SaB submission period extended

The public submission deadline for comment on 'Seeking a Balance - Conservation and resource use in the Northern Flinders Ranges' has been deferred until January 29th, 2009

See the most recent posts below for more information about Seeking a Balance.

Over the weekend the Save Arkaroola campaign placed an advertisement in the Weekend Australian (see at left), while the Wilderness Society ran its own on page 3 of today's Advertiser (below)

Today the Arkaroola Sanctuary released its own 'From the Ark update' announcing the postponement of the submission deadline. Notably, this included the following -

Arkaroola has received advice that the consultation process requires submissions to specifically address the management policies and zoning framework proposed in Seeking a Balance. So please when you Have Your Say, be sure to evaluate the document and make recommendations that can be considered in any revisionary process. We need to balance passion with purpose — to achieve a much better level of protection for Arkaroola Wilderness Sanctuary, and by inference, the Northern Flinders Ranges.

Now, it would be nothing short of outrageous should the State Government attempt to ignore submissions on Seeking a Balance that simply say 'we do not want to see any mining in the Arkaroola Wilderness Sanctuary, and to the extent that Seeking a Balance allows this I/we oppose it' - or even 'Please, just don't mine Arkaroola' - rather than addressing in detail a complicated mish-mash of zones that contradict existing legislation and don't even provide continuous 'whole of landscape' corridors for the local biota. I trust they will not attempt to do so.

In fact, given the clear conflict with the existing Class A Environmental Zone and no explanation of what the mining 'infrastructure' the new plan is prepared to see installed across the northern Flinders (in all but the limited areas assigned to Zone 1 in their plan) it's hard to work out what SaB actually means! (Click here for details)

So, I would argue that the Seeking a Balance process is flawed enough without any hypothetical figure in the state government attempting to say 'well, we're opening up the area to mining, and you must limit your comments to discussing the framework we've set up for this - but in choosing to comment you might perhaps hope to tweak our boundaries a little!'


the albert namatjira approach


But as no-one will want to see a submission wasted, and as I've advised before in this journal (see below) that submissions don't have to be long-winded or overly-detailed, I will also advise that they should at least contain wording to the effect that "I write with reference to your 'Seeking a Balance' document - and this is what I think of your proposed mining Access Zones..." and then propose what you'd wish to see for the area.

If we have to see the world through their framework let's take the Albert Namatjira approach - and paint the ranges purple!

(In SaB's mapping purple indicates Access Zone 1 - where the mining industry is most restricted - more zoning details )

don't submit - make a submission!

Submissions on 'Seeking a Balance - conservation and resource use in the Northern Flinders Ranges' plan are rolling in.

As we've noted previously, submissions don't have to involve a complex examination of the issues and intricacies of the proposed zoning system. They can be short and punchy should you only wish to make clear your own opposition to the concept of mining being allowed in the Arkaroola Wilderness Sanctuary. I have chosen something from this genre as the first example piece I've posted below.

Of course, if you are able to find the time to assemble a more complex argument it's also good to tackle any of the broad range of specific issues the document raises - or the questions it leaves begging! Accordingly, I've attached a couple more examples that pursue different lines of argument in more detail.

You don't have to buy into the bizarre idea that some kind of reasonable 'balance' can be achieved by allowing mining in a wilderness area! As a correspondent asks below 'Would NSW allow mining on the Kosciuszcko plateau?' Isn't the whole point of conservation areas is that they are excluded from precisely this kind of economic activity? In Arkaroola and the wild northern Flinders Ranges the state government simply cannot have its environmental cake and eat yellowcake, too!

So; don't submit - make a submission! And when it comes to submissions, the main thing is that they arrive on Mr Tyne's and/or Mr Irving's desks - or in their in-boxes - by December 19! Their contact details are posted again below.

There's also an excellent collection of example submissions available at the Save Arkaroola website - see the links at the bottom of the 'how can I help?' page


example one

Gentlemen,

Would NSW allow mining on the Kosciuszcko plateau? Would NT allow mining on Uluru? Would WA allow mining in the Stirling Ranges? Would Tasmania allow mining at Cradle Mountain? Would Victoria allow mining on the summit of Mt Bogong? Would Queensland allow mining on the Great Barrier Reef?

Rhetorical questions but germane ones. Unless one has been to Siller's Lookout on a cool winter's morning its impossible to describe the effect this area has on people. Arkaroola should be our 'secular scared site', to be FULLY and unequivocally preserved as an ecologically contiguous whole forever, not subject to an internecine cartographic 'death of a thousand cuts' and subsequent glossy greenwash campaign ('Seeking a Balance' being a typical example of the latter). Even when I cant get to Arkaroola, I feel better just knowing it is there, and I know I am not alone. I wonder how long I will be able to feel that way.

The fact that it has not been formally declared a national park is a historical anomaly ameliorated only by the excellent stewardship the Spriggs have demonstrated for decades. Why aren't they celebrated even more than they are for being the real pioneers of sustainable eco-tourism in this state?

I will leave the broader political, environmental, indigenous, spiritual and yes, even the economic arguments (see above) for the TOTAL PRESERVATION of this trifling percentage of the state, compelling as they are, to the many others who will surely submit their despairing and bewildered responses to this new government plan. Suffice to say that no government that pursues these policies will ever get my vote.

Save Arkaroola. Save our National Parks system.

example two

I want have to my opinion registered that exploration and mining, and in particular uranium mining, has the potential to seriously damage Arkaroola’s acclaimed tourism operation.

Arkaroola is an area of high conservation value in South Australia. Arkaroola is now known as Arkaroola Wilderness Sanctuary, with official sanctuary status under the National Parks and Wildlife Act 1972.

I am very concerned about the water use of a mine. The hydrology of the Flinders Ranges is highly complex. The relationship between aquifers, the surface springs and recharge rates requires investigation so they are not put at risk.

In a submission to the Australian Government in 2007, Marathon Resources advised that it would require 5·5 million litres a day for processing activities should a mining application be approved in the future.

The company would seek water from a variety of sources on the plains and in the ranges. Any approval to extract this measure of water from the region would contravene the government’s own targets and prescriptions around the sustainable use of water resources. It is vital that ecosystems like that in Arkaroola, enduring periods of drought as it did through the 10 years to summer 2008/9, not have their water resources compromised.

I believe that Arkaroola’s water needs to be given the highest level of protection.

Through Seeking a Balance, the government plans to introduce a new regulatory framework that will likely see parts of the Arkaroola landscape, currently protected under Environmental Class A provisions, re-zoned for standard exploration and mining activities. This is totally unacceptable.

The iconic features of Mount Painter and Mt Gee must be protected from invasive activity such as mining.

Arkaroola remains relatively weed-free, with weeds mostly restricted to day visitor areas and watercourses in the southern and south-eastern sections of the property. This situation would change dramatically with the incursion of mining activity in the region as exploration and mining increases the risk of weed introduction.

Even after a decade of drought, the integrity of Arkaroola’s native vegetation, particularly in the Mount Painter zone is highly rated. A fragmented zoning arrangement for sections of this highland area provides little assurance that this will continue.

Arkaroola had the shortest grazing history of any pastoral property in the Northern Flinders Ranges. Much of the sanctuary’s heartland has never carried livestock and plant communities are intact. Great topographic variation provides a wealth of micro-climates and environmental niches. There is great potential for remnant populations of small mammals to have survived on Arkaroola.

Some of the wildest, most elevated, least modified and most biodiverse landscapes in the Flinders Ranges occur in north- eastern districts. Five properties with contiguous landholding provide refuge for remnant, endemic, rare and threatened species, some of which are found nowhere else in the world. They also provide a corridor of connectivity for the movement of dispersing rock-wallabies. With its unique geology and landforms, lack of weediness, intact plant communities, and position as the northernmost protected area in the Flinders Ranges, Arkaroola Wilderness Sanctuary is a critical part of a greater Northern Flinders corridor. Despite this, in developing the Seeking a Balance framework, the South Australian Government has failed to deliver appropriate levels of protection for individual species and ignores its own policies that advocate landscape scale conservation The new framework, it is claimed, will balance resource use and conservation, and provide more certainty for mining and exploration companies, landholders, traditional owners and the community.

I believe that Seeking a Balance is inconsistent with other natural resource management policies, is flawed in its methodology, and is skewed toward exploration and mining at the expense of the environment. It is appalling that people like me have to respond in this way to something that should be so far from reality as to be a poor joke. Unfortunately the proposals are real and scary.

example three

To whom it may concern:

I have been informed that the government wishes to "re-evaluate" its zoning on mining activities in the Northern Flinders Ranges. I have deduced from the publication 'Seeking a Balance' that the general aim is for the government to protect certain places of higher environmental/cultural/wildlife/geological/heritage/tourism value within the region, but then open the remaining areas in the region to mining exploration an activities.

I am opposed to this proposal, as there are a number of reasons that this act could be devastating to the area. Firstly, there are a number of endemic species to the area, and if disturbed by mining activities, or if invasive species are introduced through an increase of traffic into previously untouched areas, we could lose plants and animals not found anywhere else in the world.

There are also species that have been endangered that thrive in the area, such as the Yellow Footed Rock Wallaby. The species has a high concentration of colonies along the Arkaroola Creek, however in the proposed re-zoning, there are no bio-corridors linking the colonies in the north with those in the central regions or the north eastern region. Bio-corridors are essential to species survival as they allow the species to move to adjacent areas and to adapt to environmental change.

There are also important issues for Indigenous people, namely the Adnyamathanha People, which are barely even skimmed across in the proposal. Are the traditional owners being consulted on this matter? If so, are their opinions and concerns taken into account, or is this process simply a formality? Please inform me on this matter, as I am very unclear about the process undertaken in this circumstance.

There are also implications for tourism. As Arkaroola is an outstanding example of eco-tourism, the affects of mining exploration and activities going on within the sanctuary are not appealing to potential eco-tourists. The general characteristics of mining, such as water over-use, waste (see Marathon Exploration's inappropriate methods and waste dumping at Mt Gee and Yudnamutana Gorge), as well as pollution (both noise and air etc) will have a negative impact on the landscape, and therefore reduce the appeal to tourists, not to mention all other species that live there.

Geologically, the entire area is significant. There are important features within the area that have scientific importance, including holding information about past climates, which is becoming more and more important in the face of accelerated climate change.

Astronomically, Arkaroola has a spectacular outlook, with very little light pollution and usually fine weather, the star gazing is an attraction for tourists and astronomers. If mining activities are permitted nearby, what sort of affect will the amazing clear skies encounter?

The Euro-entric heritage of the area dates back to the 1840s, with the area being used for a number of different fields. Agriculture did not suit the landscape, and mining was tried and abandoned, and the most appropriate use was found - a wilderness sanctuary. Going back to mining in the area would be a step backwards - does the government want to move forward or backward? We don't need any more reasons for the other states to call SA a "little backwater".

I am also concerned that the mine at Beverly is perhaps not being fully utilised if concentration has turned towards the areas around Arkaroola. Are there issues regarding the Beverly mine that the public should be aware of?

It appears to me that the government are placing mining above environment and conservation in this instance, which is absolutely appalling. That is not what I elected the government to do. I am deeply disappointed that the policy makers have not learned a thing when it comes to over exploitation of resources, environmental degradation, climate change, and environmental irresponsibility. If economy is the states only concern and priority, then we will ruin our precious environment.

Please do not open up areas in the Northern Flinders Ranges to mining and resource exploration and activities that are currently protected. I would prefer to see a higher level of protection to the entire area. As biodiversity does not limit itself to pockets of landscape in the region - neither should the protective zoning.

Please reconsider your proposal to provide better environmental protection of these important areas

Submissions on Seeking a Balance are due in on December 19th (There are rumours of a postponement of this deadline until the end of January next year, but neither PIRSA's nor the Dept for Environment's 'Seeking a Balance' websites currently confirm this. I'll update this information when and if it changes.) They can be e-mailed or posted to;

Email: jason.irving@sa.gov.au
Phone: (+61 8) 8124 4707
Post: Mr Jason Irving
Manager Policy and Planning
Department for Environment and Heritage
GPO Box 1047
Adelaide SA 5001
Australia

Email: ted.tyne@sa.gov.au
Phone: (+61 8) 8463 3033
Post: Dr Ted Tyne
Director, Mineral Resources
Primary Industries and Resources SA
GPO Box 1671
Adelaide SA 5001
Australia

 

seeking a balance - not a great lookout for sillers!

There's no more famous image of the Arkaroola Wilderness Sanctuary than the one at left. This view of Siller's Lookout, terminus of the outward-bound leg of the Ridgetop Tour (a party of which can be seen here on the summit) is known across Australia and the world. It's one of the iconic images of South Australian tourism, and Australian eco-tourism, full stop!

In fact, this version of the image is taken from the state government's own 'Seeking a Balance - Conservation and resource use in the Northern Flinders Ranges' (SaB) document.

But the image is used very widely - the most well-known variant being Arkaroola's own take, as used, in the example at right, in The Wilderness Society's advertisement highlighting the risk mining poses to the area.

Referring to his then newly-released 'Seeking a Balance' plan, South Australia's Environment Minister Jay Weatherill told the ABC News on the 28th of October this year -

"I think what people need to rest assured about is that when they think about Arkaroola and they think about the iconic spots, the things that they have in their minds will be now [be] protected"

As I've said, there's no more iconic image of the Sanctuary than this view of Siller's - with the lookout massif in the foreground, and the ranges on the southern flank of lower Yudnamutana Gorge rolling off to the plains and Lake Frome behind.

But in 'Seeking a Balance' the Minister has not seen fit to grant any extra protection to Siller's Lookout, nor the bulk of the country you can see in the background in these iconic images!

That's right - in his plan this area is consigned (along with the bulk of the region) to Access Zone 3 (the 'yellow zone': see the detail of SaB's own map at left) - open to standard mineral exploration and mining access, with no approval required for either activity from the Department for the Environment!

A discussion of the inadequacies of the proposed zoning system, with particular regard to the apparent conflict with the Planning Act's existing 'Class A Environmental Zone' for the Flinders Ranges - inadequacies that remain even when it comes to those areas supposedly afforded a 'higher' level of protection - can be found in the previous post - a Class A confusion.

But to choose not to assign a higher level of protection to the icon area of Arkaroola, and then to tell the public you've 'protected' all 'the things they have in their minds... when they think about Arkaroola' - well, it's breathtaking, isn't it? But not as in 'what a breathtaking view!'


don't submit - make submissions!


No, you don't have to subscribe to the logic of planning for mining access to the Arkaroola Wilderness Sanctuary and simultaneously proclaiming that it's been protected! Nor play-along with tweaking the boundaries of access and planning zones that overlap and contradict each other.

Make a submission on Seeking a Balance. They don't have to be long and complicated. You are completely entitled to express an opinion that mining is not a suitable option for the Arkaroola Wilderness Sanctuary without having to enter into detailed discussion of the intricacies of Class A Zoning versus SaB access zoning, or discussion of why there are no linking biological corridors running north to south in the Government's plan, or any other of the broad range of issues the plan raises. Not if you don't wish to.

In fact, I'd argue that because SaB and the existing Class A Zone provisions are in such obvious conflict, and because we have no definition provided for any of the allowable mining 'infrastructure' associated with SaB (but explicitly excluded by class A), it's actually difficult to assess the implications of Seeking a Balance, full stop!

But it's clear that the mining industry cannot expect to have the run of the whole state - and since they tell us 'certainty' is what they crave, let them be certain that these wild ranges are off-limits!

Submissions on Seeking a Balance are due in on December 19th. They can be e-mailed or posted to -

Email: jason.irving@sa.gov.au
Phone: (+61 8) 8124 4707
Post: Mr Jason Irving
Manager Policy and Planning
Department for Environment and Heritage
GPO Box 1047
Adelaide SA 5001
Australia

Email: ted.tyne@sa.gov.au
Phone: (+61 8) 8463 3033
Post: Dr Ted Tyne
Director, Mineral Resources
Primary Industries and Resources SA
GPO Box 1671
Adelaide SA 5001
Australia


for example


I've attached the first example submission on SaB below. It's written from the perspective of someone who is pro-mining, but, as they say, not at any cost! I am hoping that a series of such submissions will shortly be appearing on the Save Arkaroola website.

Dear Dr Tyne & Mr Irving

I am writing to you to strongly urge you to reconsider the Proposed Management Zones for the northeastern region of the Northern Flinders Ranges as indicated in the document Seeking a Balance.

I consider myself pro-mining and am All for economic benefit for the State of South Australia – BUT NOT AT ANY COST !

I enjoy bushwalking, camping and nature and I have visited the beautiful, stunning and quite magnificent Arkaroola Wilderness Sanctuary many times. I have also taken the exciting four wheel drive Ridgetop Tour through this iconic area, much of which, under the proposed zoning would become Access Zone 3: for Standard exploration and mining access.

It is my belief that this environmentally fragile region, which is currently suffering under more than a decade of drought, at least in the foreseeable future, would be irreparably damaged by current mining and exploration techniques. Many species are under considerable threat to their survival, and additional pressure could be catastrophic for them particularly given global warming.

To quote 'Seeking a Balance' itself - 'much of the Northern Flinders Ranges lies within the Development Plan’s Environmental Class A Zone. The prime objectives of the Environmental Class A Zone seek to conserve the natural character and environment of the area and to protect the landscape from damage by mining operations and exploring for new resources.'

I believe it would be better to strengthen the existing Class A Environmental standards rather than bringing in a whole new raft of legislation.

The Development Act says ‘Mining operations should not take place here unless the deposits are of such paramount significance that all other environment, heritage or conservation considerations may be overridden’ and that ‘exploitation of the deposits is in the National or State interest’ and that ‘investigations have show that alternative deposits are not available on other land in the locality..’

I believe it is pointless and dangerous to risk the introduction of new legislation when the current simply needs tweeking. Present techniques are too risky and likely to cause environmental, cultural, tourism and/or other damage and will be a blight on the landscape for decades to come.

Please follow the advice of moderation and withdraw the Management Zoning proposals mooted in Seeking a Balance.

 

a Class A confusion?

The map at left, courtesy of The Wilderness Society, superimposes the Class A Environmental Zone created by the 2003 Development Plan for the Flinders Ranges (or Class A for short) over the recently released 'Seeking a Balance - conservation and resource use in the Northern Flinders Ranges' (SaB) document's proposed mineral access zoning.

(Click the image to go to the flickr page where it's possible to access large - and very large - versions of this map.)

To quote 'Seeking a Balance' itself 'much of the Northern Flinders Ranges lies within the Development Plan’s Environmental Class A Zone. The prime objectives of the Environmental Class A Zone seek to conserve the natural character and environment of the area and to protect the landscape from damage by mining operations and exploring for new resources.

In the map the Class A Zone is indicated by the large red hatched area. Under the existing Class A provisions mining is currently possible within it only if the deposit is of 'paramount importance' and in 'the national interest' and if no similar resource is available outside the zone. Any proposed 'infrastructure' is limited to walkers huts and associated rainwater tanks and the like.

'Seeking a Balance' excludes mining and associated infrastructure only in the Purple Zones (Zone 1 in SaB). While this is an excellent result in the case of the Mawson Plateau, the largest such area, the story for the rest of the northern Flinders is rather different, and particularly for the disputed area of Exploration Lease 4355, which is shown outlined in black (see detail map below).

Roughly, Blue Zones (SaB Access Zone 2a) allow for restricted, 'non-disturbing' exploration activity and potential mining access only from 'outside' those zones (i.e from underground.) Any activity must be jointly-approved by both the Dept for Mineral Resources and the Dept for Environment.

But please bear in mind, within controversial uranium exploration lease EL 4355 - the black outline - the exploration drilling around Mount Gee and Mount Painter has largely been done already in or adjacent to these sectors. Since these zones are confined to ridge-tops they would not in any case be likely targets for direct mining access since the uranium resource lies hundreds of metres below them! (Although currently effectively ruled out by the terms of the Class A Zone optimal efficiency and economy would be achieved by accessing any resource from a low-lying gorge/valley area adjacent to it - and as we see by glancing at the map and in the discussion of the other access zones below, SaB apparently might provide such opportunities!)


it's more by way of being guidelines


Still on the blue zones (2a), while exploration may be restricted - even if that's actually moot - undefined mining 'infrastructure' is allowable. I can't tell you what 'infrastructure' might be because nowhere is that made clear! There is no specific reference to Class A but reference is made to proposals being 'assessed in light of planning guidelines and identified values'.

Now, 'guidelines' is a scary word, particularly when it's being used to describe something that is actually the mainstay of protection for the area!

Green Zones (SaB Access Zone 2b) allow for both exploration drilling and the creation of undefined 'infrastructure' and mining with the approval of both the Mineral Resources Dept. and the Dept. for the Environment on a case-by-case basis. Again, Class A is not specifically cited, but a clearer reference (better than 'planning guidelines', anyway!) is made to 'Development Plan guidelines'; but note again, this key existing legislation is still - disturbingly - referred to as 'guidelines'!

Yellow Zones (SaB Access Zone 3) - by far the largest area - allow for mining to occur as it might anywhere else in the state where only the standard provisions of the Mining Act apply. No Dept. for Environment approval is required to grant either exploration or mining permits. Might they also serve as potential departure points for shafts and declines accessing resources under the higher conservation value areas?


a very uneasy 'balance'


Do you see something of a tension here? We are apparently to believe that the Class A Zoning still exists across its marked area - legislation that was set up specifically to 'preserve the character of the ranges' and dramatically limit mining activity - and simultaneously that the new 'Seeking a Balance' plan 'increases the level of protection for the area' while apparently allowing for both infrastructure and access that Class A specifically does not permit!

Meanwhile it simultaneously reduces the bulk of the area to the same 'standard mining regulations only' status as the adjacent plains and the bulk of the rest of the state! If this supersedes Class A it's a disaster; if the two are supposed to simultaneously co-exist the tensions between them are absurd; and how are we to judge which will prevail?...


the corridors of power?


The astute among you will also notice that there are no continuous 'corridors' linking the higher value conservation areas (Zones 1 and 2a and 2b) from north to south. Such continuous corridors are standard practice elsewhere in the state where the Govt's 'Naturelinks' program is operational.

But take another look; there are apparent corridors! Consider the continuous Zone 3 'standard regs only' zones surrounding the uranium resource, which is centred on Mount Gee in the heart of the Arkaroola Wilderness Sanctuary and EL 4355 (see the detail map above).

And look at the potential link this 'standard mining access' zoning provides to the proposed processing facilities on the eastern plains!

Consider the long peninsula of green (SaB Access Zone 2B) that snakes away from Mount Gee and Mount Painter to the south east towards the proposed processing zone. Why on earth would this, the northern side of the valley of the East Painter Creek warrant a higher protection status while the southern side, which is virtually identical as a landscape, is cast into the 'access all areas' zone? Why indeed, if not to provide for a potential haulage or pipeline route on the southern side?


make submissions - but don't submit!


Submissions on seeking a balance are due in a fortnight (December 19th). Details for where they can be sent are available via the Seeking a Balance PDF (or booklet itself), or at the Save Arkaroola website (+ see link in image below)

Don't let the above phase you! Submissions don't have to be long and complicated. You are completely entitled to express an opinion that mining is not a suitable option for the Arkaroola Wilderness Sanctuary without having to enter into detailed discussion of the intricacies of Class A Zoning versus SaB access zoning if you don't wish to. I provide these details for information, and because I want to make clear my concerns with notions that the 'balance' SaB seeks is only a 'reasonable' weighing of options.

It's an intellectual fallacy that there's always a 'middle ground' that needs to be sought in any argument and is the most 'reasonable' position. Could we really believe that a half-scale Franklin Dam would have been a rational compromise? Or that we could safely drill for oil on half the Barrier Reef?

No! Absurdity must be named. There's no place for miners in the Arkaroola Wilderness Sanctuary, and the kind of convoluted logic that gives us a mish-mash of zoning and a mesh of contradictions like that found in SaB only serves to reinforce this argument. If 'certainty' is what's required then let the industry be 'certain' that it has no place here.

And I'll happily post any copies of submissions people care to send me that might serve as a good inspiration and example to other friends of the wild ranges! Feel free to either post them as a comment below or e-mail them directly to me.