Response to Submissions
Tarkine Forest Drive
Tasmania
Reference: EPBC 2011/6210
Table of Contents
1. Purpose ...... 1 2. Background ...... 1 3. Submissions Received ...... 2 3.1 Submission 1 ...... 2 3.2 Submission 2 ...... 4 3.3 Submission 3 ...... 10 3.4 Submission 4 ...... 20 3.5 Submission 5 - The Tarkine National Coalition...... 22 3.6 Other non-formal submission ...... 35 4. References ...... 36
Appendix A Public submissions
Prepared by: ______Date: 19 December 2012 Dion Lester
Reviewed by: ______Date: 19 December 2012 Ian Woodward
Authorised by: ______Date: 19 December 2012 Dion Lester
Report Revision History Rev Description Prepared by Reviewed by Authorised by Date No. 00 Response to Submissions Dion Lester Ian Woodward Dion Lester 13/12/2012 Tarkine Forest Drive Tasmania – Reference: EPBC 2011/6210
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw
1. Purpose This Response to Submissions has been prepared by the Department of Infrastructure, Energy and Resources (DIER), following the public advertising of DIERs Draft Public Environment Report (Draft PER) for the proposed Tarkine Forest Drive in Tasmania’s north west.
The Response has been prepared to assist the Commonwealth’s environmental assessment of the road upgrade under the Environment Protection and Biodiversity Conservation Act 1999 (the Act).
Following the advertising of the Draft PER for public comment, section 99 of the Act requires that DIER finalises the PER (incorporating any required amendments) and prepares this companion Response to Submissions which is to include at least a summary of public comments and how they have been addressed.
The Act requires that DIER provides the final PER to the Department of Sustainability, Environment, Water Population and Communities (SEWPaC), along with this Response and copies of any comments after finalising the PER.
The Act requires that DIER then publish the finalised PER and this Response within 10 business days of providing them to the Department.
Subject to any requests from the Minister for further information, a decision on whether the proposed action will be approved will be due within 40 business days of the Department receiving that documentation.
2. Background On 18 November 2011 a referral for the Tarkine Forest Drive Project was submitted to SEWPaC. The Minister determined that the proposal was a controlled action (EPBC 2011/6210) and that the level of assessment was to be a Public Environment Report (PER) on 3 January 2012
The Minister issued final guidelines for the PER in March 2012.
A Draft PER was prepared by DIER in accordance with the PER guidelines. The Draft PER describes the proposal, examines the potential environmental impacts and describes how those impacts will be avoided, mitigated and/or managed.
In accordance with section 98(1)(c) of the Act, the Draft PER was made available by DIER for public review and comment. Its availability was advertised in The Australian, The Advocate and The Mercury newspapers.
The public review was open from 15 October 2012 until 12 November 2012.
The Draft PER was made available for viewing and downloading from the DIER web site (http://www.transport.tas.gov.au/infrastructure_projects/public_displays/tarkine_pu blic_environment_report).
Copies of the Draft PER were also made available for viewing at: Circular Head Council offices, 33 Goldie St, Smithton The Department of Infrastructure, Energy and Resources, 10 Murray St, Hobart Smithton Library, Nelson St, Smithton Service Tasmania, 134 Macquarie St, Hobart Cradle Coast Authority, 30 Marine Terrace, Burnie
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 1
The Library of the Department of Sustainability, Environment, Water, Population and Communities, John Gorton Building, King Edward Terrace, Parkes, Canberra.
3. Submissions Received Five public submission on the Draft PER were received. For privacy reasons the names and addresses of each submission author has been omitted. The only exception to this is the organisation - the Tarkine National Coalition. It was deemed necessary to highlighted this submission given the background and also the TNC are on the public record a number of times for this project.
This Response to Submissions provides responses to the issues raised in these submissions and describes the revisions made to the PER.
The submission comments requiring a response are provided below in blue italic font, with a response directly following the specific points raised. A statement as to the changes required to the Draft PER completes each response.
A full copy of each submission can be found in Appendix A. 3.1 Submission 1 We, the undersigned, hereby lodge this written objection to the proposed project and provide in support the following most important reasons for objecting most vigorously.
1. We are totally convinced that the purpose behind these road improvements is to allow access for commercial activities, other than tourism. We are advised that under all the current Laws, irrespective of any World Heritage Listing, the state Government can still carry out forest logging and mining activities. For this reason alone, until these Laws are amended, this proposed heavy duty ‘all purpose’ road will be forever, at the risk of being used to exploit and ruin forever this vast natural wilderness area. Why not just leave the good existing ‘very useable’ roads and only upgrade any needed repairs to reach the same standard and repair or replace any bridges to the same ‘moderate’ standard? Thereby saving the State Government millions of taxpayer’s funds and allows the tourists to see the Tarkine Wilderness as it now is and how it should remain. The existing road not only slows traffic for visitors to view the beauty of the area but also protects the wildlife and must remain, as the last real Tasmanian natural wonder.
The Tarkine Forest Drive was conceived as a tourist road (please refer to sections 1.6 & 1.7 of the PER) and directly corresponds with one of the five corridors identified in the Tarkine Tourism Development Strategy, developed in 2008 by the Tarkine Discussion Group. The Tarkine Discussion Group is a key regional representative stakeholder group, consisting of regional tourism bodies, Tourism Tasmania, local government leaders, public land managers and special interest groups, including the Tarkine National Coalition and the Arthur Pieman Conservation Management Committee. The group has been extensively consulted (and continues to be) in the development and planning for the Tarkine Forest Drive.
There is considerable uncertainty over the future of Forestry in this region (as a result of the Tasmanian Forests Intergovernmental Agreement, refer to Figure 1.2 in the PER) and mining (as a result of the potential National Heritage Listing); however, the planning of the Tarkine Road has continued unabated. This is because the Tarkine Forest Road is a tourist road.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 2
The State-owned road network consists of 3,650 km of road. It is a subset of the broader road network that focuses on connectivity and movement functions at State and regional levels. To plan and manage this network within a clear and strategic framework, DIER has adopted a five-tier hierarchy. The hierarchy identifies five categories of roads: Category 1 Trunk Roads - The primary freight and passenger roads connecting Tasmania Category 2 Regional Freight Road - Tasmania’s major regional roads for carrying heavy freight Category 3 Regional Access Road - The main access roads to Tasmania’s Regions, carrying less heavy freight traffic than Regional Freight Roads Category 4 Feeder Road - Allowing safe travel between towns, major tourist destinations and industrial areas Category 5 Other Roads - The remainder of the State Roads.
The Tarkine Forest Drive is a Category 5 Other Road. Other Roads are primarily access roads for private properties. Some may be used for comparatively low frequency heavy freight vehicle transport and for log transport but they are not the most important log transport roads, and experience fluctuation in use.
The works proposed are the minimum necessary to facilitate safe tourist access – there is certainly no “heavy duty ‘all purpose’ road” proposed. In fact, the design width is 0.6 m narrower (shoulders are each 0.3 m narrower) than DIER’s target standards for a Category 5 road.
The existing roads will be improved so that they can facilitate increased and improved tourist access to the area. Moreover, many tourists are denied access to this area as hire car companies do not allow vehicles to travel on gravel roads.
DIER has recently assumed responsibility for all of the previously Forestry Tasmania roads that make up the Tarkine Forest Drive. Under Forestry Tasmania management there was no impediment to the use of B-Doubles on these roads. However, under DIER’s management, B-Doubles will be prohibited from using these roads without the issue of a special permit.
No change to the PER is required.
2. We are opposed to the way the Tasmanian State Government is being locked into these commercial aspects of business enterprises which is dramatically depleting the ability of this State Government from carrying out it’s proper Governmental obligations. This vast expenditure on such heavy duty highway construction works, will not allow the Police, Hospitals and Schools to return to the proper functional conditions which they were before the recent budget cuts were introduced. We keep wondering who is really running this State Government, is it the Public Service or Forestry Tasmania dictating what project is next, as was evidently happening when the Franklin Dam was designed and stopped by massive public disapproval. If this scenario is what really exists, then the State Government is simply asking for more trouble.
This is a comment on State Government Policy; it is not relevant to the PER.
No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 3
3.2 Submission 2 I am extremely concerned and suspicious about the timing and true purpose of this proposal which appears to have been submitted at this stage in order to circumvent potential Heritage Listing. The Tasmanian State Government has made no secret of its wholehearted support for mining projects in the region and has lobbied the Federal Environment Minister opposing Heritage Listing for the Tarkine.
http://www.themercury.com.au/article/2011/09/11/260501_tasmania-news.html
This Mercury article relates to the Venture Minerals projects on the Pieman Road – some 60 km south of the proposed Tarkine Forest Drive. The Tarkine Forest Drive travels in an east west direction. The Venture Minerals Mt Lindsay ore concentrates will be exported through Burnie or Port Latta. The likely transport route will follow the Murchison Highway, which is not part of the Tarkine Forest Drive route and does not, at any point, intersect the Tarkine Forest Drive. The Grange Resources Savage River Mine is south of the Tarkine Forest Drive route.
The Tasmania Government has made its intentions very clear regarding the timing and scope of the Tarkine Forest Drive. In early December 2010, the then Minister for Infrastructure, Hon Lara Giddings MP, announced that Cabinet had approved a revised Project.
This commitment was consolidated in the 2011/12 State Budget with the Project identified as a key project and funding allocated for the period 2011/12 to 2013/14. Both of these announcements occurred well in advance of DIER submitting the referral (November 2011), and therefore there was ample time for the Federal Minister for the Environment to determine the National Heritage Listing, emergency or otherwise.
No change to the PER is required.
These public pronouncements totally contradict the supposed tourism benefits of the proposal and it therefore appears that the true purpose of the road is to assist a mining company to use the route for transporting its product to ports and open up the area for logging.
Please refer to the response to submission 1.
No change to the PER is required.
I am particularly concerned that the Report admits on page 11 that the transport of product for Shree Minerals proposed magnetite/hematite mine near Nelson Bay River will use Rebecca Road, Blackwater Road and Sumac Road, all part of the proposed Tarkine Forest Drive. This will have a potentially devastating impact on threatened species such as the Tasmanian Devil regardless of the mitigation measures proposed in the report.
The proposed Shree Minerals operation is currently subject to EPBC Act assessment. The proponent has provided their own suite of mitigation measures in relation to roadkill (these are summarised on pages 11 & 12 of the Tarkine Forest Drive PER). In addition, an exhaustive risk based assessment of the Tarkine Forest Drive route has been undertaken by DIER – this assessment has informed the extensive mitigation strategy proposed. In the event that the initial mitigation strategy is not effective, weekly monitoring of roadkill and quarterly assessment of the results will inform adaptive management of roadkill. These measures are considered to appropriately mitigate any roadkill risk, from Shree Minerals or other road users.
No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 4
I would also refer you to a report in the Canberra Times dated 22/11/2011, in which former UTAS environmental scientist Professor Hamish McCallum has suggested that roading for new mining proposal could have a tenfold increase in roadkill of the endangered Tasmanian devil. Now Griffith University’s environment department head, Professor Hamish McCallum, said that the impact of increased traffic of heavy vehicles would ‘‘effectively decimate’’ the populations of Tasmanian devils, in a refuge that remains free of a deadly facial tumour disease. ‘‘This is a serious concern, and yes, it could be time to consider whether roadkill should be listed [in law] as a key threatening process to native wildlife like the Tasmania devil,’’ he said. http://tasmaniantimes.com/index.php?/weblog/article/expert-predicts-new-mining- in-the-tarkine-could-result-in-a-tenfold-increas/
The Tarkine Forest Drive is not roading for new (or existing) mining proposals as is asserted. As previously stated, it involves the sealing of an existing road for the purposes of improving the safety and accessibility for tourists. The risk of roadkill from the changes proposed has been assessed and mitigated. Any new mining proposals will need to undergo their own separate assessment process, and if there is elevated risk of roadkill, will be required to manage this risk.
It is not clear on what evidence Professor McCallum has based his assertion of a 10 fold increase in roadkill or indeed which mining proposals he is referring to that will cause such an impact.
The mining proposals that do exist would be developed irrespective of the sealing or otherwise of the Tarkine Forest Drive.
The EPBC Act provides the legal framework for management and protection of nationally important fauna, including the Tasmanian devil. Any development that may have a significant impact on a matter listed in the EPBC Act must be assessed by the Federal Minister. This assessment includes the cumulative impact of proposals. Roadkill is already listed as a threat to Tasmanian devils and already requires consideration in development proposals, so Professor McCallum’s calls would achieve no apparent purpose.
No change to the PER is required.
I also fail to see why the two areas outside the Tarkine Forest Drive (Roger River Road and a 12.8 km section of Arthur River Road, north of Arthur River) that are recognised as having existing elevated roadkill should not already be mitigated by measures such as the installation of rumble strips as outlined in Section 6 of this report. Claiming that these benefits will be lost if the project does not proceed is a damning indictment of the Government’s lacklustre approach to conservation.
The two sections of road discussed above are not DIER roads. Roger River Road is managed by Forestry Tasmania, and the Arthur River Road by Circular Head Council. The elevated roadkill levels on Roger River Road were only discovered as a result of the roadkill research and background surveys that occurred because of the Tarkine Forest Drive.
The Arthur River Road had roadkill mitigation measures installed as part of its upgrade in 2003. Analysis of the roadkill data collected on this road indicated that what residual roadkill was occurring generally did so in two clear areas or hotspots.
Development of the Tarkine Forest Drive will be accompanied by the additional placement of mitigation treatments at known hotspots on both Roger River Road and Arthur River Road. However if the Tarkine Forest drive is not developed then the budget for the project will be allocated to other government priorities and it will not be possible for DIER to fund these mitigation treatments on the two roads in question. No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 5
The Tarkine is one of the last DFTD-free refuges for the threatened Tasmanian Devil and the EPBC Act List of Threatened Fauna shows that the listing of the Tasmanian Devil was upgraded to endangered species status on 29 May 2009 having first been listed as a vulnerable species in May 2006.
http://www.environment.gov.au/cgi- bin/sprat/public/publicthreatenedlist.pl?wanted=fauna#mammals_endangered
The draft Tasmanian Devil Recovery Plan prepared by DPIWE in 2010 has yet to be incorporated within the EPBC Act which appears to breach Section 273 of the EPBC Act which specifies the deadline for recovery plans as follows: (1) Subject to subsection (2), a recovery plan for a listed threatened species or a listed threatened ecological community must be made and in force within 3 years of the decision under section 269AA to have the plan. (2) The Minister may, in writing, extend the period within which a recovery plan must be made. Only one extension can be granted for the making of the plan, and the period of the extension must not be more than 3 years.
http://www.austlii.edu.au/au/legis/cth/consol_act/epabca1999588/s273.html
The latest distribution mapping for the extent of DFTD shows that DFTD affects 75% of the state1. This includes a significant area of south west and northwest Tasmania. It is misleading to state that the Tarkine is one of the last DFTD refuges.
If and when the Draft Tasmanian Recovery Plan becomes incorporated within the EPBC Act, and how that relates to Section 273 of EPBC Act, is not a matter for DIER or in fact relevant to the PER that has been prepared. Importantly, the Draft Recovery Plan and all other known relevant documents have been reviewed and are referred to within the PER.
No change to the PER is required.
However, the following Conservation Advice approved by the Federal Minister for the Environment on 19 May 2009 is required to be taken into account when assessing any proposal referred under the EPBC Act. It advises that the main identified threats to the Tasmanian Devil are DFTD and motor vehicles, while culling by humans is a lesser threat. In addition to the identified threats, the main potential threats include foxes and habitat modification. If Tasmanian Devil densities become very low there is a risk that disturbance or destruction of maternal dens, as a result of land clearance, for example, for urban development, forestry and agriculture, could affect the species’ breeding success and pose a significant threat to the Tasmanian Devil.
http://www.environment.gov.au/biodiversity/threatened/species/pubs/299- conservation-advice.pdf
The extensive investigations and mitigation strategies developed specifically in relation to roadkill indicates the importance DIER places on mitigating this risk.
The Draft Recovery Plan for the Tasmanian Devil notes that “there are indications that the total number of devils killed on roads is declining with the decline in the population”. It goes on to say that “Collision with vehicles is generally considered a low level threat to the species across Tasmania; however, in areas where devil numbers are already reduced, loss of a high number of individuals due to collisions with vehicles could contribute to a population decline.” (Page 12) No change to the PER is required.
1 Save the Tasmanian Devil Program website. http://www.tassiedevil.com.au/tasdevil.nsf/Mapping-the- disease/A140AACCA1B1F6B0CA2576CB0011BD2C
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 6
Section 139 of the EPBC Act defines the legislative requirements for decisions about threatened species and endangered communities as follows:
(1) In deciding whether or not to approve for the purposes of a subsection of section 18 or section 18A the taking of an action, and what conditions to attach to such an approval, the Minister must not act inconsistently with: (a) Australia’s obligations under: (i) the Biodiversity Convention; or (ii) the Apia Convention; or (iii) CITES; or (b) a recovery plan or threat abatement plan. (2) If: (a) the Minister is considering whether to approve, for the purposes of a subsection of section 18 or section 18A, the taking of an action; and (b) the action has or will have, or is likely to have, a significant impact on a particular listed threatened species or a particular listed threatened ecological community;
the Minister must, in deciding whether to so approve the taking of the action, have regard to any approved conservation advice for the species or community.
http://www.austlii.edu.au/au/legis/cth/consol_act/epabca1999588/s139.html
The Conservation Advice clearly precludes the development of any proposal which will impact upon the threatened Devil population in the Tarkine, especially given that this is the last refuge for healthy DFTD-free Devils. In addition to the Tasmanian Devil, the list of Tasmanian threatened species for which the proposal provides an unacceptable risk includes the Spotted-tailed Quoll and Tiger Quoll for which Recovery Plans are currently in preparation.
http://www.environment.gov.au/biodiversity/threatened/recovery.html
The fact that roadkill is listed as a threat to the Tasmanian devil and that the Tarkine Forest Drive may increase the risk of roadkill does not preclude the approval of this project. The Minister needs to consider all the matters listed in Section 139 of the EPBC Act. Importantly, this includes whether the action will have or is likely to have a significant impact on a threatened species. The PER provides a comprehensive assessment of the risk of roadkill and responds with a detailed mitigation strategy. The measures outlined in the PER are considered to mitigate the risk of roadkill to such a level as to render the chances of a significant impact to be very low. In the unlikely event that the mitigation strategy does not adequately manage roadkill, the adaptive management strategy, and the associated trigger levels, will ensure that any increase in roadkill from current levels will be detected and appropriate management actions implemented.
The same comments apply to the spotted-tailed quoll.
No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 7
Threatened wedge-tailed eagles will also be put at more risk as they will inevitably scavenge roadkill which will be significantly increased by additional traffic if the road proceeds as proposed.
The roadkill mitigation strategy will ensure that the risk of wedge-tailed eagle (and other fauna species) roadkill is minimised. One of the fundamental benefits of the strategy is that it will reduce all roadkill and therefore reduce the food resources present on the road for scavenging species.
No change to the PER is required.
If the Tasmanian Government truly wishes to maximise the tourism potential of the Tarkine, as claimed in the Report, then it would support rather than oppose heritage listing of the entire area. In this regard it should be noted that the Australian Heritage Council recommended in October 2010 that the entire 447,000 hectares of the Tarkine met the criteria for permanent heritage listing as a whole. These recommendations were briefly published on a government website but were quickly removed from public view and their release refused by FOI.
http://www.theaustralian.com.au/national-affairs/burke-defied-report-on-tarkine- listing/story-fn59niix-1226018009389
http://tasmaniantimes.com/index.php?/weblog/article/acid-on-burke-australian- heritage-council-recommends-tarkine-national-herit/
The Summary of National Heritage Values in the Tarkine states:
The natural and cultural values of the Tarkine are well recognised and include; - The largest single tract of rainforest in Australia, and the largest Wilderness dominated by rainforest in Australia; - 190,000 ha of rainforest in total; - The northern limit of Huon Pine (Lagarostrobus franklinii); - A high diversity of wet eucalypt (tall) forests including large, contiguous areas of Eucalyptus obliqua; - A great diversity of other vegetation communities, such as; dry sclerophyll forest and woodland, buttongrass moorland, sandy littoral communities, wetlands, grassland, dry coastal vegetation and sphagnum communities; - A high diversity of non-vascular plants (mosses, liverworts and lichens) including at least 151 species of liverworts and 92 species of mosses; - A diverse vertebrate fauna including 28 terrestrial mammals, 111 land and freshwater birds, 11 reptiles, 8 frogs and 13 freshwater fish; - Over 50 rare, threatened and endangered species of flora and fauna, including the Tasmanian Wedge Tailed Eagle and Giant Freshwater Crayfish; - A complex and diverse invertebrate fauna, including; at least 16 species found nowhere else, the largest freshwater invertebrate on earth (Astacopsis gouldi) and one of the richest amphipod (a type of small crustacean) fauna diversities in the world; - Globally unique magnesite karst systems in the Lyons/Keith/Arthur River areas and at Main Rivulet/ Bowry Creek area; - Excellent examples of joint controlled drainage features (e.g. Huskisson syncline, Meredith Range, Rapid River);
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 8
- Significant coastal features such as the Sandy Cape dune field and the Arthur River estuary (probably the best example of a large river estuary in good condition in Tasmania); - Dolomite karst systems in the Trowutta/Sumac/Black River region; - Karst landforms in the 'Ahrberg' group (Donaldson and Upper Rapid rivers); - The largest basalt plateau in Tasmania retaining its original vegetation; - Other geomorphic features such as the Bulgobac glacial end moraine and fossil sites at Marionoak and Hatfield River; - Large areas of high quality wilderness centred on the Meredith Range and the Sumac region and three separate areas (Norfolk Range, Mt Bertha/Donaldson River and Savage/Keith River) which actually abut each other, creating a continuous stretch of wilderness covering much of the proposed National Heritage Area; - Areas of high quality scenic value such as; Australia's largest tract of rainforest, the Meredith Range, the Norfolk Range and the coastline; and - One of the richest archaeological sites in Tasmania with the diversity and density of Aboriginal sites ranking it among "the world's greatest archaeological sites''.
http://tasmaniantimes.com/images/uploads/Tarkine_Place_Details_(Aust_Heritage_Da tabase_-_4_March_2011).doc
http://law.anu.edu.au/acel/TARKINE_PLACE_DETAILS_AUST_HERITAGE_DATABASE_- _4_MARCH_2011.pdf
http://news.anu.edu.au/?p=7841/
In addition, an Australian Centre for Environmental Law Working Paper dated March 2011 concludes:
A crucial finding of the Council in the context of the Tasmania Magnesite proposal was that, not only does the Tarkine possess ‘extensive high-quality wilderness and natural landscape values’, but ‘consideration of wilderness in the Tarkine as a National Heritage value must encompass all of these areas as parts of a whole, as a single wilderness region, as is traditionally done for the Tasmanian Wilderness World Heritage Area’. This is significant because it implies that damage to one part of the Tarkine will affect the wilderness value of the whole, not just the parcel of land on which the project is located and its immediate surrounds.
http://tasmaniantimes.com/images/uploads/Working_paper_- _NHL_and_the_Tarkine_(8_March_2011).doc
Although I broadly support any proposal to increase eco-tourism in the area by improving access I see no valid reason to rush ahead with a dubious proposal which should be delayed, reviewed and resubmitted after the Tarkine National Heritage Assessment has been finalised. For that reason, I conclude that the current proposals for the Tarkine Forest Drive should be rejected.
Furthermore, the potentially adverse impact of this current proposal demands that Federal Minister for the Environment reinstates the Emergency Heritage Listing as a matter of urgency and I call upon Minister Burke to act accordingly.
Whether or not the Tasmanian Government supports a National Heritage Listing for the Tarkine is not relevant to the Tarkine Forest Drive proposal or PER. The assertion that DIER is rushing ahead with this proposal is rejected - as mentioned previously. The timing of the current proposal has been widely distributed and importantly it comes after the previous proposal for a longer route in 2009. This project and its predecessor have been well known to the Tasmanian community since 2009.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 9
The Tarkine Forest Drive involves no new infrastructure. It proposes the upgrade of existing assets, and therefore whether or not a National Heritage Listing is present is immaterial. Wilderness values are unaffected by the upgrade to existing infrastructure – in accordance with the National Wilderness Inventory criteria – and the other natural and cultural matters for the Tarkine have been thoroughly assessed throughout the planning phase of the project.
No change to the PER is required.
Finally, I consider that this proposal is a prime example of a project developed by a State Government Department (DIER) which demonstrates an unacceptable conflict of interest in terms of assessing the proposal should the Federal Government proceed with its flawed proposals to develop assessment and approval bilateral agreements under the EPBC Act.
http://www.environment.gov.au/epbc/publications/accreditation-standards- framework.html
This Draft Framework is not relevant to the current proposal. The Tarkine Forest Drive is being assessed by the Federal Government through a Public Environment Report. It is not being assessed under the existing Bilateral Agreement or the yet to be initiated framework highlighted in the above link.
No change to the PER is required. 3.3 Submission 3 This major road upgrade proposal is not primarily for tourists because it basically serves as a facility to aid the logging and mining industry, commercial fishery, recreation users and coastal shack owners. In particular, it will provide an easy access for fast travel, mostly in the dark, for the shack owners and off-road recreation users to and from the Couta Rocks/Temma areas on the TARKINE Coast.
It should be noted that this project was a political decision to appease the above users, the Circular Head Council and self-interest promotors for road sealing. Ironically, these same people avoid the use of the word TARKINE and have a record of resistance to any moves for the improved protection and management of the area’s natural heritage and Aboriginal cultural values.
Please refer to previous comments regarding the purpose and function of the Tarkine Forest Drive. The proposed road improvements will improve the safety for existing road users, such as shack owners, but that is not the primary purpose of the proposal. In conjunction with associated marketing of the Tarkine and complementary private investment in experiential tourism and infrastructure in the region, visitation is estimated to increase from 30,000 interstate and overseas tourists in 2011 to 74,000 by 2025.
No change to the PER is required.
I consider that the proponent DIER should not be given the responsibility for the design, construction and management of this project because it has a history of being incapable of doing what is right for natural, heritage and cultural values. By way of example, this Department has declined for years to meet with the Cradle Stakeholders, despite repeated invitations, to discuss issues that relate to DIER’s part in the management of important tourist roads leading to and within the National Park/World Heritage Area.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 10
DIER is Tasmania’s peak transport body. There is no more appropriate body to be developing this road. The Transport Infrastructure Services Division of DIER seeks to provide a transport system for Tasmania that is safe, recognises the needs of the community and helps to enhance economic development.
The investment of public funds in upgrading the Tarkine Forest Drive to “Tourist Road” standard results in a very high return on investment to government and the community. This result is achieved from the combination of the direct and flow-on impacts of the project and most dramatically from increased tourism demand, expenditure and investment.
DIER is working hard to ensure that consideration of the sensitive environment is paramount during the planning, design and construction stages of this project. It believes that this road offers opportunities to showcase innovative solutions to protect Tasmania’s precious flora and fauna. Ultimately, these solutions will have more widespread benefits.
Issues that relate to other areas of the States road system are not relevant to the PER.
No change to the PER is required.
Early Eco-Tourism I have been involved in establishing the first commercial eco-tourism operation in the Tarkine that attracted many local, state, interstate and international clients to view this area and to experience its natural and cultural values at first hand. Utilising the existing gravel road network, this operation, known as TASVENTURE ® Safari Tours was featured in the cover story of Tourism Australia’s international magazine, and was reported on by attending officers from that Department.
More recently, I acted as manager and was one of the volunteer guides for Club Tarkine ® Inc. That ran day, weekend and extended bus tours out from Launceston into the Tarkine wilderness. This tourist service also utilised the existing road network (excluding the so-called “Western Explorer”), and enabled the public (including international Indigenous people) to experience the many accessible values of the Tarkine.
These Tarkine tourist businesses were based on my in-depth knowledge of the area, which began in 1968 with the preparation of the Norfolk Range National Park proposal to the Tasmanian State Government for protecting what is now known as the Tarkine area. This proposal was initiated by the Circular Head Council and supported by the local community.
Over a period of 44 years, I have been officially involved in recording the rich diversity of unique Aboriginal cultural values of the Tarkine as well as highlighting the area’s great natural values, and the need for their sustainable management and protection, both locally and internationally as worthy and meeting the criteria for World Heritage nomination.
Being very familiar with the features along the route of the proposed TARKINE FOREST DRIVE project, having driven, walked, flown and closely studied and photographed the area on numerous occasions, I now place before you the following comments on this proposed project.
History The proponent fails to recognise the role of pioneering eco-tourism ventures such as Tasventure ® and Club Tarkine ® Inc.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 11
Current access The existing network of roads and tracks in the Tarkine already provides access for small tour coaches and the normal suburban car to many of its features and it is wrong for the proponent to claim that the area is “not suitable for hire vehicles which greatly restricts its accessibility to tourists”. Many vehicle hirers accept the insurance waiver and travel carefully into the area on the existing unsealed roads. By way of example, the winding gravel road (the so-called Western Explorer) through the Tarkine is already promoted by DIER and is used by visitors in hire cars. This 50km stretch of road in a remote area has virtually no service features at all, other than a few basic signs, and it has little ongoing management by DIER to inform or aid visitors.
Significant sections of the route are unsealed and therefore not suitable for touring cycles, motorcycles, hire vehicles and some cars which greatly restricts its accessibility to tourists. The roads were also constructed to forestry standards rather than public road standards, which presents a safety risk to users, notably tourists, who are unfamiliar with such roads.
It is well established that many hire car companies void vehicle insurance if the vehicle is taken on gravel roads; they have a zero tolerance of gravel roads. This significantly diminishes the number of visitors who will consider driving on gravel roads. It is an odd concept to suggest that vehicle hirers should simply accept this risk and drive carefully. Tourists are highly represented in crashes on gravel roads and many visitors to Tasmania are unfamiliar with such roads.
The Tarkine has been identified in a number of previous studies as providing a key drawcard on which to anchor the future of tourism in the North West Region. A number of economic studies demonstrate the benefits to the North West. The existing condition of the roads, however, necessarily constrains the wider marketing of the area. Only once safe, all-weather access and improved facilities are provided can the area be marketed as a viable extension to the itineraries of visiting tourists and an area worthy of wide visitation by Tasmanians.
The Tarkine Forest Drive will create an impetus for the development of the tourism industry in the region by leveraging the Tarkine brand to put the North West Region firmly on the tourist map. Improved accessibility fits with visitor preferences to explore destinations which have varied experiences in close proximity and the project has the potential to increase the stay of tourists in the region to multiple days.
The project will also support existing and proposed ecotourism ventures and experiences in the Tarkine Region, resulting in the creation of a unique tourism icon. This will be of great benefit to a region that has been hit hard by the downturn in the economy.
The project is a logical extension and major enhancement of the Great Nature Trail.
DIER has been working with Tourism Tasmania and other key stakeholders to optimise the implementation of the project to maximise its tourism potential. Construction of the Tarkine Forest Drive will facilitate future development in the North West through: Opening up the area to organised tours including coaches Providing access to new eco-adventure sites Providing safer access to previously difficult to access areas with high tourist value Creating a loop road to encourage visitors to travel further and spend more time in the North West Promoting existing attractions Allowing visitors with hire cars to access areas previously off limits due to insurance restrictions on unsealed roads
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 12
Developing and improving tourist facilities within the State Forest Creating potential for significant attractors to create ‘iconic’ Tarkine experiences.
No change to the PER is required.
Potential conflict for road users It is indeed unfortunate that this proposed route for the tourist drive will also facilitate heavy industrial traffic associated with forestry and mining operations. Whilst the traffic numbers from this industrial source may be small, their presence will nevertheless impinge detrimentally on the quality of the wilderness experience for visitors who use this same route.
Please refer to previous comments regarding the purpose and function of the Tarkine Forest Drive. Any changes to forestry or mining traffic in the region will occur with or without the Tarkine Forest Drive.
No change to the PER is required.
DIER - has a very poor track record It is noted that the proponent (DIER) of this proposed TARKINE FOREST DRIVE project says it will “ensure minimal environmental impact and protection of the local flora, fauna and heritage values”. But how? It is quite clear that with an expected increase in visitor numbers, uncontrolled, there will be impacts that will be detrimental to the local flora, fauna and heritage values as well as the ultimate Tarkine experience. There are numerous examples of DIER’s works impacting on local flora, fauna and heritage sites in other sensitive areas including: • a wipe out of local populations of threatened fauna in the Cradle Mountain precinct, including a population of Eastern Quolls on the Leary’s corner to Cradle Mountain Village sealed road (see Mena Jones 1992 study), as well as within the Cradle Mountain National Park;
In June 1991, 2 km of the access road into the northern end of the Cradle Mountain – Lake St Clair National Park was widened and sealed to carry an increasing volume of heavy traffic such as tourist coaches. This occurred part-way through an ecological study of the dasyurid carnivore guild (which includes quolls and devils), during which local populations were being monitored.
The coincidence of these two projects allowed assessment by Jones (2000) of: The factors that changed with the road upgrading that may have contributed to an increase in roadkills The road mortality patterns in relation to landscape features; and The success of measures implemented to reduce mortality.
Prior to the road upgrade, the local populations were estimated to be 19 eastern quolls and 39 devils. In the 12 months immediately following the road upgrade there was a marked increase in the number of roadkills of eastern quolls and Tasmania devils recorded on the upgraded section of the road. Most of these were concentrated in three areas, which were identified as ‘black spots’. The eastern quoll population declined from 19 to 1 individual in 17 months, reaching zero after 22 months. The Tasmanian devil population declined from 39 to 20 individuals in 22 months (Jones 2000).
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 13
On being made aware of the increased roadkill DIER undertook a number of mitigation actions in collaboration with the members of the ecological study team. The measures included placement of slow points (barriers to constrict traffic to a single lane in the centre of the road), appropriate signage alerting drivers they were entering a wildlife zone, wildlife reflectors to deter wildlife from crossing the road when vehicles were present and improving table drains to enable animals to escape off the road.
The combined measures implemented appear to have been successful in reducing the roadkill rate. Within 6 months, several eastern quolls, were living in the study area. After 2 years, a resident breeding population that was almost 50% of the size of the original pre-upgrade population of 19 individuals, had become established (Jones 2000).
Importantly, the report authors made particular reference to the support and input of DIER in the study and in designing and facilitating the various mitigation actions.
Rather than being an example of being a poor DIER track record, the Cradle Mountain project demonstrates just the opposite, namely that DIER has recognised and responded successfully to roadkill impacts in sensitive areas and that same responsiveness has informed DIER’s comprehensive approach to roadkill mitigation on the Tarkine Forest Drive project.
No change to the PER is required.
inappropriate traffic calming installations at Cradle Mountain Village (see photo below of the New Zealand method);
The traffic calming measures placed at Cradle Mountain (inappropriate or otherwise) are not proposed for use on the Tarkine Forest Drive. The nature of the road environment on the Tarkine Forest Drive renders use of these measures, or indeed the measures displayed in the submission from New Zealand, as a significant traffic hazard. This type of installation would not be anticipated by the majority of drivers in the rural road environment of the Tarkine Forest Drive, and in most areas would not be visible from a safe distance and as such would create a safety hazard.
No change to the PER is required.
Over used and ineffective signage;
The Tarkine Forest Drive has a well defined signage strategy for both tourism and environmental purposes. This signage strategy has been developed in consultation with the Tarkine Discussion Group. The signage proposed as part of the Tarkine Forest Drive Roadkill mitigation strategy is a very small part of a larger more strategic strategy. The use of roadkill related signage will be appropriate to location of an elevated risk of roadkill. In addition, DIER is investigating the use of Intelligent Transport System signage elsewhere in the state for roadkill.
No change to the PER is required.
spreading of roadside weeds; insensitive roadside vegetation slashing by DIER contractor along the Cradle Mountain Tourist Road and the road to Dove Lake in the World Heritage Area in 2009 (see photo below); lack of due care during the construction of bridges and culverts;
The management of weeds and also bridge construction methods to be utilised on the Tarkine Forest Drive have been discussed in detail in the PER. Extensive and robust hygiene and construction management measures are proposed and will be implemented to ensure that the development of the road does not facilitate the spread of weeds or
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 14
impact on the sensitive river environments of the area. Baseline water quality data has been collected; this has: Established a database of background water quality with which to compare water quality during and post construction Ensured that an appreciation of the surface water values in the project area were known and considered in developing project tender documents, project task instructions and project management prescriptions prior to construction Demonstrated compliance with the Environmental Management and Pollution Control Act 1994 and the State Policy on Water Quality Management 1997.
No change to the PER is required.
an example of unsupervised DIER contractors who dumped hot bitumen into the Iris River, off the Cradle Mountain Tourist Road (see photo below); a lack of public toilet facilities on the Cradle Mountain Tourist Road at Black Range lookout and at the Lincoln Junction at Moina, causing a build-up of human waste at both locations and along the tourist road itself; piles of beer bottles, broken equipment and rubbish left behind by inadequately- supervised DIER road maintenance staff and contractors; a sub-culture within DIER of carelessness towards the natural environment; and
These points are not relevant to the PER. However, it should be noted that environmental impacts from the construction of the Tarkine Forest Drive will be managed by a detailed Construction and Environmental Management Plan and full time surveillance, providing much more comprehensive and sophisticated controls than were available 20 years ago for the Cradle Mountain project. Also, additional toilets to those currently on the South Arthur Forest Drive are proposed as part of the Tarkine Forest Drive – refer to Table 2.2. in the PER.
No change to the PER is required.
inadequate attention to road speed restrictions, especially at “dusk to dawn” hot spots.
The monitoring and enforcement of traffic speed is a critical component of the adaptive management strategy for the project. From the outset speed will be monitored using portable devices, with an escalating series of feedback and compliance measures, should excessive speed be determined to be a contributing factor to any increases in road kill.
No change to the PER is required.
Traffic hygiene There is an omission in the draft proposal by the proponent for measures that will need to be implemented for vehicle hygiene measures, including a wash down station/s for all traffic entering the Tarkine to minimise the introduction of weeds and pathogens.
The road upgrade proposal, if approved, will result in an increase in road traffic with the potential to allow weeds to be introduced through seed dispersal from road- making machinery, construction vehicles and visitor’s cars (Refer to Cradle Coast NRM Weed Hygiene Action Plan 2009).
This submission is incorrect. The contractor will be required to prepare a Construction Environmental Management Plan (CEMP). The CEMP will describe the construction management measures that will be required to be implemented by construction contractors as a condition of contract with DIER. The PER outlines the structure and
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 15
contents of the CEMP - importantly, Appendix C of the PER contains the Environment Protection Guidelines that will apply to the construction of the Tarkine Forest Drive. These include measures to manage introduced plants, pest and disease. Wash down stations for construction vehicle are an important element of these measures.
No change to the PER required.
Road kill prevention Accompanied by interstate visitors on a recent drive from Wynyard to Kunannah Bridge on the Arthur River between 10-11am, I personally counted 4 Tasmanian Devils freshly killed on that section of road alone. Despite this intensity of road kill, DIER has taken little, if any, practical precautions to help mitigate these deaths (see photo below). As I also travel frequently on the section of the Cradle Mountain road from Wilmot to Learys Corner, I have made numerous other observations of Tasmanian Devil road kill, apparently all free of DFTD. These incidents have all been reported to the authorities. Whilst in more recent times the road kill of other non-threatened species has increased in this area, there has been no recent sightings of Devil road kill. This indicates to me that these local populations of Tasmanian Devil have now been wiped out (see photo below).
Apart from one section of this Cradle Mountain access road where there is a warning sign ‘dusk to dawn’, the remainder of this commuter / tourist road has a 100 km/h maximum speed restriction.
This speed is far too high, and it has now contributed to the local extinction of Devils. With regard to the measures proposed by the proponent for the prevention of road kill of Tasmanian Devils and other EPBC threatened species, the use of rumble strips, wildlife underpasses, traffic calming devices and speed advisory signs will have little or no effect on those drivers who already have no respect for Tasmanian wildlife. Speed restrictions must all be mandatory and regularly enforced for there to be any chance of them being effective. It is too far late to bring in enforcement once the threatened species has been wiped out.
What has not been addressed in Section 666 Mitigation, is the removal of all roadkill off all sections of this proposed TARKINE FOREST DRIVE project on a regular daily basis. This removal-measure would take away the food source for the threatened carnivores and carrion, which attracts them on to the roads in the first place.
I predict that road kill alone will be a far greater threat to the survival of the Tasmanian Devil than DFTD. At present, there are little, if any, proven measures that are being presently developed or adopted by the State Government authorities, including DIER who are to design, construct and manage this road upgrade proposal, to reduce this severe impact on the threatened species.
Furthermore, there needs to be more done along existing roads elsewhere in the State that are under the control of DIER to demonstrate that Department’s capacity to effectively reduce road kill before any additional road works are approved in the Tarkine, let alone before DIER is allowed to manage this road’s construction and/or maintenance and ongoing management.
The measures proposed are designed to change both driver and animal behaviour. This will ensure that if driver behaviour remains unchanged as a result of the mitigation measures there is an opportunity to still reduce roadkill through changing animal behaviour.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 16
Examples include: Light coloured pavement is believed to cause animals to feel exposed and hence not linger on the road The rumble strips’ most notable effect is an audible sound when crossed by vehicles. The placement of these in areas known to have high animal abundance has been proven to reduce roadkill by greater than 50%. One reason for this is likely to be the sound alerting animals on or near the road to approaching vehicles The verge clearance measures proposed will reduce resources and shelter for animals adjacent to the road, reducing animals lingering by the road side, so when a vehicle does approach they are less likely to be flushed onto the road The improvement to road side drainage will reduce pooling water. This also reduces road-side resources for animals.
Since submission of the draft PER, further analysis has occurred on the appropriate traffic speed limits for various sections of the route. This has resulted in the speed limit being reduced in many sections of the route. The changes are as follows: Arthur River to Spur Rebecca ( sections A, B & C) – 80 km/h Spur Rebecca to Western Explorer (section D) – 80 km/h Western Explorer to Rapid River Rd ( sections E,F,G,H,I,J) - 70 km/h Rapid River Road (section K) - 50 km/h Tayatea Road (section L&M) - 70 km/h.
The PER has been updated to reflect these change.
Vehicle speeds will be monitored in key areas by road traffic counters and analysed on a quarterly basis (with opportunity for interim analysis if required). If vehicle speed is demonstrated to be creating elevated roadkill, then there are a variety of measures that will be implemented on a sliding scale – these include enforcement.
All roadkill found along the route will be removed daily from areas driven by the construction contractor during the construction of the road. Given the location and length of the Tarkine Forest Drive it is not feasible to remove roadkill on a daily basis after construction. DIER does not consider that it will be necessary given the other extensive mitigation actions that will be implemented – i.e. there will be limited roadkill to remove.
The assertion that roadkill provides a greater threat to the survival of the Tasmanian devil than DFTD is not supported by the Federal or State Government authorities responsible for DFTD monitoring.
DIER is currently undertaking works to reduce roadkill elsewhere on the DIER road network, these include: Wildlife Warning Signs Trials (Intelligent Transport System-based Active Wildlife Signs) on East Coast roads - The trial includes - The selection of 15 high roadkill sites (on the Tasman and Arthur Highways) which currently have no wildlife signage and no reduction in speed limits - Initial baseline monitoring of each of the sites for an appropriate period prior to installation of wildlife warning signs and also vehicle speed monitoring - Once treatments (five control sites, five static wildlife warning signs and five active wildlife warning signs) are in place, monitor and record roadkill, continue to record vehicle speed
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 17
- The results will be analysed and inform future DIER signage strategies. Moreover, if results indicate a significant change in driver behaviour, DIER will consider installing ITS based Active Wildlife Signs which would have the capability of communicating back to DIER’s Transport Systems Group control sites for further monitoring and maintenance purposes
Dawn to dusk travel anomaly It is noted that Shree Minerals in their mining agreement have agreed to restrict the transport of ore from the mine during daylight hours and supply a bus for the workers. This is a commendable first step, but it is not enough because it is doubtful that the heavy slow-moving trucks are the biggest problem. Apparently there will be no restrictions on staff, contractors, service personnel or others who can travel this road at anytime. So roadkill will not be prevented.
This submission relates to Shree Minerals, which is currently subject to EPBC Act assessment. Any measures provided by Shree Minerals are in addition to the extensive mitigation strategy proposed as part of the Tarkine Forest Drive.
No change to the PER is required.
Protocol for road construction workers I have been successful in the past in working with Mineral Resourses Tasmania to draw the attention of mining companies to a range of basic precautions that need to be taken by all their workforce and contractors when exploring for minerals in the Tarkine Wilderness. These precautions are as follows: (1) respect the environment, (2) avoid excessive speed when accessing the work site, (3) refrain from feeding native animals, (4) conceal food scraps, and (5) all waste to be contained and disposed of away from the work site at authorised sites.
These proven basic precautions by mining operatives should be included in a protocol to be developed and enforced by the proponent for its contractors and personnel who access this area as well.
The contractor will be required to prepare a Construction Environmental Management Plan (CEMP). The CEMP will describe the construction management measures that will be required to be implemented by construction contractors as a condition of contract with DIER. The PER outlines the structure and contents of the CEMP, the measures outlined above (with the exception of no feeding of native animals) and a number of other management measures are outlined in the PER – refer to Section 6 and also Appendix C.
No change to the PER is required.
Management of the proposed TARKINE FOREST DRIVE This proposed road passes through and impacts on lands that are managed by Forestry Tasmania and the Parks & Wildlife Service. The latter has been progressively starved of funds, has suffered staff and funding cuts and has insufficient Park Rangers to administer, manage or see to the compliance of existing regulations in the large area of the Tarkine under its control.
There needs to be an assurance by the proponent that sufficient funds will be allocated to enable resources for the proper management of the whole of the TARKINE FOREST DRIVE precinct to manage and protect EPBC listed threatened species.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 18
Also nowhere in this proposal is there any reference to the threat of fire to the area brought about by an increase in uncontrolled human activities facilitated by this roading project. The impact of fire on the Tarkine should be assessed in terms of its impact on EPBC listed threatened species.
Already there is evidence of the catastrophic effect of an alleged deliberately lit fire along the DIER-controlled ‘road to nowhere’ (the so-called Western Explorer) as a direct result of uncontrolled public access in this remote wilderness area. This fire resulted in the temporary closure of the Savage River Mine, and to the best of my knowledge was not pursued by authorities. Any increase in road usage will lead to an increase in roadside litter. Apart from being a visual scar, some rubbish thrown from vehicles creates a food source for threatened species. As part of the road management, regular roadside rubbish collection should form part of the management protocol and all users should be encouraged/enforced not to litter.
With the completion of the proposed TARKINE FOREST DRIVE, the planned promotion for its use ‘for everyone in the normal suburban car’ will create a demand for information. So there may be the need for a seven-day-per-week staffing of visitor information booths at both ends of the Drive at Kunnanah Bridge as well as at the Arthur River township. Many users of this remote area will require face-to-face support for information, advice on local conditions, emergencies including fire, health and accidents, and reinforcement of basic protocol and safety precautions.
The level of funding provided to other State Government Departments is a question of Government policy and is not relevant to the PER.
The threat of fire has been discussed within the PER (section 5.3.7), although it is noted that the risk of such random events cannot be quantified. The Tarkine Forest Drive does not facilitate access to areas that cannot already be accessed. What it does do is increase the opportunity for a greater number of people to access the area – with more people comes more risk, but also more passive surveillance. Those more likely to explore are more likely to drive vehicles that can already access other areas. Many new tourists to the area are unlikely to have suitable vehicles for wider exploring. In addition, interpretation signage in relation to wildfire and cigarette disposal receptacles will be installed at key tourist stopping areas along the Tarkine Forest Drive. Wood burning barbecues will be removed at Julius River Reserve and replaced with gas barbecues.
Suitable barriers (for example locked boom gates) will be installed on key Forestry Tasmania spur roads to block access to fire sensitive areas.
No change to the PER is required.
Conclusions The report states that “... DIER is intent on improving the existing road in an iconic area and believes that its development will provide long term benefits to the north west community and valuable lessons on how construction can be managed sensitively.”
Whilst there is little doubt that there will be economic benefits to the north west coast business community, these will come at a cost. The impact on the iconic natural and heritage values of the environment following the promotion of access to this remote area (not ‘rugged’ as described by the proponent) for everyone in the ‘normal suburban car’ will be severe and incremental. The proponent, DIER has a poor track record with regard to interacting with stakeholders, and providing satisfactory facilities to service the basic needs of tourists in remote locations, and certainly has no prior experience in managing threatened species in such sensitive areas. The proponent claims that “valuable lessons on how construction can be managed sensitively” for this proposed TARKINE FOREST DRIVE project. However, the proponent
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 19
has learned little over the years where it has been responsible for managing threatened species or servicing iconic areas.
This Tarkine road upgrade should not be used for lessons to be learned. I consider it totally inappropriate for approval to be given to this government Department (DIER) to have the sole responsibility for the design, construction and management of this proposed TARKINE FOREST DRIVE project. It cannot guarantee the protection and proper management for EPBC Listed Threatened species in this iconic area.
Should approval be granted for this proposed TARKINE FOREST DRIVE project, there will be a surge in visitor numbers, with an expectation of those who visit in their ‘normal suburban car’ to have basic facilities to service their needs in this relatively remote area. This wilderness area with its many iconic features is not ‘seen’ so much as ‘experienced’, and unless there is careful planning and sufficient funds and staffing levels to ensure satisfactory ongoing servicing and management, it will end up being a ‘turn off’ for many who will not wish to return or recommend it to others.
This is an opinion. DIER considers itself a responsible environmental manager and the work done for this project is the most valid demonstration of that. An immediate surge in activity is not as likely as a gradual increase in tourism visitation and DIER’s adaptive management strategy will respond to any new impacts within a reasonable timeframe.
No change to the PER is required. 3.4 Submission 4 The information provided is voluminous but ‘flawed’ for the following reasons:
1. This is not a ‘win-win’ project as represented.
This is opinion, with no reference to elements of the PER that require amending or further consideration.
2. It should not be being pursued prior to the National Heritage Listing decision.
The timing of any National Heritage Listing is a matter for the Federal Environment Minister. Refer to previous discussion on this matter. No change to the PER is required.
3. The proposed road project was a “thought-bubble” of the former Premier Dave Bartlett, whose policy longevity was not one of his stronger points and whose understanding of nature conservation was, I suspect, limited to mowing his backyard.
The claimed origin of the project is incorrect. The original project – the Tarkine Drive was conceived prior to the tenure of the former Premier Bartlett, who served as Tasmanian Premier from May 2008 until January 2011. The September 2007 SCA Marketing report “The Tarkine Opportunity, Market and Customer Analysis”, prepared for the Cradle Coast Authority, refers to the Tarkine Drive (page 30). No change to the PER is required.
4. It was politically inspired and ill-conceived from the start.
This is opinion, with no reference to elements of the PER that require amending or further consideration.
5. It’s now widely perceived as an extravagance and a ‘waste of money’, especially at a time when funds are sorely needed to provide health, educational and Police services.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 20
This is opinion with no reference to elements of the PER that require amending or further consideration.
6. The TFD was originally a vote-buying exercise, designed to shore-up Labor votes in the Smithton-Circular Head region prior to the State election.
This is opinion, with no specific reference to elements of the PER that require amending or further consideration.
7. Upgrading these existing roads is really quite unnecessary for eco-tourism operators, and actually counter-productive to natural values protection.
The Cradle Coast Authority, Tarkine Discussion Group and many other industry stakeholders of the north west region would disagree. Refer to previous discussion on why the upgrade is required and what it will facilitate. No change to the PER is required.
8. The TFD will primarily benefit mining and logging interests (not eco-tourism).
Refer to previous discussion on the rationale for the Tarkine Forest Drive. No change to the PER is required.
9. The name (like the so-called ‘Western Explorer’ goat-track near-by) is ‘gilt-lining’ mining/logging road in the Tarkine, and tourists will soon see through the deception.
This is opinion, with no reference to elements of the PER that require amending or further consideration. No change to the PER is required.
10. Tourists do not like being ‘deceived’, and they will eventually boycott those regions and facilities and tell their friends.
This is opinion, with no reference to elements of the PER that require amending or further consideration. No change to the PER is required.
11. The scientific argument that bitumen roads are inappropriate in nature conservation areas (as more bitumen means more roadkill - humans as well as animals) has been totally ignored in this document, as unfortunately in the conception of the project.
12. Measures to reduce / and or prevent Devil and other Threatened Species roadkill are not adequately addressed.
A significant portion of the PER and the background investigation effort has been devoted to dealing in detail with these matters. The level of background survey work, trial sites and mitigation effort sets a new benchmark for managing road kill in Tasmania. No change to the PER is required.
13. The anticipated TFD users’ aspirations are not addressed.
The Tarkine Forest Drive is the first part of a tourism development strategy for the region and includes the upgrade of some existing tourism facilities – these are outlined in the PER. Importantly, the project will be the catalyst for further tourism ventures developed by private investors, existing tourism operators and other key stakeholders of the north west (such as the Cradle Coast Authority and the Councils of the region) as well as wider development in the region. No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 21
14. The ‘no action’ option is not adequately addressed.
The Tarkine Forest Drive is a high priority community project. Community expectations are for the original funds allocated to be expended in the area to boost the economy and jobs.
The “no action” option will result in no change to the current situation – the regional tourism benefits will not be realised, the rate of roadkill on the roads as a result of others current and proposed land uses will continue unabated. If the project does not proceed, these multiple benefits (which are quantified in the Benefit Cost Analysis) will not be realised. There is no “no action” option. No change to the PER is required.
15. Community scrutiny is not addressed.
The Tarkine Forest Drive and its predecessor have been through an extensive community and stakeholder engagement processes. This has included community information sessions, industry briefings (including the North West Regional Tourism Forum, the Circular Head Tourism Association, the Smithton Progress Association, the Advance Burnie Committee and a number of North West businesses), Council briefings and extensive and ongoing briefings for the Tarkine Discussion Group, hosted by the Cradle Coast Authority. No change to the PER is required.
16. Given its track record, expecting the Department of Infrastructure, Energy and Resources (DIER) to undertake a project of this kind ‘sensitively’ is problematic.
This is opinion, with no reference to elements of the PER that require amending or further consideration.
17. Much of the funding for this project should be re-directed elsewhere as a matter of urgency. For instance, at the Black Range look-out overlooking the Vale of Belvoir on the DIER-managed tourist road to Cradle Mountain, it’s a sad indictment of the State Government’s priorities (and those of DIER too, I must say) that tourists have to step over and around so much human faeces to take a photograph of the iconic view. A similar situation exists at Moina.
This is a matter for State Government policy and is not relevant to the PER.
No change to the PER is required. 3.5 Submission 5 - The Tarkine National Coalition As a preliminary comment, DIER notes that the submission from the Tarkine National Coalition is considerably at odds with statements that were made on at least two occasions to DIER by the Tarkine National Coalition’s Campaign Director – Scott Jordan. At the following two sessions, key aspects of the Draft PER, in particular the roadkill mitigation strategy, were conveyed to Mr Jordan: 12th September at Tall Timbers, in Smithton, in the presence of the Tarkine Discussion Group 31st October at the TNC offices in the presence of a north west wildlife expert.
On neither occasion did Mr Jordan express dissatisfaction at the results of the rumble strips or the mitigation strategy proposed more generally. On both these occasions his stated concerns were limited to wishing to see comparative roadkill data on light coloured verses dark coloured pavement on the existing DIER network.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 22
It should also be noted that an additional presentation to members and a selection of the Board of the Tarkine National Coalition occurred on the 31st October at the TNC offices. Throughout that 3 hour discussion no concerns were raised for which DIER could not satisfactorily respond and there was general acceptance of the measures being proposed in relation to roadkill.
The TNC submission in its introduction and conclusion states that the PER is inadequate and should be resubmitted. The scale of the specific comments, however, are confined to detail in most part and certainly do not provide justification for this extreme view.
DIER has undertaken extensive consultation with the TNC in its planning of the Tarkine Forest Drive project and finds it disconcerting that advice and comments provided by the TNC to DIER in face to face meetings have been subsequently contradicted in the TNC’s written submission.
The Tarkine Forest Drive Road Upgrade is likely to have significant effects on a number of threatened species. The referral documents do not adequately spell out proven mechanisms by which these impacts would be managed or mitigated, instead referring to an adaptive management strategy reliant on further implementation of unproven measures. Given the significance of this area as habitat and in the case of the Tasmanian devil, the importance of this intact disease free population, it is critical that any assessment of projects is made on the basis of provable and tested measures. The PER provided is reliant on assumptions, and in some cases flawed information, and as such is not an adequate report for consideration and should be rejected, with the onus on the proponent to resubmit a new application (and be subject to a public comment period) should they conduct the necessary trials in the future.
This submission fails to provide any evidence as to which assumptions or information is flawed. In the absence of this it will only be possible to respond to the submission author’s interpretation of the adaptive management.
Because of the complexities of habitat distribution and the dynamics of wildlife populations and behaviour and the inevitable variety of vehicles and driver motivations and experience (some careful, some not, some capable, some not), there can be no single, fixed mitigation solution. Management and mitigation measures should adapt to the findings of ongoing monitoring that measures their effectiveness over time, with the aim of steady and progressive improvement, using an adaptive management approach.
Adaptive management is a systematic process for continually improving management by learning from outcomes. The concept of adaptive management was developed in the 1970’s. Its goal is to develop optimum management while avoiding major crisis (Allan 2002). Adaptive environmental management recognizes the complex and interrelated character of ecosystems, with flexibility stressed within the process to account for any changes in conditions or the emergence of new evidence (Briassoulis 1989, Lawrence 2000). It provides a means to continue to manage and benefit in the face of uncertainty (Allan 2002, Briassoulis 1989). Because of the complexities of natural systems, predicting their response over the long term to up-front management measures is difficult. The best way to optimise those measures is to allow them to evolve in response to observations, to learn from experience.
Importantly, adaptive management is not a random trial and error process, but involves systematically monitoring outcomes to test assumptions. Broadly, it involves an evaluation of the issue, the development of a concept of what is occurring and what appears to be needed, followed by the implementation of initial management measures and then the monitoring of their outcomes. Importantly, the next stage involves comparing the results with the predictions and developing an understanding of what works and why, and also what does not work and why (Salafsky et al 2001).
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 23
By monitoring before, during and after the disturbance, we are able to learn how the natural system responds to the changes, so that the process can be fine-tuned through subsequent interventions. Adaptive management addresses criticisms of conventional environmental management practices which often do not allow for the uncertainty of outcomes from policy implementation (Allan 2002, Ladson and Argent 2002, Salafsky et al 2001).
Adaptive management provides a means to gain a better understanding of a system while that system is being actively managed.
This process has merit with the unpredictable nature of environmental management, including roadkill, and has therefore formed the basis for the roadkill background investigations, analysis and management plan design for this project.
No change to the PER is required. Fauna: Tasmanian devil Sarcophilus harrisii (listed as Endangered at both the national level and state levels). The threat to the Tasmanian devil is well documented in the Northbarker Ecosystem Report. The proponent has failed to present a convincing and provable mitigation program that would address the risks of increased road kill. As the last refuge for disease free Tasmanian devils, the Tarkine must not be used as a testing ground for theoretical or unproven mitigation measures.
The latest distribution mapping for the extent of DFTD shows that DFTD affects 75% of the state2. This includes significant area of south west and northwest Tasmania. It is misleading to describe the Tarkine as “the last refuge for disease-free Tasmanian devils”. The mitigation strategy proposed is based on an extremely robust: Baseline data collection Trial sites, designed, implemented and assessed via a Before-After-Control-Impact study design Risk based assessment of the entire route across a number of ecological and human (i.e. traffic) factors; and Significant literature review of similar studies elsewhere (64 separate Australian and International studies have been reviewed).
The following is taken directly from the North Barker Ecosystem Services (2009) report that accompanied the original 2009 referral:
“This species, which previously occurred on the Australian mainland, is now confined to Tasmania where it is widely distributed across all environments, but densities are very low in the southwest. The Devil Facial Tumour Disease (DFTD), first noticed in 1996, is a rare contagious cancer that is 100% fatal to animals that contract it, usually killing within 8 months. This disease has lead to significant declines in population (up to 97% in the far northeast of the State), resulting in a complete loss of mature individuals, with no animals over 2 years of age. The impacts of DFTD have resulted in the species being listed as Endangered under both the Tasmanian TSPA and the Commonwealth EPBC Act. Impact on the Tasmanian devil is considered to be potentially significant for the following reasons: • There is considerable potential for increased roadkill rates following completion of the road (this is discussed further in the section Roadkill below).
2 Save the Tasmanian Devil Program website. http://www.tassiedevil.com.au/tasdevil.nsf/Mapping-the- disease/A140AACCA1B1F6B0CA2576CB0011BD2C
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 24
• Animals with large movement ranges, low reproductive rates and low natural densities (such as devils) tend to be negatively affected by roads and traffic (Fahrig and Rytwinski 2009).
The Tarkine remains the last refuge for disease-free Tasmanian devils. Compromising this refuge significantly increases the likelihood of extinction of this iconic species in the wild. In particular the original 2009 referral document states:
“The devil facial tumour disease (DFTD) is the single most significant cause of mortality and consequent threat to the conservation of the Tasmanian devil. The retention of naturally occurring disease free populations is a key factor in ensuring the long term survival of the specie in the wild. Any activity that may increase the risk of accelerating the spread of DFTD into areas currently disease free may be considered as having a significant impact on the species.”
“Construction of the proposed road, and in particular construction of new bridges across the Arthur River, may increase the mobility of devils (i.e. increase their ability to range from north of the Arthur River to south of the river) and hence increase the spread of the disease into areas that are currently disease free.”
The 2009 Tarkine Road Project referral was withdrawn. The current project is different to the 2009 proposal, and so the original referral and the 2009 Northbarker report is not relevant to the current proposal. The author of this submission has clearly overlooked the relevant Northbarker report (2011), included in both the referral and also the PER.
Although some of the statements of fact from the 2009 project remain correct, the assessments of impact are no longer relevant. The comment on construction of road and bridges cannot be considered as the new road sections assessed in 2009 have been withdrawn along with the new bridges that were included.
No change to the PER is required.
The experience of the sealing of the Arthur River road saw an increase in Tasmanian devil road kill despite substantial mitigation measures. Raw data obtained from G. King (the source of the data used for the Landscape Impressions (2008) report quoted) showed an increase in Tasmanian devil road kill from 12,13 and 18 kills in the pre-construction years (mean = 14.3) 1999-2001, going to 33 and 17 (mean =25) in the construction years 2002-03, and 20,35,23,28 and 31 (mean = 27.1). This equates to a near doubling of Tasmanian devil road kill on the 12.8km section that was sealed.
This assertion is in direct conflict with the Landscape Impressions Report conclusions. The report notes an upward trend, not a doubling of Tasmanian devils roadkill. The report notes that “more data and modelling would be required to determine if this increase if significant” (Thompson 2008). The report concludes:
“Our analysis of the data suggests that the sealing and widening of the road has had little impact on the rate of road mortality for the spotted-tailed quoll or Tasmanian devil.” (Page 42, Thompson 2008) While roadkill on Arthur River Road may have increased as a result of the works there, to assert that it is a near doubling is not supported by the statistical analysis undertaken by the independent consultant charged with assessing the results.
No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 25
The Landscape Impressions (2008) report recommended:
“Through the process of completing this assessment report, it became evident that there is likely to be a common problem in relation to the planning and design of road works through environmentally sensitive areas: there is a lack of baseline data on road kill. Without comprehensive and complete baseline data, over at least a five-year period prior to major works, there can be little chance of accurately assessing the impacts of the works on wildlife. Furthermore, without this knowledge the planning and design of mitigation works (such as underpasses) cannot be comprehensively undertaken. Therefore, it is recommended that more comprehensive and complete road kill monitoring be considered as a core activity by land management agencies, particularly where there is likely to be future development in respect to the road network. A case in point is future road development in the Tarkine in North West Tasmania.”
This recommendation has been ignored in the preparation and submission of this referral, with only limited surveys conducted to date. This is clearly unacceptable in any circumstance, but particularly so in the case of this PER, coming three years after the original (withdrawn) referral.
The need for robust baseline data was recognised by DIER at the outset of the project (in 2009) and this is why roadkill and animal abundance data was collected over a 12 month period. To suggest that only limited survey work has been undertaken is inaccurate.
The survey effort for the Tarkine Forest Drive included weekly surveys from October 2009 to September 2010 plus three sets of 21 daily observations, over a six-month period (during Oct 2009, Jan 2010 and Mar-Apr 2010).This has been followed by a fixed point monitoring of trial hot spots using remote sensor cameras supplemented with 8 weeks of roadkill surveys. The entire route has been inspected for evidence of vertebrate carnivore activity (tracks and scats) on more than one occasion. This information has been used to inform the Roadkill Minimisation Plan.
The roadkill data that was collected was analysed and determined to be a sufficient quantity to allow robust analysis. It is not feasible in most development situations to collect 5 years worth of background data. The adaptive management proposed sufficiently mitigates any perceived risks with lack of background data.
No change to the PER is required.
Inadequate mitigation trials consisting of only one treatment scenario (rumple strips + roadside clearing + signage) on existing road sections in the vicinity (both sealed and unsealed sections of road exist) do not allow any real confidence to be expressed in the ability to lower the incidence of roadkill. The combination of measures seems to have had a dramatic effect, however the short 8 week trial was conducted in the tourism low season. The trial also may have been compromised by removal of at least one Tasmanian devil carcass by a well meaning road user (this person contacted TNC, who passed the information onto DIER) that is not recorded in the monitoring results. The combination of measures in this trial may also give a false level of confidence, as any effect from the road clearing is unattributable, and there is an assumption that roadside clearing will be continuous, a position that is contrary to the experience in rural and remote area roads. Also unknown is the effect of the new signage, and whether the effect (if any) is maintained over a period past the initial 8 week trial. The 55% reduction in roadkill at the sites within the mitigation trial is encouraging, and further trials should be conducted to test the longevity of the impact, and to attempt to isolate effects of discrete measures.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 26
This submission fails to comprehend the design or analysis undertaken for the trials. The analysis indicates that there was reduction in roadkill of over 50% at better than a 99% confidence – this means the observed reduction in roadkill produced by this trial would likely to happen by chance alone 1% of the time. The data was deemed by the statistician to be of very high quality – refer to Appendix I of the PER. The treatment sites were randomly chosen from natural pairs. This is a very rare situation in ecological studies. It enables the distinct benefit of providing some surety that any changes detected are due to the treatments applied and not due to the specifics of any particular site.
It is incorrect to suggest that the trials were undertaken in the tourism low season – the trials commenced in late February and ran for 2 months. The winter months of June, July and August are well known to be the tourism low season in Tasmania. Of more importance in selecting the trial period was when Tasmanian devils are known to be most active. Most mating occurs from February to March and the young are weaned mid-December to early February, at about nine months, and then leave the maternal den (DPIPWE 2010). The timing of the trials was entirely appropriate.
The removal of a single carcass (location not specified) would not have compromised the study. One of the treatment sites experienced a reduction from 30 road kills before to 8 after the treatment – demonstrating the effectiveness when all species are considered. Looking at Tasmanian devils in isolation (it should be noted that the numbers are too low for this to be considered statistically reliable) the control sites experienced one Tasmanian devil roadkill during the “before” and one during the “after” survey period – i.e. no change in road kill. The treatment sites experienced 3 before and none after. Even if the reported carcass was removed from a treatment site, then the results still indicate a 2/3 reduction in Tasmanian devil roadkill.
The trials were successful, and which measures contributed to a greater or lesser degree is immaterial, as all measures put in place at the trial sites will be implemented as a package at the known roadkill hotspots on the Tarkine Forest Drive.
The implementation of improved roadsides (moderate verge vegetation clearance in comparison with what currently exists and improved drainage) is well documented as an important mitigation measure and does not warrant a specific trial in isolation. The roadside clearance does not rely on significant on-going maintenance, and therefore there is no “assumption” that continuous clearing will be required. Rather the clearance proposed is as a result of the improved cross section (wider road) over much of the route. The areas of clearance will be surfaced with medium to discourage vegetation growth. The spatial distribution of natural resources is the main reason why animals venture onto roads, where they may be killed. Animals are struck by vehicles while trying to reach food, water, den sites etc (Coffin 2007). Wildlife movements (and their interaction with roads) tend to be linked to specific habitats, adjacent land use types and topography, with roadside vegetation being one of the most commonly identified attributes associated with roadkill (Taylor & Goldingay 2010).
The data collected and analysis undertaken to date has been extensive and is considered appropriate to design a robust mitigation strategy. In the unlikely event that elements of the strategy are not successful, the routine monitoring and adaptive approach will ensure that this can be rectified in a timely manner.
No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 27
Alternate mitigation treatments remain untested however. We have great concerns over applying a ‘best guess’ approach, particularly where there is sufficient opportunity to test mitigation measures. Despite good intentions and what was considered at the time to be the best available advice, the sealing of the Arthur River Road and the Cradle Mountain Road have had disastrous impacts on Tasmanian devil and Spotted tailed quoll.
The results of the Cradle Mountain Road works have been discussed in a previous response and demonstrate both that and this submission to be inaccurate on this point. In the absence of definitive statistical confirmation on the outcome of the Arthur River Road improvements the submitter’s claim that the results have been disastrous is very subjective and unsubstantiated by the evidence.
For the Tarkine Forest Drive project, DIER has committed to a comprehensive and responsive adaptive management framework to react to any new roadkill and mitigate roadkill risk. Please refer to the previous discussion on the benefits of adaptive management. This mitigates any perceived residual uncertainty.
No change to the PER is required.
We believe that the following assumptions remain untested: That light coloured pavement lowers roadkill. That alternating between light and dark pavement increases the effect of light coloured pavement in locations where it is applied.
Improving visibility along roads is recognised as a method of giving animals and drivers a greater opportunity to avoid collision (Hobday & Minstrell 2008). Light coloured road surfacing was suggested as potentially useful by Magnus (2006). Light coloured pavement may decrease roadkill due to increased visibility because most animals will be more visible on a lighter surface compared to a dark surface. Most Tasmanian wildlife is dark in colour and animals may feel uncomfortable spending extended time on a light coloured road surface due to their increased exposure (Jones 2000, Magnus et al 2004, Magnus 2006).
This is further supported by a study undertaken in 2010 by Hobday, where it was found that animal colour is a greater determination of night time detection distance than animal size (Hobday 2010).
During the Tarkine Drive Vertebrate Carnivore Assessment Forum it was suggested that there is evidence that road pavement colour can influence the incidence of roadkill.
It is unlikely that light coloured pavement will not reduce the incidence of road kill, but if that is shown to be the case, then this will be picked up in the routine weekly monitoring and rectified by alternative mitigation solutions.
The alternating of light coloured pavement, or more correctly selective use of light coloured pavement in higher risk areas, is likely to have some impact on driver behaviour – it creates a unique and unfamiliar driving environment and a very obvious cue to encourage most drivers to utilise caution. Importantly, when combined with the signage, other measures and public education programs it provides a tangible warning for when drivers are entering a wildlife zone.
No change to the PER is required.
The success of the rumble strip trials were in conjunction with roadside clearing, there is a need for identification of what quantum of the effect was from rumple strips or from roadside clearing.
Please refer to previous discussion. No change to the PER is required.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 28
That the absence of scats at roadside sites is counter-indicative of crossing hotspots. Tasmanian devils have a tendency to use clearly identifiable latrines, however there is no evidence to suggest a preference or otherwise for roadsides as latrine areas. It is possible and likely that crossing hotspots may have been missed due to absence of latrine sites on roadsides.
The PER does not suggest that locations of latrines constitute crossing hotspots or that areas with no such latrines are not crossing hotspots. The presence of scats indicates that there is some Tasmania devil activity in these locations. The activity hotspots have been determined by confirmed Tasmanian devil sightings during the headlight surveys. The determination of locations for mitigation treatments on the basis of animal abundance has been reconsidered in light of some informal advice from a local wildlife expert. For a full discussion refer to the relevant section later in this document.
No change to the PER is required.
It is essential that these assumptions be tested in suitable trials as they form key parts of both the planned mitigation measures, and the adaptive management measures. There should also be trials of any other measures the proponent may utilise (at this point only vague references to adaptation are given).
Please refer to previous discussion regarding the purpose and benefits of the adaptive management strategy.
No change to the PER is required.
TNC also has concerns that the frequency of roadkill surveys may be misrepresented in the PER, with the reference to 12 months of data collection not clearly identifying that the collection being a weekly count of carcasses. It is acknowledged by the proponent that the current Tasmania devil population ensures that carcasses are usually consumed overnight, and so weekly surveys under represent the true number of roadkill carcasses. Ironically, the absence of carcasses can indicate a higher level of Tasmanian devil activity.
This is incorrect – please refer to page 40 of the PER, where it clearly outlines the scope of the study. An error has been noted in the description of the survey undertaken south of Arthur River township (which is discussed in the next section), otherwise the PER is very clear about the scope of the roadkill survey.
This error has been corrected in the PER.
At no stage does the PER assert that the data collected represent roadkill for 12 months; clearly it is a method to sample roadkill across a 12 month period.
The PER also fails to address measures to prevent transmission of the Facial tumour disease across the Arthur River. It appears that commitments given to implement measures to deter Tasmanian devil’s crossing the bridges across the Arthur river (gate systems, sonic deterrents) have been abandoned by the proponent, despite early assurances that these measures were achievable.
The Tarkine Forest Drive does not construct any new bridges across the Arthur or any other river. Nelsons River Bridge and Rapid River Bridge are existing timber bridges that will be replaced. The Tarkine Forest Drive is currently completely contained in DFTD free areas (according to the Save the Tasmanian Devil website www.tassiedevil.com.au). In meetings after the submission of the draft PER, such measures were discussed between DIER and the TNC and DIER is indeed investigating the installation of such deterrents on its bridge at Arthur River township and the two other bridges owned by others.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 29
No change to the PER is required.
Spotted-tail quoll Dasyurus maculatus subsp. maculatus (listed as Vulnerable at the national level and Rare at the state level). Similarly to the Tasmanian devil, the presence of road kill attracts the Spotted-tail quoll to the road and increases it’s likelihood of being hit by traffic. As reported in the Vegetation Survey and Fauna Habitat Assessment, local populations have been dramatically reduced by previous roading projects. Local impacts are inadequately known, as is referenced in the Landscape Impressions (2008) report: “The core habitat of this species, listed as vulnerable on the Commonwealth EPBCA and rare on the Tasmanian TSPA, is generally described as lowland, high-rainfall forest across the north of Tasmania. The species utilises forest areas with suitable nesting sites such as hollow logs or rocky caverns as denning habitat. Hunting habitat can include non forest and regenerating forest areas adjacent to suitable denning habitat. Construction of the proposed road is unlikely to have any significant impact on either hunting or denning habitat of this species but there may be an increased impact from roadkill.” The risk assessment does not refer to additional risks posed by increased fire potential resulting from the road, and therefore does not adequately assess impact on hunting or denning habitat.
The threat of fire has been discussed within the PER (section 5.3.7), although it is noted that the risk of such random events cannot be quantified. The Tarkine Forest Drive does not facilitate access to areas that cannot already be accessed. It does increase the opportunity for a greater number of people to access the area – with more people comes more risk, but also more passive surveillance. In addition, interpretation signage in relation to wildfire and cigarette disposal receptacles will be installed at key tourist stopping areas along the Tarkine Forest Drive. Wood burning barbecues will be removed at Julius River Reserve and replaced with gas barbecues.
Suitable barriers (for example locked boom gates) will be installed on key Forestry Tasmania spur roads to block access to fire sensitive areas.
No change to the PER is required.
Eastern-barred bandicoot Perameles gunnii (listed as Vulnerable at the national level but not listed at the state level). Threatened by increased traffic and increased fire risk. The PER refers to a three year study that indicates no local populations of Eastern barred bandicoot. This is a misrepresentation of a ten year roadkill study, in which there were three years where Eastern barred bandicoot were not found in the survey data. This sort of misrepresentation is clearly unacceptable and calls the entirety of the PER assertions into question.
It is not evident within the Landscape Impression Report that any eastern barred bandicoots were recorded and we do not have the original data set. The Natural Values Atlas shows the nearest records as occurring in Bond Tier, 18 km north east of Arthur River township (figure 4.12 of the PER). The eastern-barred bandicoot is not listed in Tasmania under the Threatened Species Protection Act 1995. Habitat clearance and predation are identified as key threats in the SPRAT profile. There is no mention of roadkill. In any event, to ensure there has been no misrepresentation, the relevant statements regarding the Landscape Impression Report (as it relates to eastern barred bandicoots) have been removed from the PER (page 69).
The PER has been updated accordingly.
Wedge-tailed eagle Aquila audax subsp. fleayi: listed as Endangered at both the national and state levels. Wedge-tailed eagle are known to take road kill carcasses from roads, placing themselves at risk. An increase in road kill will create more opportunities for Wedge-tailed eagle to be struck by traffic. Unnatural mortality from collision with vehicles is listed as one of the biggest
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 30
threats to the species (Threatened Species Section (2006). (Threatened Tasmanian Eagles Recovery Plan 2006-2010. Department of Primary Industries and Water, Hobart). Assertions as to the presence of nest ignore the fact that nest are not at risk from this proposal, where feeding eagles are.
The PER deals with risk of roadkill for all species. Table 5.3 highlights the risk of roadkill to wedge tailed eagles and section 5.6.5 discusses it in more detail. Table 6.1 outlines the proposed mitigation actions and section 6.6 details the mitigation measures proposed. The extensive mitigation measures will keep total roadkill to its current levels. This will ensure that there is no increase in carcasses for foraging species, such as the wedge tailed eagle.
No change to the PER is required.
Flora: The following threatened flora are listed in the referral document. Caladenia dienema windswept spider orchid: listed as Critically Endangered at the national level and Endangered at the state level.
Corunastylis brachystachya shortspike midge-orchid: listed as Endangered at both the national and state levels. Diuris lanceolata large golden moths: listed as Endangered at both the national and state levels.
Prasophyllum favonium western leek-orchid: listed as Critically Endangered at the national level and Endangered at the state level.
Prasophyllum secutum northern leek orchid: listed as Endangered at both the national and state levels.
Pterostylis cucullata subsp. cucullata leafy greenhood: listed as Vulnerable at the national level and Endangered at the state level.
Pterostylis rubenachii Arthur River greenhood: listed as Endangered at both the national and state levels.
The following species were omitted from the list in the referral documentation, but are known to exist in roadside verges in the project area.
Prasophyllum pulchellum (critically endangered), Prasophyllum rostratum (endangered), Caladenia caudata (vulnerable) Pterostylis ziegeleri (vulnerable)
All are EPBC listed endangered orchids occurring on the road verges of Temma Rd and Rebecca Rd.
Insufficient survey work has been undertaken (3 days), and so this list cannot be considered comprehensive, and as such is inadequate to allow proper assessment. It is considered likely that additional listed flora will be identified in further survey work, and the failure to consider these species ‘likely to occur’ in this application is negligent on the part of the proponent. Of the listed flora, all are at risk from increased risks of both fire, illegal off-road vehicle use and introduction of disease and weeds. The risks discussed in the PER documents, however, limit the discussion of risk to the immediate construction, and fail to consider these issues as the legacy of the road construction. Concerns expressed by Nigel Swarts (Tasmanian Botanical Gardens) are reproduced below;
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 31
With regards to the survey, I can appreciate the methods that were employed as this seems to be the only way to cover an area as large as this and the timing seems correct to capture most species. However, there is no doubt there are limitations to the survey, mostly attributed to the seasonal nature of orchid flowering, their inconsistent re-emergence patterns, higher incidence after a fire (particularly in that area) and due to their cryptic nature many individuals will be missed. These limitations can only be overcome by extremely thorough surveys repeated on a fortnightly basis during peak flowering over multiple seasons. Certainly not in the job description of the consultant. That said, making recommendations or assessment of impact on the basis of such limited data is difficult but also maybe quite incorrect. In my opinion, the impact of increased road activity, changed runoff patterns, disturbance attributed to road making is likely to be underestimated for all species identified. There must be mention of impact on the state listed D. palustris also (perhaps in the DPEMP). Any impact assessment must consider the impacts of these activities on mycorrhizal presence and function on all species, pollinator presence and function for C. dianeama and possibly the Pterostylis taxa. The above ground pollinator requirements and below ground mycorrhizal fungi requirements are essential to the ongoing survival of these orchid populations. As I mentioned earlier there is a paucity of data in the relevant literature to predict how these activities may impact the orchids and their biological associates. In some instances disturbances may be beneficial and promote flowering and recruitment events. The mitigation proposed will no doubt go some way towards safeguarding the orchids, however I think that more needs to be done given the risk to the EPBC species listed. It must be remembered that these species are severely restricted in their distribution, have extremely narrow habitat tolerances and any loss of habitat is likely to be detrimental to the species.
From an insitu mitigation perspective there is not much more to recommend than exclusion zones, however I would expect that at least a four year monitoring program is implemented where populations of EPBC species (and D. palustris) are monitored at least one season prior (for benchmarking) and three seasons post development. This must be compared to a reference population some distance from the road. This data is essential to determine the impact of disturbance and if more immediate intervention is required – such as hand pollination of flowers or translocation. Monitoring usually involves presence/absence and demographic data collection.
For C. dianeama, flowers are pollinated by male wasps which are deceived by pheromone cues. These wasps rely on nectiferous food plants for survival and are highly sensitive to ecosystem change. I recommend that natural pollination rates and wasp presence/abundance via pollinator baiting methods should be monitored as above.
There may be a risk of changed hydrology and water runoff to orchid mycorrhizal fungi. This can be determined by comparing mycorrhizal diversity and function before and after development. This involves DNA sequencing of mycorrhizal associates and fungal ‘baiting ‘ to determine presence/absence. This is something that should be considered. For longer term risk mitigation, I recommend that seed and mycorrhizal fungi be collected and placed in long-term storage for each of the species identified. These collections can be used for establishing living collections of genetically representative material for reintroduction in the event of population decline.
For Pterostylis rubenachi individuals that are to be taken, a translocation plan should be developed.
All these recommendations are based on strategies for orchid recovery identified in the recently revised Tasmanian Threatened Orchid Recovery Plan. I am happy to discuss these recommendations further.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 32
The north west coast of Tasmania between Marrawah and Temma is subject to regular, extensive, on-going and thorough surveys by a number of parties. It is frequented by amateur botanists and orchid enthusiast as well as professionals; a targeted threatened orchid survey was undertaken of likely habitat in 2008 as part of the Orchid Recovery Plan (ECOtas 2009).
This means that the information on the distribution of orchids in this area is comprehensive. This is reflected in the data on the Natural Values Atlas from all times over many years. Sites include several well known roadside locations such as Tiger Flats but also other sections of heathland each side of Temma Road. It is misleading to claim that data and conclusions are simply based on ‘3 days of survey work’. The work has been of a very high standard.
Threatened Plants Tasmania, a community group committed to the study and protection of threatened flora, have been active in this area, reporting on targeted surveys at Tiger Flats undertaken in 2010 and 2012 (TPT 2012). The results of this work have been used to confirm the limited impact (2 plants) to one species (Pterostylis rubenachii), known to occur in close proximity to the road, during the construction works.
It is incorrect to state that four species have not been referred to in the referral documentation.
Prasophyllum rostratum was omitted because it is not listed under state or commonwealth legislation as threatened and so does not qualify for consideration. The other three were all considered in Table 4.3 and determined to not be impacted. There are no records of Caladenia caudata from the region with the nearest record on the Natural Values Atlas being 160 km to the east.
A new record for Prasophyllum pulchellum has been reported for a location 200 m east of the Temma Road. In light of this information, this species is now assessed further in the PER.
With the accumulation of recent records for the area of some species, all threatened flora maps have been updated in Section 4 of the PER incorporating the most recent (as of November 2012) data on the Natural Values Atlas.
Diuris palustris is not listed nationally. It will be considered within the permit application process under the Tasmanian Threatened Species Protection Act 1995.
The assessment of impacts to threatened flora considers in detail indirect and cumulative impacts. The threat to the mycorrhizal health and condition of foraging resource (nectar plants) for pollinating insects is overstated. The environment is already bisected by an unsealed road. Arguably the long term consequence of a sealed road is a reduction in physical disturbance to the road shoulder and potential runoff.
Other human induced impacts are addressed in the PER Detailed investigations of the mycorrhizal diversity and function along with collections of seed and mycorrhizal fungi for long-term storage are considered unnecessary in light of the risk to operations from the project.
The PER is based on the currently published Threatened Orchid Recovery Plan. The recently revised Tasmanian Threatened Orchid Recovery Plan is not available for reference at this stage.
The PER has been updated as indicated above.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 33
The potential for weed invasion is high. Existing roading in this area shows weed invasion already occurring, and the opening of new roading is likely to extend the occurrence of weeds. Blackberry (Rubus fruticosus agg.), Gorse (Ulex europaeus), Spanish heath (Erica lusitanica), and Foxglove (Digitalis purpurea) are seen on existing roads in the area. In particular, foxglove and blackberry seem to be commonplace on existing roads, including new forestry roading, hinting at the high likelihood of new roading becoming infested.
Serious concerns are also held regarding the potential for spread of the pathogens into the area during and following constructon. Phytophthora cinnamomi (root rot fungus), Chalara australis (myrtle wilt disease fungus) and chytrid fungus are of particular concern. Previous experience has shown that new roading facilitates the spread of theses pathogens. In meetings with Mineral Resources Tasmania it was indicated to TNC that the construction of the Western Explorer road spread Phytophthora cinnamomi by an additional 12km into previously undisturbed areas.
There is no ‘new roading’ associated with this project. Weeds have been considered in detail in the PER. The entire route has been surveyed and weed locations mapped.
The contractor will be required to prepare a Construction Environmental Management Plan (CEMP). The CEMP will describe the construction management measures that will be required to be implemented by construction contractors as a condition of contract with DIER. The PER outlines the structure and contents of the CEMP, importantly Appendix C of the PER contains the Environment Protection Guidelines that will apply to the construction of the Tarkine Forest Drive. These include measures to manage introduced plants, pest and disease. Vehicle wash down stations are an important element of these measures.
No change to the PER is required.
In addition to these threats, the increased risk of wildfire caused by increased roading poses an unacceptable risk to the Tarkine’s heritage values. Human-induced fires whether by misadventure or arson represent a large number of fires in north west Tasmania. Fragile rainforest ecosystems within the Tarkine are highly susceptible to fire, and many rainforest flora do not regenerate after fire. As such, any increase in fire risk jeopardises the integrity of these ecosystems.
The threat of fire has been discussed within the PER (section 5.3.7), although it is noted that the risk of such random events cannot be quantified. The Tarkine Forest Drive does not facilitate access to areas that cannot already be accessed. What it does is increase the opportunity for a greater number of people to access the area – with more people comes more risk, but also more passive surveillance. In addition, interpretation signage in relation to wildfire and cigarette disposal receptacles will be installed at key tourist stopping areas along the Tarkine Forest Drive. Wood burning barbecues will be removed at Julius River Reserve and replaced with gas barbecues.
Suitable barriers (for example locked boom gates) will be installed on key Forestry Tasmania spur roads to block access to fire sensitive areas.
No change to the PER is required.
Illegal off road vehicles will also present an increased risk following new roading. Experience in this area has shown that new roading also results in a proliferation of illegal off road vehicle use, creating uncontrolled sites with direct damage to natural values, and an increase in fire risks. The combination of illegal off road vehicle use and the absence of effective policing or regulation already poses a high management threat to fragile coastal ecosystems and significant Aboriginal heritage.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 34
There is no new road proposed as part of the Tarkine Forest Drive. The project involves the sealing of existing roads. The current gravel roads provide sufficient access to the area for off road vehicles. The sealing of the road will introduce new and additional visitors to the area. These visitors are more likely going to be driving suburban vehicles and be attracted to the area because of its natural assets and therefore would be very concerned by illegal off-road vehicle access. The increase in visitation will bring with it increased passive surveillance of these sensitive areas. In addition suitable barriers will be installed to many of the spur roads reducing opportunities for illegal off-road vehicle use.
No change to the PER is required.
The lack of clearly identified visitor management also raises significant concerns with the project. The proposed road will increase access and is projected to increase visitor numbers to 100,000 without any additional resourcing for Parks and Wildlife to manage these areas (in fact major funding cuts were announced in recent months). A classic example of this under resourcing is the Arthur River camping grounds. For the past five years these sites have been without rubbish bins after PWS staff were forced to remove them due to an inability to devote stretched staff resources to emptying bins. This is a classic example of the Tasmanian state government’s negligence of heritage areas, and speaks of their capacity to deliver on appropriate management of the ongoing visitor issues should the road proceed.
The Tarkine Forest Drive Benefit Cost Analysis, September 2012 included, as Appendix D of the PER, estimated an increase from 30,000 interstate and overseas visitors in 2011 to 74,000 in 2025.
The remainder of this submission relates to Tasmanian Government policy and is not relevant to PER.
No change to the PER is required. 3.6 Other non-formal submission On the 31st October representatives of DIER presented the PER to the TNC and a local wildlife expert at the TNC offices in Burnie. This person has not provided a formal submission but he raised a number of points during that meeting that DIER wish to respond to. Three key issues were raised: 1. That there had been misrepresentation of the eastern barred bandicoot data contained in the Landscape Impression Report – this point was raised in the TNC in their submission and has been responded to previously within this document 2. That on page 40 of the PER it states that the area south of Arthur River township was monitored daily for roadkill for the entire 12 month period, when in fact monitoring did not occur at this frequency. This is correct - at the time Parks and Wildlife had agreed to undertake daily roadkill monitoring; however, this was not able to be achieved. The PER has been updated accordingly 3. The third point raised related to the questionable need for rumble strips in the area east of Kanunnah Bridge at the expense of additional mitigation measures on the west coast – on segment A in particular. This will be discussed further below.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 35
The eastern section of the Tarkine Forest Drive (from Tayatea Bridge to Kanunnah Bridge) can be characterised as follows: A lower speed environment than areas further west, due to road alignment The proposed speed limit in this section will be between 50 km/h and 70 km/h Generally expected to have lower traffic numbers than areas to the west The overwhelming majority of traffic is expected to be tourist traffic, with some occasional forestry or other work related traffic; and It is expected to have very little dusk to dawn traffic (as there will be predominantly tourist traffic on this section).
This renders this section of the route very low risk from a roadkill perspective. Indeed, in previous consultation sessions the TNC has expressed little concern over the upgrade of the road in this section.
In the Draft PER, section 6.6.5 discusses the presence of Tasmanian devil scats at many of the points where Forestry spurs intersect the Tarkine Forest Drive but, as the TNC quite rightly points out in their submission, latrines do not necessarily indicate a crossing hotspot and, given the very low risk of roadkill due to the traffic mix and speed environment, DIER has amended the mitigation strategy to remove the installation of rumble strip east of Kanunnah Bridge, while at the same time introducing additional rumble strips onto section A.
The PER has been amended at section 6.6.5, 6.6.6 and Appendix N to respond to these comments.
4. References Allen, C. (2002) An adaptive management background paper. Paper to the workshop “Adaptive management in Australian catchments: learning from experience”, Albury Briassoulis, H. (1989) Theoretical orientations in environmental planning: an inquiry into alternative approaches. Environmental Management 13: 381-392 Coffin, A. W. (2007) From Roadkill to Road Ecology: A review of the ecological effects of roads. Journal of Transport Geography. No. 13, pp 396 – 406 ECOtas (2009). Extension Surveys for Threatened Flora: Caladenia dienema and Prasophyllum favonium in the Arthur-Pieman Conservation Area; Chiloglottis trapeziformis in the Wynyard area; Thelymitra jonesii and Thelymitra malvina in the Rocky Cape National Park Area; Prasophyllum robustum in the Latrobe Area; Miscellaneous Findings of Other Threatened Species and Species of Biogreographic Interest. A report to the Threatened Species Section (Department of Primary Industries & Water) by Environmental Consulting options Tasmania (ECOtas) 11 February 2009 Department of Primary Industries, Parks, Water and Environment (2010). DRAFT Recovery Plan for the Tasmanian devil (Sarcophilus harrisii). Department of Primary Industries, Parks, Water and Environment, Hobart Hobday, A. J. & Mintrell, M. L. (2008) Distribution and abundance of roadkill on Tasmanian Highways: Human Management Options. Wildlife Research 35, pp 712 – 726 Hobday, A. J. (2010) Nighttime driver detection distances for Tasmanian fauna: informing speed limits to reduce roadkill. Wildlife Research 37, pp 265 - 272 Ladson, T., Argent, R. (2002) Adaptive management of environmental flows. Australian Journal of Water Resources 5: 89-102
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 36
Jones, M. (2000) Road upgrade, road mortality and remedial measures: impacts on a population of eastern quolls and Tasmania devils. Wildlife Research 27 pp 289 – 296 Magnus, Z. (2006) Wildlife Roadkill Mitigation Information Kit, A guide for local government and land managers. Sustainable Living Tasmania, Hobart, Tasmania Salafsky, N., Margoluis, R., Redford, K. (2001) Adaptive management: a tool for conservation practitioners. World Wildlife Fund, Washington Taylor, B. & Goldingay, R. (2010) Roads and wildlife: impacts, mitigation and implications for wildlife management in Australia. Wildlife Research 37, pp 320 – 331 Thompson, D. (2008) Assessment Report Arthur River Road EPBC decision 2003/93 Threatened Plants Tasmania (2012). Arthur River greenhood, Pterostylis rubenachii, population update at Tiger Flat. 27th October 2012.
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw 37
Appendix A
Public submissions
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw
Submission 1
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw
The Department of Infrastructure, Energy and Resources GPO Box 936 Hobart TAS 7001
Attn. Andrew Fowler
Re: A project to seal 92.7km of existing road and replacing 2 bridges along Tarkine Forest Drive to improve tourism facilities and facilitate greater visitation by tourists. Interested persons and organisations are invited to comment in writing on the Public Environment Report. Comments in writing must be received within 20 business days (no later than close of business 12 November 2012).
Andrew Fowler,
We, the undersigned, hereby lodge this written objection to the proposed project and provide in support the following most important reasons for objecting most vigorously. 1. We are totally convinced that the purpose behind these road improvements is to allow access for commercial activities, other than tourism. We are advised that under all the current Laws, irrespective of any World Heritage Listing, the state Government can still carry out forest logging and mining activities. For this reason alone, until these Laws are amended, this proposed heavy duty ‘all purpose’ road will be forever, at the risk of being used to exploit and ruin forever this vast natural wilderness area. Why not just leave the good existing ‘very useable’ roads and only upgrade any needed repairs to reach the same standard and repair or replace any bridges to the same ‘moderate’ standard? Thereby saving the State Government millions of taxpayer’s funds and allows the tourists to see the Tarkine Wilderness as it now is and how it should remain. The existing road not only slows traffic for visitors to view the beauty of the area but also protects the wildlife and must remain, as the last real Tasmanian natural wonder. 2. We are opposed to the way the Tasmanian State Government is being locked into these commercial aspects of business enterprises which is dramatically depleting the ability of this State Government from carrying out it’s proper Governmental obligations. This vast expenditure on such heavy duty highway construction works, will not allow the Police, Hospitals and Schools to return to the proper functional conditions which they were before the recent budget cuts were introduced. We keep wondering who is really running this State Government, is it the Public Service or Forestry Tasmania dictating what project is next, as was evidently happening when the Franklin Dam was designed and stopped by massive public disapproval. If this scenario is what really exists, then the State Government is simply asking for more trouble.
This is not any kind of threat, just our humble opinion, because that is how we view the situation that is developing. This project cuts right through any forest peace agreement.
We, the undersigned, oppose this monster road upgrade and will also protest vigorously.
Submission 2
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw
Submission 3
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw
Submission 4
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw
Submission 5
Ref: HB09080H002 Response to submissions 33P Rev 01/DL/jw