Mr Gerard Brown
ANZ Group Headquarters
100 Queen St Melbourne Vic 3000
We wish to draw attention to the impacts on threatened species from Gunns Ltd’s proposed Long Reach pulp mill in northern Tasmania and the role of ANZ as prospective principal banker.
We and the general public understand that the ANZ has serious obligations under the Equator Principles to examine the environmental aspects of the pulp mill project and the pipeline route.
Given both the serious shortcomings of Gunns’ data and ANZ’s Equator principles, funding should be refused.
Serious problems with Gunns’ road kill data
Gunns’ data through significant shortcomings in its completeness and the lack of replicate sampling checks by independent operators fails basic quality assurance standards and invalidates the conclusions drawn. It means that threatened species surveys must be redone to an acceptable standard.
The data set provided by Gunns is more than 80% incomplete.
- Data were not collected for 80% of the three month daily monitoring program as required by the Commonwealth Chief Scientist (Rec. 220.127.116.11). In addition, for the first six of twenty four sampling runs, data was collected over only 8010m or 24% of the total 32912m of the East Tamar Highway.
- Further, there is no data for any of the “major roads associated with construction, commissioning and operation” (Rec. 18.104.22.168) as required by the Chief Scientist. Major roads omitted from Gunns’ data include West Tamar Highway, Batman Bridge approach and the Bridport Highway.
- Whilst carcass photos were submitted by Gunns’ operative for identification confirmation, there were no independent replicate monitoring checks that test for missed roadkill animals. Independent verification is recognised as essential by testing laboratories to withstand scrutiny in a court of law eg NATA registered labs. Gunns data cannot withstand a legal challenge.
Since October 2007, Tasmanians Against the Pulp mill (TAP) have been conducting a daily roadkill monitoring program along 22kms of the East Tamar Highway to ensure accuracy and compliance by Gunns with acceptable standards of quality assurance and quality control. Our own data has been subject to rigorous standards of QAQC utilising photographic and GPS instrumentation and independently verified by Dr. Sally Bryant, Shannon Troy (Department of Primary Industry and Water - bandicoot expert), Carol Donelly (Devil Research - DPIW) and Lorraine De Weys (Swift Parrot Wildlife rescue & recovery).
Where TAP has independently confirmed fifteen carcasses belonging to threatened species out of a total of 656, Gunns have found only five out of 272. Refer to the link below, page 24, http://www.gunnspulpmill.com.au/permits/EIMP_Module_B_Mill_site_vegetation_clearing.pdf
Gunns’ assessment of the impact of its operations on threatened species is inadequate and poorly researched. The evidence shows that any development along the proposed East Tamar pipeline route is likely to have adverse impacts on rare and threatened wildlife.
Biodiversity significance of Doctor’s Hill
Gunns’ water pipeline as planned will traverse a biodiversity hotspot on the East Tamar. It will pass through private farmland and an area known as ‘Doctor’s Hill’, which is recognised for its unique flora and fauna. The Launceston City Council describes ‘Doctor’s Hill’ as ‘an Area of Regional Significance under the Launceston Planning Scheme 1996.’ The purpose of such an area is ‘to enable the protection of the area from development which would detract from or spoil its special features or qualities.’ Under Section 40.3 subsection (3) of that part of the Planning Scheme it is incumbent on Council to consider ‘any reports and recommendations on landscape, cultural or scientific qualities of the area’.
The proposed pulp mill project is deeply unpopular and there is strong opposition to the pipeline route by farmers and landholders. One farming family, strongly opposed to the pulp mill, owns more than 8 km of land that the pipeline is planned to traverse.
The pulp mill has not been subject to a proper risk assessment and the evidence points to it being environmentally unsustainable. It can survive only as long as MIS schemes and government subsidies exist. It cannot meet the benchmarks as set by the Equator Principles and as such, ANZ cannot consider it a viable proposition to finance.
We include a copy of a letter to Department of the Environment, Water, Heritage and the Arts in the appendix.
On behalf of TAP.
Cc Tasmanian Greens
Mr Neville Matthew
Acting Assistant Secretary
Compliance and Enforcement Branch
Department of the Environment, Water, Heritage and the Arts.
Re Gunns Ltd Pulp mill Assessment Condition 26. Roadkill.
I refer to our previous letter to your office dated 31/3/08, and note that as of yet there has been no reply.
As stated previously by both myself and TAP’s Dr. Rodney Ross, Gunn’s commitment to this module has been unsatisfactory, having not met the objectives set down by the Chief Scientist.
Gunns Ltd’s responsibilities under Condition 26 of the EPBC 2007/3385 states:
“To manage the risks to listed threatened species associated with roadkill, Gunns Limited must, in accordance with the EIMP:
a) Immediately following the date of this approval, establish baseline monitoring of roadkill along the East Tamar highway and other major access routes for construction.
b) Monitor roadkill and implement response strategies, as necessary, in accordance with the EIMP if the number of road killed mammals exceeds the trigger levels in the EIMP.”
Gunns Ltd has clearly failed to comply with the objectives set.
Condition 26 requires Gunns Ltd to establish baseline monitoring “immediately
following the date of this approval”. Approval was given on the 4th October 2007, but no results are recorded until 4th November 2007.
Condition 26 requires baseline data for “East Tamar highway and other major access routes for construction”.
The report submitted by geNAMES acknowledges on behalf of Gunns that they were only engaged to undertake a baseline monitoring programme on the East Tamar Highway between Dilston and Bell Bay.
It is important to note that no baseline monitoring has been conducted on other major access routes. Major routes other than the East Tamar Highway used for construction and supply of logs have been ignored. There has been no roadkill survey conducted on behalf of Gunns on the West Tamar Highway, Batman Bridge approach or the Bridport Highway.
Therefore the requirements of Condition 26 have not been complied with.
The Chief Scientist, in his report at 22.214.171.124 (www.environment.gov.au/epbc/notices/assessments/2007/3385/pubs/report-chief-scientist.pdf) made the following recommendation:
Baseline monitoring of roadkill along the East Tamar highway and other major access routes for construction should commence immediately. On a daily basis, the roads should be driven and all roadkill data collected, identified to species and the location recorded using GPS.
Three months of data before construction commences, analysed in relation to known seasonal variation elsewhere in Tasmania, is a minimum requirement.
A further recommendation at 126.96.36.199 of his report states:
Roadkill should be monitored daily along the East Tamar Highway and all other major roads associated with construction, commissioning and operation, with all vertebrates collected, identified to species, and locations recorded using GPS. Daily removal of all road killed vertebrates should be routine, to reduce secondary mortality of scavengers such as Tasmanian Devils (Sarcophilus harrisii) and Spot-tailed Quolls (Dasyurus maculatus maculates).
This is exactly what TAP proceeded to do, with one exception, no roadkill was removed.
TAP commenced its survey on 21st October 2007. The survey has been conducted, seven days a week, typically commencing between 7 to 8 am. It still continues. Our data comprises species identification, location from both local landmarks and GPS along with dated digital photos of specimens and locations.
TAP’s survey identified several threatened species, the Tasmanian Devil and the Masked Owl being two that are recognised as endangered. Examples of the Eastern Barred Bandicoot and Spotted Tail Quoll have also been found and recorded by TAP. Local veterinarians have attended to Swift Parrots from the Highway.
The length of the highway covered by TAP was small; only a length of 22 kilometres and this was performed from a motor vehicle.
The error margin is considered to be minor. As the road was travelled daily, a previous omission would be included the following day. However, very small or injured animals that managed to reach dense vegetation obviously were not found.
All Tasmanian Devil finds recorded by TAP’s Tony Saddington, were reported and logged by Carol Donaldson, Tasmanian Devil Management (DPIW).
The Gunns-sponsored survey appears to have been conducted only during Monday to Friday. Fluorescent spray marking of roadkill by Gunns occurred only on these days. No roadkill was removed by the Gunns team although the instructions were clear to do so. Weekends and public holidays appear not to have been included in assessment. Weekend roadkill generally deteriorated or was removed by persons unknown prior to Monday.
WORKS-Infrastructure, a road maintenance crew, occasionally observed the Gunns survey team travelling the highway after roadkill had been removed by WORKS. It is understood that WORKS patrolled the East Tamar Highway twice a week.
As such, the lack of species variation and in particular, failure to log threatened species, along with infrequent assessments and inaccurate data, illustrates a non compliance of the objectives of Condition 26.
The fact that Gunns’ website http://www.gunnspulpmill.com.au/permits/epbc.htm, lists only the East Tamar Highway as having been monitored, also demonstrates Gunns’ failure to monitor other major access routes and implement response strategies, as necessary, in accordance with the EIMP, as instructed by the Chief Scientist.
TAP surveys recorded over the same period identified threatened species that were not recorded by Gunns Ltd and demonstrates that the less-regular monitoring undertaken by Gunns Ltd does not provide an adequate baseline.
The purpose of the surveys is to obtain “adequate baseline data” to assess the impact of the pulp mill on listed threatened species. Given this objective, the approved survey methodology should be sufficient and representative.
As demonstrated above, this is clearly not the case.
TAP calls on your Department to refuse or revoke permits relating to this module as the objectives set down under Condition 26 have not been met.
a) Gunns have failed to recognise or discover existing threatened species and as such have not established a true baseline.
b) Three major access routes have been ignored for survey. Gunns’ own website shows that only the East Tamar Highway was surveyed.
c) Data was not collected daily, as recommended by the Chief Scientist. Weekends and public holidays appear to be unmonitored and observations spasmodic.
d) Evidence exists that carcasses were removed on occasions prior to inspection by Gunns’ survey crew.
We look forward to an early reply on this matter.
On behalf of TAP