We need your help to stop this.
We have put together a useful How-To guide for you to use when making your submission through the 'Have Your Say' portal.
To make your submission, you should head to the Department of Agriculture, Water and Environments website.
How to make a submission
We have put together a handy guide which will take you, step by step, through the submission tool.
We have also put together a pro forma answer, based off our assessment of MMG's referral, that you are welcome to copy and paste into Question 4.
Due to the word limit, we have used some acronyms and jargon (such as MNES - Matter of National Environmental Significance, or EIS – Environmental Impact Statement). Rest assured where we have used these they have an established meaning under the EPBC Act.
Our proforma is below:
Copy and Paste this into Q4.
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 10m2/25m2 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 attributes Brooker’s gum, but have only assessed known occurrences. Given numerous impact sites, the proponent should have surveyed these at a minimum. 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 company'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. Assertions that Devils were using the roadway as dispersal routes ignore the question of dispersal to where? 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 known to be present on the site and it’s surrounds. Members of the public were camped on the access road from December 2020 to May 2021 and heard calls throughout this time. The limited time dedicated to surveys of masked owl in the area is surprising given their admission that the project area is critical habitat.
Given the distinct and known locations of proposed works, it is unfathomable that 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. It is impossible for the Minister to be satisfied that there is no impact, or to determine the level of impact in the absence of survey data from the impact zone.
The flaws in the referral are fatal. No case can be made to accept this referral as complete. The referral must be declared clearly unacceptable.
You can find our guide here:
You can find the Department of Agriculture, Water and Environment's submission platform here.