Edgar EPBC Comment - Restore Lake Pedder as the safe alternative

Public comments on Hydro’s proposed Edgar Dam works are open until March 13th.

Your submission must state that these works need to be a controlled action under the EPBC Act due to the impacts on the Tasmanian Wilderness World Heritage Area.

This is a generational oppertunity to see Lake Pedder rightfully restored.

Make a comment opposing the high risk dam works, in the Tasmanian Wilderness World Heritage Area and restoring Pedder as the safe alternative.

Find out more at LakePedder.org

Public comments on Hydro’s proposed Edgar Dam works are open until March 13th.

Your submission must state that these works need to be a controlled action under the EPBC Act due to the impacts on the Tasmanian Wilderness World Heritage Area.

This is a generational oppertunity to see Lake Pedder rightfully restored.

Make a comment opposing the high risk dam works, in the Tasmanian Wilderness World Heritage Area and restoring Pedder as the safe alternative.

Find out more at LakePedder.org

Restore Pedder - make the Edgar proposal a controlled action under EPBC

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Dear Minister Plibersek,

The Edgar Dam referral, ENTURA23902C, must be treated as a controlled action under EPBC because strengthening the dam (excavation down to bedrock and complete removal and replacement of cement dam face), will have a significant impact on several Matters of National Significance namely: The Tasmanian Wilderness World Heritage Area; a National Heritage Place, Threatened Species and Ecological communities.

Hydro states that there is no alternative to ‘strengthening’ the dam with its ‘high risk’ status to downstream residents. There is an unstated and untested assumption that the dam remains necessary for hydroelectric power supply and that assumption is sufficient to justify the ongoing compromising of the natural, cultural and wilderness values for which the TWWHA was listed.

Alternatives

Hydro has failed to assess the alternative action of decommissioning the dam and has proactively decided against giving permanent safety assurance to downstream residents and against enhancing the integrity of the TWWHA by removal of Hydro infrastructure.

World Heritage Area

The Edgar ’strengthening’ is the first stage of revamping the man-made Pedder impoundment which the World Heritage Committee included in the TWWHA boundaries on the assumption that it would be removed and Lake Pedder restored when the dams reached the end of their useful life. Keeping it undermines the Natural and Wilderness values of the TWWHA.

‘As it sits now the lake [the Huon-Serpentine storage] is an insult upon the land. We initially thought it should be excised from the existing World Heritage site but our 1989 evaluation foreshadowed the eventual prospect of restoration and on that remote (at that time) prospect we left it in. On earth in general and in Tasmania in particular it is time for healing. I would hope this process can begin with the successful restoration of Lake Pedder’ - Jim Thorsell Senior Advisor, Natural Heritage IUCN, 1995

Failure to provide full project description
Hydro intends to conduct major repair works to Scotts Peak dam as well and hence the Edgar referral is only a partial referral. The whole project must be considered as one and not in parts.

Natural Values of the TWWHA

Rejigging the dams is deliberately significantly impacting the integrity of the TWWHA and the natural values of exceptional natural beauty, distinctive landforms, paleoendemic species and communities, unusual threatened plants and animals and ecological processes.

Hydro’s own Natural Values assessment identifies some but not all of the threatened species to be impacted by the dam but argues the impacts will not be significant but provides no evidence to support that conclusion. It is clear the impacts will be significant and hence this is a controlled action.

Flora

The vegetation survey of impacted areas around the dam site including the proposed workers camp site is desk top. A two day field survey is completely inadequate. To conclude on the basis of a two day survey that none of the seven threatened flora species identified in the PMST as potentially occurring within a 5km radius are considered likely to occur within the disturbance foot print, is shoddy and untested. 
Specifically, Hydro fails to refer to the threatened Chiloglottis valida orchid which is present on the site of the workers camp.

Fauna

Hydro admits the presence of threatened species in the areas to be disturbed but then argues that the impacts can be mitigated. They cannot and that is why the proposed works must be a controlled action.

Hydro’s proposal fails to address the full area impacted and the risk to threatened species of 2,500 truck with trailer movements on Gordon River Rd, Scotts Peak Rd, Florentine Rd and between Boral Quarry at Bridgewater and the Edgar Dam, 150kms over an 18 month period. They pose a high risk and therefore significant impact from roadkill to listed threatened species of the Tasmanian devil, spotted and Eastern quoll. Restricting the truck movements to daylight hours is inadequate as the roads are in areas where these species are found and distances travelled between Bridgewater and the Dam site mean that the trucks will be on the road before sunrise and after sunset during a large part of the year. The roadkill surveys taken between Dec 2019 and Dec 2020 were during Covid travel restrictions and cannot be assumed to be a true survey during normal road use.   The mitigation proposals of recording roadkill and removing carcasses do not bring the animals back to life. They merely record the numbers of threatened species killed. Using Covid lockdown roadkill numbers as a baseline to suggest that there are few roadkills and therefore this project will not be a significant impact on the species is wrong.

23 threatened fauna species were identified as being, or likely to be, in a five km radius of the disturbance site and the following in the disturbance area: namely Tasmanian devil (Sarcophilus harrisii), eastern quoll (Dasyurus viverrinus) and spotted-tailed quoll (Dasyurus maculatus subsp. maculatus) • three bird species: white-bellied sea-eagle (Haliaeetus leucogaster), Tasmanian masked owl (Tyto novaehollandiae castanops) and the White-throated needletail (Hirundapus caudacutus) • one fish species: swamp galaxias (Galaxias parvus). In addition, two threatened invertebrate species (Ouse River caddisfly Oxyethira mienica and Tyenna River freshwater snail Phrantela pupiformis) listed under the TSP Act may occur within small tributaries within the disturbance footprint and intersecting creeks along Scotts Peak Road.

Hydro has failed to state the significant impact on the Galaxias Parvus, which it admits is present in the Edgar toe pond. Details of the dewatering process to translocate aquatic fauna are not available and this is a serious omission.

The dismissal of the recorded screechings of the Masked Owl in the camp ground on the basis that there are no habitat trees in the disturbance footprint is disingenuous. The Masked Owl has been recorded as present, Hydro acknowledges that it uses the area possibly for foraging. The likely significant impact on the Masked Owl of Hydro’s construction of a worker’s camp needs serious environmental assessment. The mitigation proposed, to minimise lighting and noise at night in a workers camp is unrealistic.

Nor does Hydro acknowledge the impact of the dam ‘strengthening’ as opposed to restoration on the habitat and foraging range of platypus, which prefers shallow streams to an impoundment.
 
Hydro also fails to outline the impacts on threatened fauna from the lights, noise, blasting and diesel generator vibrations from the workers camp which will be in place for 18 months to two years.

Consultation
Hydro’s statements about having conducted adequate community and Aboriginal consultation are wrong. The Huon Valley consultation was attended by less than 20 people. The Council meeting on Feb gives the lie to Hydro’s claims - https://www.youtube.com/live/xhuljjUOEME?si=0D3LcEHZtbcMosJ_

Hydro also claims to have consulted the Tasmanian Aboriginal Community. Their form with the Huon Valley Council casts doubts on any claims. Various groups have been contacted by us as collaborative partners and will make public comments.

For all these reasons, the Edgar Dam ENTURA23902C, proposal will have significant impacts on matters of Environmental Significance, is a controlled action and must be subject to a full environmental assessment.

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