National Parks and Wildlife Service (NPWS) Position

• Wingecarribee should be a nature reserve
• Peat mining has caused environmental damage
• Peat mining is unsustainable
• Peat mining continues to threaten flora and fauna
• Peat mining threatens cultural sites
• Approval has not been granted

1. The most appropriate land use over the swamp is that of a nature reserve (see map).

In the period since 1971 when the DMR granted the mining leases a considerable body of evidence derived from intensive scientific research, strongly substantiates the NPWS position that the swamp must be protected and reserved.

The establishment of a nature reserve would provide for the effective conservation of the significant natural, cultural, historical and palynological values, while at the same time providing for the maintenance of the hydrological and functional values of the swamp. In this regard the NPWS and SWC conservation and management responsibilities would be most effectively met.

The transfer of tenure of the swamp from the SWC to the NPWS has been negotiated conditional upon peat mining ceasing in the swamp and in so doing providing for the gazettal of the swamp as a nature reserve.

The NPWS considers that environmental damage has already occurred as a result of past and current mining.

Mining to date has opened up an extensive area of swamp with an extensive free water area now replacing what was a shrubland/ rushland peat deposit. The free-water body now dissects the swamp and fills the basin created by the removal of a considerable depth and volume of peat.

A considerable palynological history may have already been lost as mining has and is taking place in the widest and deeper peat sections of the swamp. Fragmentation and destruction of the swamp ecosystems has occurred and will be accelerated if peat mining was to continue.

Much palaeoenvironmental and palaeoclimatic research has still to be carried out in the swamp and further peat mining will destroy the storehouse of information that is held within the organic deposits.

The functionality of the swamp as a significant filter of catchment nutrients and pollutants particularly from septic effluent seepage from Robertson township has already been compromised but further peat mining, with the potential to remove the bulk of the peat deposits would completely destroy the natural ecosystem filtering and nutrient retention functions, with a consequent change in water quality and hence habitat for the invertebrate and amphibian fauna.

Changes in water regimes in the swamp as a result of milling potentially also threaten the continued existence of the small populations of endangered plants listed on Schedule I of the Threatened Species Act, and if mining continued at increasing rates of extraction, physical destruction of the populations could result within the term of any renewed leases.

The continuation of peat mining would also contribute to the spread of aquatic weeds within the swamp, particularly willows (Salix spp) and exotic water plants such as Glyceria maxima. The latter plant has already colonised several areas of the swamp The weed problem predictably, would be greatly increased if the filtering and nutrient storage capacity of the swamp was to be further reduced by the future peat extraction and an increase in nutrient enrichment eutrophication of the open waters created by peat mining.

The creation of future areas of open shallow water following peat extraction also poses a potential major problem if European Carp (Cyprinus carpio) were to colonise the open water areas. These fish are bottom feeders and contribute to turbidity and water quality problems.

The NPWS considers peat mining in Wingecarribee Swamp is unsustainable.

The NPWS position is that this mining operation is ecologically unsustainable and does not meet State and Commonwealth commitments and criteria for Ecologically Sustainable Development (ESD).

The NSW Wetlands Management Policy gives support to this position. The Policy is to be applied and implemented by all Government agencies such that there is no further degradation of wetlands in the State. The Policy states: The ecological sustainable use, management and conservation of wetlands in NSW for the benefit of present and future generations.

Whilst claims (DMR I996), that only 2% of the swamp having been mined to date and only a maximum of 4% will be mined by the end of any renewed mining leases, the NPWS considers that it is not the percentage of the swamp by area that is important. The important factor is the volume of peat extracted over the term of any new lease and the continued degradation of the total swamp ecosystem in future years. The extraction of-even a further 'small' volume of peat will further and exponentially increase the rate of decline and degradation of the swamp ecosystems.

The NPWS also recognises the potential for greatly increased peat extraction capacity and the desire of the company for an approximate 10 fold increase in production from the current 38000 tonne per annum (as stated by the company). This would greatly exacerbate the degradation of the swamp ecosystems and could result in all the stated extractable peat resources being removed within the term of any renewed leases, if they were a standard 21 year DMR lease.

Calculations by the DMR (1996) that peat would accumulate to 1.3 metres depth over a 260 year period if leases were renewed and current rates of mining were continued, themselves indicate that peat mining is an unsustainable industry. Research by Hope, Kodela and Whinham suggest very much slower rates of accumulation, as noted previously.

The claims based on these calculations by the DMR and the mining company that the mining operation is and will be ecologically sustainable, are not accepted by the NPWS

Peat mining has been recognised by the NPWS as a having a detrimental impact on the swamp and a threat to the continued survival of the swamp ecosystems, and flora and fauna.

The NPWS has supported the nomination for listing of peat mining at Wingecarribee Swamp as a threatening process under the Commonwealth Threatened Species Conservation Act.

The NPWS also recognises the threat to the continued existence of the rare and endangered plants Gentiana wingecarribiensis and Prasophyllum uroglossum and the rare dragonfly Petalura gigantea. The plant species are listed on Schedule I Part I of the Threatened Species Conservation Act. (1995) and a Threatened Species Recovery Plan has been developed for the Gentian.

Peat mining threatens the conservation and maintenance of a number of Aboriginal and European cultural sites within the swamp.

Five archaeological surveys have been carried out in the swamp with 14 relic sites being identified along the southern perimeter of the swamp: These sites are all on the flat to slightly elevated lands on the fringe of the swamp. Most of the artefacts recorded from these sites are silcrete and quartz flakes of a type which suggests they are less than 4000 years old. Some of the excavated artefacts have exhibited organic residues which suggest extensive USE of the swamp's plant resources by Aboriginal family groups.

No Aboriginal sites have been found within the swamp however it is possible that Aboriginal organic implements and human remains may well be preserved within the peat deposits. Brayshaw (1993 & 94) states that: "the current automated peat mining procedures are unlikely to allow the discovery of such items, and that peat mining represents the greatest threat to the Aboriginal cultural heritage of the swamp".

All Aboriginal sites and relics in NSW are protected under Section 90 of the National Parks and Wildlife Act (1974) and it is an offence to knowingly disturb or destroy any Aboriginal relics without the consent of the Director-General of the National Parks and Wildlife Service.

The NPWS is therefore responsible for and committed to ensuring all sites in and around the swamp edge are protected and appropriately managed.

The NPWS questions the existence of a valid Development Approval and recognises the requirement for an Environmental Impact Statement to be prepared before any consideration could be given to the renewal of the mining leases.

No documentation of a valid Development Approval has been made available, to the NPWS. This documentation was sought when the SWC and NPWS were jointly preparing the Plan of Management for the swamp and Wingecarribee Reservoir Special Area.

If a development consent was granted in 1967 as claimed by the mining company it is unlikely that an adequate environmental impact assessment was carried out and the NPWS is unaware of any research or monitoring being, undertaken in subsequent years by the company upon which the impacts of the mining operation can now be considered or assessed.

Pursuant to Section 237(1) of the Mining Act (1992), the Minister is obliged to "take into account the need to conserve and protect:- a) The flora, fauna, fish, fisheries and scenic attractions, and b) the features of Aboriginal, architectural, archaeological, historical or geological interest in or on the land over which the authority or claim (the renewal of mining leases) is sought".

A further issue in the context of development approval is that the land within the swamp, the subject of the mining lease renewal, is zoned 7A under the Wingecarribee Local Environment Plan (1989). This is a recognition of the significant environmental values of the swamp.. The NPWS position is therefore that if a valid Development Approval does not exist, an Environmental Impact Statement would have to be prepared under the provisions of the Environmental Planning and Assessment Act before consideration could be given to the renewal or granting of mining leases for the extraction of peat from the swamp.

National Parks and Wildlife Service, Submission to the Mining Wardens Inquiry into Possible Renewal of Mining Leases for the Extraction of Peat from Wingecarribee Swamp, 1997, Exhibit 23, pp. 8-12.