Letter 5 from TAP to RPDC re Directions Hearing

Executive Commissioner RPDC
GPO Box 1691
Hobart TAS 7001

Robert McMahon
Chairman of TAP Inc.

Dear Executive Commissioner

Re: Directions Hearing

Further to our letter of 10-10-06 seeking permission to attend and address the RPDC at the Directions Hearing, we also request permission to raise a significant point about economic modelling predictions.

A key objective of the legislative framework of RPDC is to facilitate economic development for Tasmania in accordance with sustainable development criteria. For credible decision making, the RPDC must assess the veracity of claims both scientific and economic, and ascribe a level of confidence (zero to high) to each of those claims.

There is a relatively transparent process operating for assessing claims made by scientific studies. For example, Toxicos’s own quality assurance checks revealed transcription errors affecting the published data for dioxins. Also, shortcomings in the methodology and therefore the level of confidence that can be attributed to claims, have been identified in the submission by the Tasmanian Fishing Industry Council consultant.

However, the transparency of economic modelling and claims made is altogether different. The Monash University / Allens Group economic model and its predictions of very substantial economic benefits for Tasmania are not open to scrutiny and independent assessment. We note that Allens Consulting Group disclaims responsibility for the model projections. It is not clear who is taking responsibility for the claims – the proponent Gunns or Monash University.

The importance of thorough independent assessment by the RPDC of the economic model cannot be understated since the claimed economic benefits are seen as a key driver for building the pulp mill. The validating body (Gunns or Monash) must be identified. The economic models and their predictions must be assessed for the completeness and representativeness of the parameters used, just as applies to any scientific sampling study. In addition, the accuracy of the input data must be validated and sensitivity of the output predictions to reasonable variations in assumptions must be described.

We believe that this data will come to light to some extent as potential financial backers of the proposed mill meet their obligations of duty of care to their shareholders and independently assess the viability of the proposal. It would be embarrassing to say the least if their analysis did not support the findings of the RPDC.

At the Directions Hearing, we request that the RPDC undertake to make a transparent and thorough assessment of the claims made by the Monash / Allens Group economic model and that this also be open to public scrutiny in order to assure all Tasmanians that our economic development is sustainable.

Yours sincerely

Robert McMahon
On behalf of TAP Inc. membership