NEW AND URGENT: Make a submission on the reconsideration of MMG's roading and clearing.

We’ve won a second chance for takayna’s Masked Owls.

Late Friday 13 May 2022, a week out from the federal election, the Minister for the Environment announced a reconsideration of her decision to allow MMG to undertake drilling and roading works ahead of building the proposed heavy metals tailings waste dump in Tasmania’s takayna’s rainforest. The ancient forests threatened by 14km of new roads, clearing for 165 drill sites is home to Tasmanian Masked Owl, as well as Tasmanian Devil, Spotted tailed Quoll and Wedge Tailed Eagle.

A reconsideration is a very rare thing, and has come about due to the amazing and untiring work on the ground by Campaigners, our science team, our legal team and the blockaders who have held MMG’s works at bay over the past 5 months.

But a second chance is not a guarantee, so we need to make it count. We have until 27th May 2022 to raise many public submissions in to the Minister to ensure whoever they are after the election, they understand the risks to our ancient rainforest and the endangered wildlife that call them home. You don’t need to be an expert to make a submission, and we’ve created this guide to help you through the process.

Next Monday, we will be announcing our plan to use our new political opportunity post-election to pressure our new parliamentarians on getting the right decision for takayna. 

We will be hosting a Zoom meeting next Wednesday evening at 6pm. You are invited to join us to hear more. 

Six Steps to Make Your Submission.

1. Head to the EPBC Have Your Say portal. 

2. Fill in your contact details.

3. Select 'yes' where it asks if you consider it a controlled action. A controlled action is one that cannot be taken without Federal approval. 

4. Explain your reasoning for why this action must be controlled, in less than 500 words. 

This must be restricted to Matters of National Environmental Significance as defined by the EPBC Act. Out draft submission will give you the information. Alternatively, you can cut and paste the draft submission into the box, or mo

5. Fill out the remaining privacy and declaration sections.

6. Click submit your comment, and then share this with as many people as you can.

Copy and Paste this into the box

The referral represents a significant impact on an area containing numerous MNES. The proponent withdrew the elements of this referral from referral 2021/8909, avoiding the need to provide a full EIS. This referral relies on data already deemed insufficient to make a determination on preliminary documentation, along with just four days additional survey work.

The proponent under-represents the footprint as being 14.88ha. Figure 2 shows, the various works are spread over an area encompassing the 285 hectares project area from referral 2021/8909. Impacts of 6m wide roading, or 10 x 10m/25 x 25m cleared drill pads represent fragmentation of a relatively intact landscape and increased risks of erosion, drying, fire, disease, weeds, and degradation of values that are to be assessed in referral 2021/8909.

The proponent under-attributes Brooker’s gum, only noting known occurrences of 7.14ha, where ground truthing by BBF found 12.41ha (a 74% under representation). For the identified areas, a 30m buffer is insufficient and unlikely to protect sites from disease, drying and increased risk of fire.

An eagle nest within 1km line of sight of proposed tracks and 500m of proposed tracks and works sites highlights the risks to this species. The proponent’s proposed management plan avoiding works during the breeding season ignores the fact that the roading and tracks created will be used to access the site for this proposal, but also for referral 2021/8909 facilitating long-term unmitigated impacts.

The proponent asserts that habitat is sub optimal for Tasmanian Devil and Spotted-tailed Quoll despite only four days of surveying, and having identified both scats and tracks on roadways within the site. The proponent seeks to dismiss it’s own data by asserting that Devils were using the roadway as a dispersal route. Three flanks of this area being bounded by the Pieman and Huskisson River impoundments, it is unlikely that animals were merely passing through. Denning or foraging remain the likely reasons for animals identified in the area. The proponent’s recommendation for post-approval surveys should not take the place of informed assessment of complete referrals.

Masked Owl is verified present on the site and it’s surrounds. The mitigation measures proposed by the proponent are inadequate. Masked owls are known to nest in trees of less than 1mDBH. No evidentiary basis is provided for a 15m buffer preventing nest abandonment or physical harm. An operating drill rig may reach 120dB (the equivalent of a jet aircraft).

Despite known locations of proposed works, the proponent has not conducted vegetation surveys of each of these sites. This demonstrates the same disregard for the EPBC Act that led them to proceed with illegal and unapproved works at this same site between May and July 2021 and currently on Helilog Rd (subject to referral 2021/8909). It is impossible for the Minister to determine the level of impact in the absence of data from the impact zone.

This referral was incomplete, and the decision that it was not a controlled action in error. The referral must be reconsidered a controlled action, and clearly unacceptable.


To make your submission, you should head to the the EPBC Make a Comment portal.