Shane Wells Alison Leake

Shane Wells From: Alison Leake Sent: Friday, 17 August 2018 9:49 AM To: Phil Barker Subject: FW: Comment: Prosser Plains Raw Water Scheme Tasmania (EPBC 2017/7927) Kind regards, Alison Leake Accounts North Barker – Ecosystem Services 163 Campbell Street Hobart TAS 7000 [email protected] 62 319788 From: Ben Waining < [email protected] > Sent: Wednesday, 15 August 2018 1:33 PM To: Alison Leake < [email protected] > Subject: Comment: Prosser Plains Raw Water Scheme Tasmania (EPBC 2017/7927) To whom it may concern, I am writing to provide comment on the proposed action by the Glamorgan Spr ing Bay Council to construct and operate a 3000 megalitre capacity water storage on the Tea Tree Rivulet. My concerns are related specifically to the risks posed by this development to the population viability of the critically endangered swift Parrot. T he swift parrot has been listed as critically endangered under the EPBC Act. The conservation advice issued by the Threatened Species Scientific Committee, established under the EPBC Act lists habitat loss and alteration as one of the key threats facing th e survival of the Swift Parrot. The proposed removal of known swift parrot habitat is an action that will have a direct impact on this critically endangered species. The proposed offsets do not alleviate this impact, as it still remains that there would b e a net loss of available habitat if this dam proposal was to go ahead. It is further noted with concern that the offset areas are not finalised. To further endanger a critically endangered species for the purposes of installing a dam shows a fundamental disregard for the sustainable management of our land. The GSBC are entrusted as the planning authority to make decisions that provide for the best outcome for all, including the environment and the species that inhabit that environment. An alternative appr oach to supplying water for commercial interests must be found that does not involve the further endangerment of our threatened species. yours sincerely Ben Waining. Land owner in the GSBC municipality. 1 Shane Wells From: Alison Leake Sent: Friday, 17 August 2018 9:46 AM To: Phil Barker Subject: FW: Comments Re: Prosper Plains Raw Water Scheme, Tasmania Kind regards, Alison Leake Accounts North Barker – Ecosystem Services 163 Campbell Street Hobart TAS 7000 [email protected] 62 319788 From: Gary Whisson < [email protected] > Sent: Wednesday, 15 August 2018 4:59 PM To: Alison Leake < [email protected] > Subject: Comments Re: Prosper Plains Raw Water Scheme, Tasmania Dear Phil, Please find attached my comments on the Prosser Plains Raw Water Scheme. I recognise that in futur e years the Orford region will be in need of an expanded water resource, both because of the growing population pressures, but also a likely increasingly unreliable rainfall - with or without servicing the Tassal requirements for fresh water. My comments and concerns are confined to issues of avoidance of impacts on significant terrestrial environmental values. As your reports clearly demonstrate, clearing the proposed Twamley Dam site to provide for the proposed water supply will necessarily cause the los s of environments that meet the criteria as Matters of National Environmental Significance under the EPBC Act (1999). Where possible significant impacts on Threatened species and Threatened Ecological Communities should be avoided. While Environmental Of fsets are proposed that meet EPBC Act requirements, offsets necessarily result in the progressive additional loss of the Threatened Ecological Communities and Threatened Species Habitat. That is they still represent a net environmental impact that should o nly be acceptable is other potential options are not available. While not identified as a Threatened Species or Ecological Community, it should also be recognised that the Twamley Dam will result in the clearing of some 20ha of Eucalyptus viminalis Grassy Forest and Woodland (DVG). This community is extensively cleared and highly under reserved, less than half of the JANIS criteria for 15% reservation relative to the original extent of the community. The TasVeg mapping referred to in the report notes that only some 6% of the DVG Forest type is reserves State wide, and some 6.5% in the SE Bioregion of Tasmania. It is notes, significantly that the TasVeg mapping only records the extent of Forest type relative to the mapped extent of existing remaining vegetat ion. As you will appreciate this will necessarily lead to the above percentages being a significant over estimation of the actual proportion of these vegetation types reserved relative to their original extent. This species also provides feeding habitat fo r Swift Parrots. 1 As such, the proposal to provide additional raw water resources to the Orford supply should have considered or presented potential alternative options in greater detail so that a judgement as to costs relative to environmental impacts can be made. I understand that Hobbs Lagoon - an existing water resource that Tassal has available to use has been identified as a potential alternative water resource, but is not specifically referred to in this report. As an existing water resource, this option would presumably not require extensive clearing of threatened vegetation communities, nor the associated impacts on breeding and foraging habitat of Endangered Fauna species. The Proposed Twamley Dam site is within the catchment of the existing of the Lower an d Upper Prosser Dams, as such it does not provide access to an additional water catchment, only serves to provide additional storage capacity within the catchment of the Prosser Dams, that can be released when needed. The option of raising the hight of the existing Prosser River dams. likely to be a much lower environmental impact alternative is briefly discussed and the argument is presented but effectively dismissed on the grounds that this is a higher cost option. No cost comparison is presented. It is n oted that the proposed Twamley Dam option is a "no or minimal cost" option because the GSBC is offering to bear the costs (at significant impact to Council Dept). The significance of this statement in determining the Twamley Dam as a lower cost option has not been explained and should be clarified. Regards Gary Whisson 2 Shane Wells From: Alison Leake Sent: Friday, 17 August 2018 9:47 AM To: Phil Barker Subject: FW: Comments regarding the Prosser Plains Raw Water Scheme Tasmania (EPBC 2017/7927) Attachments: Comment_Prosser Plains Raw Water Scheme Tasmania.doc Kind regards, Alison Leake Accounts North Barker – Ecosystem Services 163 Campbell Street Hobart TAS 7000 [email protected] 62 319788 From: Bec Donaldson < [email protected] > Sent: Wednesday, 15 August 2018 2:39 PM To: Alison Leake < [email protected] > Subject: Comments regarding the Prosser Plains Raw Water Scheme Tasmania (EPBC 2017/7927) Dear Sir/Madam Please find attached my comments regarding the Prosser Plains Raw Wat er Scheme Tasmania (EPBC 2017/7927). I look forward to these concerns being considered, to ensure no additional impacts on critically endangered swift parrot populations. Thankyou for this opportunity. 1 R Donaldson BSc (Hons) Dipl [email protected] 2 North Barker Ecosystem Services 163 Campbell Street Hobart Tasmania 7000 14 August 2018 To Whom it May Concern Thank you for the opportunity to provide comments regarding the proposed Prosser Plains Raw Water Scheme Tasmania (EPBC 2017/7927). The Referral documents associated with the proposed development (including expert opinions) identify unambiguously that the proposed action will have significant impacts on critically endangered swift parrots and their habitat. Given that regardless of three successive Recovery Plans, swift parrots are still declining rapidly towards extinction, and given that this decline is due largely to insufficient habitat and continued loss of remaining habitat, it is essential that no further habitat is lost. Below please see several concerns and points regarding the proposed dam: (1) The need to recognise that offsets which preserve *existing* habitat, to which swift parrots already has access, mean that the action still represents a net loss of habitat, at a time of critical endangerment for the species. Such offsets are blatantly insufficient to ‘offset’ the destruction of important habitat caused by the proposed development. Similarly, any proposed offsets or mitigations involving planting new habitat would not be sufficient to mitigate net loss of habitat in the time frames necessary for swift parrot recovery. (2) The need to consider Cumulative Impacts. (3) The need to consider impacts related to loss of future breeding trees. These points are expanded below. Referral documents agree regarding the significance of the impacts on swift parrots Document A of Referral documents, PPRWS Referral, under the heading “Offset”, states: The EPBC significant impact criteria indicate that this impact is likely to be significant. The criteria that are met are the "likelihood" to: 1. lead to a long term decrease in the population 2. reduce the area of occupancy of the species 3. adversely affect habitat critical to the survival of the species 4. modify, destroy, remove, isolate or decrease the availability or quality of habitat to the extent that the species is likely to decline. 5. Interfere with the recovery of the species. Referral document containing Expert opinion from Birdlife Tasmania states: I concur with the report’s conclusions that the area to be impacted is significant Swift Parrot habitat: …loss of the habitat is likely to cause a significant impact as per the EPBC assessment criteria, …loss of the habitat in the area under evaluation will disrupt the breeding cycle of a population and modify, destroy, remove, isolate or decrease the availability or quality of habitat to the extent that the species is likely to decline, and …the habitat is an important feeding habitat that supports breeding in the area.

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