Mr Julian Green
Executive Commissioner RPDC
GPO Box 1691
Hobart TAS 7001
Chairman of TAP Inc.
Dear Mr Green
Re: request for permission to make a late submission on Gunns draft IIS
We respectfully seek an extension of 45 days after 25th September 2006 to enable us to fully develop and complete our submission in response to the Gunns draft IIS.
Tasmanians Against the Pulpmill Inc. [TAP] is a community based, non-politically aligned group of residents from throughout Tasmania who share a common concern over the scale of impacts of the proposed Gunns pulp mill on livelihood, amenity, life- supporting capacity of our environment and the needs of future generations.
We understand the administrative imperatives of a defined closing date for public comments but feel that the difficulties flowing from granting an extension are minor given the enormous responsibility to get the best outcomes from the decision making process. We note that the proponent has already caused rescheduling with their revised project scope submission on 9 May 2005.
Although the period for public comment is the longest of any Tasmanian project, it is still highly restrictive in view of the extraordinary complexity and amount of information to review in the 7500 pages of the draft IIS.
Gunns state that the proposed pulp mill is the “largest ever” investment by the private sector in the State and will have a “pervasive economic impact on many businesses throughout Tasmania”. In consequence, the proposal demands the “largest ever” degree of scrutiny and evaluation by individuals, community groups and businesses.
The capacity of the community to provide a meaningful critique of the draft IIS is severely constrained by limited time and funds. As a Tasmania-wide group we are doing our best through raffles and private donations to assist the community to contribute to the RPDC. The expectation is that members of the community who wish to provide a response to the IIS will do so in evenings and weekends at their expense and without the benefit of independent data.
Our situation is typical of many in the public struggling to meet the deadline and a refusal to grant an extension would be unfortunate at best. Our submission will be severely curtailed, less thorough and less cogent, and well-resourced industry funded submissions will carry a disproportionate weight. It will increase the risk of failure to analyse the shortcomings of the draft IIS and lead to poor decision making with regard to the approval and appropriate conditions to be attached to the proposal. It leaves the RPDC open to accusations of poor management of the process and bias in favour of the proponent. None of these outcomes is helpful in meeting the objectives of the legislative framework of RPDC and promoting quality decision making for a sustainable future.
We look forward to your favourable response to our request.
On behalf of TAP Inc. membership