interest and there is no alternative nearby.”
The following is taken from the Development Plan:
1. Development should not impair the natural and scenic features of the area.
2. Native vegetation should not be cleared in the Environmental Class A Zone.
3. No new roads or tracks should be formed or constructed in the Environmental Class A Zone.
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4. No mining operations should take place in the Environmental Class A Zone except where:
(a) the deposits are of such paramount significance that all other environment, heritage or
conservation considerations may be overridden;
(b) the exploitation of the deposits is in the National or State interest;
(c) investigations have shown that alternative deposits are not available on other land in
the locality outside the zone;
It these ‘guidelines’ can be so easily concealed by another overlying zoning system, which also has no
legislative strength, AND the zones can be changed as more information comes to light, it does not seem
that either system offers any real, long-term, or even useful protection to landscapes, biodiversity,
cultural and heritage values, or to Arkaroola’s finite and small water resources which would probably be
impacted upon by mining.
RECOMMENDATIONS:
My father, Reg Sprigg, a highly-respected Australian geologist, while Chairman of the Australian
Petroleum Exploration Association for 22 years, made certain that the Great Barrier Reef was protected
from hydrocarbon exploration. I believe he would have done everything in his power to make certain
that his beloved Arkaroola was similarly protected if he had realised it might face this current threat.
Others have made the point that we wouldn’t mine Wilpena Pound or Uluru, or in front of the Australian
National Museum – I believe that the Arkaroola Wilderness Sanctuary, though not a National Park,
should be added to that list.
It is however pointless making Arkaroola a National Park. With Dual Proclamation this area would still
be under threat from mining and exploration. This area is a special case, and requires formal
recognition of its values, with legislated protection - even if it is privately owned and operated.
Seeking a Balance should therefore be looked on as an valuable initiative that has raised public
awareness; its current proposals, though perhaps hastily conceived and inadequate in scope, should
lead to something much more thoroughly considered with positive outcomes for the State of South
Australia.
Schemes for multi-zoning the Arkaroola Wilderness Sanctuary for mining and exploration should be
eliminated once and for all, and a long term, genuine protection strategy be developed in its place with
full protection for Arkaroola’s outstanding geological and biological values right across the sanctuary.
Please ‘paint’ all of the mountainous area of the Arkaroola Wilderness Sanctuary ‘Namatjira Purple’
Zone 1: No Mining Access.
Sincerely,
(personal details deleted)
Margaret Sprigg
Arkaroola Wilderness Sanctuary
Owner/Manager
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REFERENCES
Lothian, A. (2009) Flinders Ranges Landscape Quality Assessment Project, Scenic Solutions, Adelaide.
Hamilton-Smith, E. (2001) Review: Protected Area Management: Principles and Practice, Worboys, G,
Lockwood, M & de Lacy, T. Charles Sturt University, Aust.
Lay, B. & della Torre, B, (2000) Arkaroola Pastoral Lease Assessment Report, Dept Env. Heritage &
Aboriginal Affairs, Biodiversity Monitoring Evaluation, Adelaide.
Dept of Planning & Local Govt. (2003) Development Plan: Land Not Within a Council Area ( Flinders),
Development Act, , Adelaide.
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