The Marine Environment and the EPBC Act

Transcription

1 The Marine Environment and the EPBC Act 1. INTRODUCTION The Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act ) provides protection for the marine environment in a number of ways. People who are interested in the protection of the marine environment should be aware of relevant aspects of the EPBC Act and how the Act can assist in achieving environmental outcomes. This fact sheet deals with the following issues. The key marine provisions of the EPBC Act. The environmental assessment and approval process. Listed marine species and cetaceans and the permit process. Wildlife conservation plans. Strategic assessments. Opportunities for public involvement. Where to find further information. 2. KEY MARINE PROVISIONS OF THE EPBC ACT The key provisions of the EPBC Act that relate directly to the marine environment are: Part 3, ss.23 and 24A which impose approval and assessment requirements on actions concerning the Commonwealth marine environment and Commonwealth managed fisheries; Part 13, Division 3 which protects whales and other cetaceans in Commonwealth areas; Part 13, Division 4 which protects members of listed marine species in Commonwealth areas; Part 13, Division 5 which enables the Commonwealth Minister for the Environment and Heritage (the Minister ) to prepare and implement wildlife conservation plans for listed marine species and cetaceans; and Part 10 which requires management plans for Commonwealth fisheries to undergo strategic assessment. These provisions of the EPBC Act are discussed in greater length below. However, readers should be aware that there are also several other elements of the EPBC Act that, while not exclusively related to marine issues, can provide protection for the marine environment. These include the following. Part 3 provides protection for matters of national environmental significance, the environment on Commonwealth land, and the environment generally where the relevant actions are taken by the Commonwealth or a Commonwealth agency or are carried out on Commonwealth land. The matters of national environmental significance include the Commonwealth marine environment and Commonwealth managed fisheries (via ss.23 and 24A). However, they also include listed threatened species and ecological communities, listed migratory species, the world heritage values of World Heritage Areas and the ecological character of Ramsar wetlands. Many of the listed threatened and migratory species are marine species and several of the Ramsar wetlands are located in the tidal zone. Similarly, a number of the World Heritage Areas are, or include, marine areas, such as the Great Barrier Reef World Heritage Area and the Lord Howe Island Group World Heritage Area. For more information on matters of national environmental significance and the protections provided under Part 3, see the EPBC Unit Fact Sheet on Environmental Assessment and Approval under the EPBC Act. 1

2 Part 13, Divisions 1 and 2 impose restrictions on actions taken in Commonwealth areas that may harm or injure a member of a listed threatened species, listed threatened ecological community or listed migratory species or habitat that is critical to the survival of a listed threatened species or ecological community. These provisions are similar to those found in Part 13, Divisions 3 and 4, which relate to cetaceans and listed marine species (see below). The EPBC Unit Fact Sheets on Threatened Species and Ecological Communities and Migratory Species contains more information on how the Act protects listed threatened species and ecological communities and listed migratory species. Part 13, Division 5 requires recovery plans to be prepared for listed threatened species (except conservation dependent species) and ecological communities. Wildlife conservation plans (which are discussed below) can be prepared for conservation dependent species. These plans must identify habitat that is critical to the survival of the relevant species or community and set out procedures to ensure the survival and recovery of the species or community. Part 13A of the Act imposes a number of restrictions on the import and export of wildlife specimens. These can include marine specimens and specimens derived from marine plants and animals. For more information on these provisions, see the EPBC Unit Fact Sheet on Wildlife Trade. Part 14 allows the Minister to enter into conservation agreements with landholders and others for the protection and conservation of biodiversity. These agreements can provide for the protection of elements of the marine environment. For example, the Minister could enter into conservation agreements with fishers, whereby the Commonwealth provides financial support to assist fishers to adopt more sustainable fishing practices. For more information on conservation agreements, see the EPBC Unit Fact Sheet on Conservation Agreements. 3. ENVIRONMENTAL ASSESSMENT AND APPROVAL PROCESS 3.1 The approval trigger Part 3 of the EPBC Act requires activities that are likely to have a significant impact on a matter of national environmental significance and other matters concerning the Commonwealth to be assessed and approved under the Act. The matters of national environmental significance include the Commonwealth marine environment, which covers (ss.23 and 24A): actions taken in a Commonwealth marine area that are likely to have a significant impact on the environment; actions taken outside a Commonwealth marine area that are likely to have a significant impact on the environment in a Commonwealth marine area; and fishing in a Commonwealth managed fishery that is likely to have a significant impact on the environment. Under ss.23 and 24A, actions that fit one of these descriptions are required to be assessed and approved under the Act. Actions are defined for these purposes as including a project, development, undertaking, activity or a series of activities. However, an action does not include a decision of a government body to grant a governmental authorisation or to provide funding by way of a grant. Broadly, the Commonwealth marine area includes the waters between 3 nautical miles and 200 nautical miles (or the edge of the continental shelf, which ever is further) of the low water mark of the Australian coast, the airspace above those waters and the seabed below those waters. Generally, the States and Territories are responsible for the waters (called the coastal waters ) between the low water mark and 3 nautical miles. However, in certain instances, the Commonwealth has been given responsibility for the management of fisheries in coastal waters by agreement with the relevant State or 2

3 Territory. Similarly, in some instances, the States/Territories can be responsible for the management of fisheries located in the Commonwealth marine area. 3.2 Exemptions There are a number of important exemptions from the approval requirements in Part 3. In this regard, the following actions (amongst other things) are exempt from the approval requirements: fishing in a fishery located in a Commonwealth marine area (notwithstanding that the fishing may have a significant impact on the environment) if the fishery is managed under a law of a State or Territory and the fishing is authorised under that law; fishing in the coastal waters of a State or Territory (notwithstanding that the fishing may have a significant impact on the environment in the Commonwealth marine area) if the fishing is authorised under the laws of the relevant State or Territory; actions authorised under the Great Barrier Reef Marine Park Act 1975 (Cwlth); actions that were authorised under State, Territory or Commonwealth law before 16 July 2000, provided no further environmental authorisation was required to take the action at that date; and actions that are a lawful continuation of an existing use of the land, sea or seabed that was occurring before 16 July 2000 (although an expansion or intensification of a use is not a continuation of a use). The Minister also has the power to grant exemptions in certain circumstances. For more information on exemptions, see the EPBC Unit Fact Sheet on Exemptions from the Approval and Assessment Process. 3.3 How does the assessment and approval process work? The general steps in the assessment and approval process are as follows. Step 1 Referral A person who believes an action may have a significant impact on: a matter of national environmental significance; the environment on Commonwealth land; or the environment generally where the action is carried out on Commonwealth land or is being taken by the Commonwealth or a Commonwealth agency, must refer details of the action to the Minister. The Commonwealth Department of the Environment and Heritage (which is called Environment Australia ) has published Administrative Guidelines on Significance, which are intended to assist proponents to determine when an action should be referred to the Minister. Guidelines have also been published on: when proposed offshore seismic operations should be referred to the Minister (and when a permit may be required under Part 13 for seismic operations see below on permit requirements); and the application of the Environment Protection and Biodiversity Conservation Act 1999 and the Great Barrier Reef Marine Park (Aquaculture) Regulations 2000 to aquaculture projects in areas adjacent to the Great Barrier Reef. These guidelines can all be found on the Environment Australia EPBC website at: Step 2 Controlled action decision After the Minister receives a referral, he/she must decide whether the project needs to be approved under the Act (ie whether it is likely to have a significant impact on a matter of national environmental significance, the environment on Commonwealth land, or the environment generally where the action is taken by the 3

4 Commonwealth or a Commonwealth agency or is carried out on Commonwealth land). Actions that require approval are called controlled actions. If the Minister decides the action does not require approval, the proponent can proceed with the action (provided all other Commonwealth/State/Territory approvals have been obtained). Step 3 - Provision of preliminary information If the Minister decides a project requires approval under the Act, the proponent must provide certain preliminary information about the project to the Minister. The information that must be provided is described in Part 5 and Schedule 3 of the Regulations. This information is intended to assist the Minister to decide how the project should be assessed. Step 4 - Assessment approach decision Within 20 business days of receiving the preliminary information, the Minister must decide which of the following types of assessment will be used to assess the relevant environmental impacts of the action: assessment on the preliminary documentation; a public environment report ( PER ); an environmental impact statement ( EIS ); a public inquiry; or an accredited assessment process (which generally involves the accreditation of a State or Territory environmental assessment process, or another Commonwealth assessment process). Within 10 business days of making this decision, the Minister must give notice of the decision to the proponent and relevant State or Territory in which the project will be carried out, and publish notice of the decision on Environment Australia s website. Note that if a bilateral agreement is in place that accredits a State assessment process, the State (and not the Commonwealth) will assess the project. Similarly, if a Ministerial declaration has been made that accredits another Commonwealth assessment process, the action will be assessed under that process (and not under the process outlined in the EPBC Act). For more information on bilateral agreements, see the EPBC Unit Fact Sheet on Bilateral Agreements. Step 5 Assessment After the proponent has been notified of the assessment approach decision, the assessment must be carried out. The processes that apply differ according to the type of assessment. For more information on these assessment processes, see the EPBC Unit Fact Sheet on Environmental Impact Assessment and Approval under the EPBC Act. Note that assessments under the EPBC Act will usually only assess the impacts of a proposed activity on the matters that triggered the approval and assessment requirement. So, for example, if a project requires approval because it is likely to have a significant impact on the environment in a Commonwealth marine area, the assessment under the EPBC Act will usually only assess the potential impacts on the relevant Commonwealth marine area. The Act defines these impacts as the relevant impacts. The broader environmental impacts of a project will usually be assessed under applicable State and Territory assessment processes. Step 6 Approval Once the Minister receives the relevant report on the assessment, he/she will usually have 30 business days (40 business days if the report was provided by Commissioners appointed to hold a public inquiry) to decide whether or not to approve the project in question. If the Minister approves a project, he/she can impose conditions on the approval. 4

5 For more information on the approval process, see the EPBC Unit Fact Sheet on Environmental Impact Assessment and Approval under the EPBC Act. 3.4 Penalties for non-compliance Maximum penalties for taking an action without a required approval include 7 years imprisonment and/or a fine of up to $550,000 for an individual and $5.5 million for a corporation. The offender may also be required to pay for the mitigation or repair of any environmental damage caused by the action. Maximum penalties for contravening a condition of an approval include 2 years imprisonment and/or a fine of up to $110,000 for an individual and $1.1 million for a corporation. Directors and managers of companies can be found liable for offences committed by their companies. 3.5 Community involvement Can I comment on proposed actions? Members of the public are usually provided with an opportunity to provide comments at two stages in this process: at the referral stage where members of the public will usually be provided with an opportunity to comment on whether the action is likely to have a significant impact on a matter of national environmental significance, the environment on Commonwealth land, or the environment generally where the action is taken by the Commonwealth or a Commonwealth agency or is carried out on Commonwealth land; and at the assessment stage where members of the public will usually be provided with an opportunity to comment on the adequacy of assessment documentation that has been prepared by the proponent, whether the action should be approved and, if it is approved, what conditions should be attached to the approval. If an action is assessed by way of a public environment report or environmental impact statement, members of the public may also be provided with an opportunity to comment on draft guidelines for the report or statement. What can I do if somebody has contravened the Act? If you are concerned that a project is being carried out without a required approval, you can: ask the Minister to call in the activity for a determination on whether it requires approval under the Act; write to the developer or relevant State agencies requesting them to refer the activity to the Minister under the EPBC Act; and/or if the activity has been commenced and it has caused significant harm to a matter of national environmental significance, ask the Minister to take enforcement action against the perpetrator. In addition, if you may be entitled to apply to the Federal Court for an injunction to prevent the action, and if appropriate, an order to repair or mitigate environmental damage. You should contact a qualified legal practitioner (such as the Environmental Defender s Office) if you are considering commencing any legal action. 4. LISTED MARINE SPECIES AND CETACEANS 4.1 Listed Marine Species The List Under s.248 of the EPBC Act, the Minister is required to maintain a list of marine species. The current list of marine species includes all Australian sea-snakes, seals, crocodiles, dugongs, turtles, seahorses and seabirds. 5

6 Marine species can be added to the list, provided the Minister is satisfied the species occurs naturally in the Commonwealth marine area and listing is necessary to ensure the long-term conservation of the species. There is no formal statutory process whereby members of the public can nominate species for inclusion on the list. However, this does not prevent members of the public from asking the Minister or Environment Australia to include a species on the list. Permit requirements Under Part 13, Division 4, a permit is required to do any of the following in a Commonwealth area (which includes a Commonwealth marine area): take an action that results in the death or injury of a member of a listed marine species (other than a cetacean or a member of a listed marine species that is also a listed threatened species or listed migratory species); or take, trade, keep or move a member of a listed marine species (other than a cetacean or a member of a listed marine species that is also a listed threatened species or listed migratory species). Listed marine species that are also listed threatened species, listed migratory species or cetaceans are exempt from these requirements because there are equivalent permit requirements for these matters in Part 13, Divisions 1, 2 and 3 respectively. There are a number of other exemptions from these permit requirements. In this regard, a permit is not required for (amongst other things): actions provided for in, and taken in accordance with, a wildlife conservation plan for the relevant species; actions covered by an approval in operation under Part 9 for the purposes of ss.23, 24A, 26 or 27A; actions taken in accordance with an accredited management plan, where the Minister has declared that actions taken in accordance with the plan are exempt from the approval requirements under relevant provisions in Part 3 (ie. ss. 23, 24A, 26 or 27A); actions that are necessary to relieve or prevent the suffering of a listed marine species; actions that are reasonably necessary to prevent risk to human health; actions that are reasonably necessary to deal with an emergency involving a serious threat to human life of property; actions that occur as the result of an unavoidable accident; actions taken in accordance with a permit issued under the Great Barrier Reef Marine Park Act 1975 (Cwlth); and actions taken in accordance with a management plan that has been accredited under Part 13, Division 4. Notification requirement If a person harms, injures, takes or trades a member of a listed marine species without a permit, and the act is not an offence by virtue of the operation of one of the available exemptions, the person is required to notify Environment Australia within 7 days of becoming aware of the action. 4.2 Cetaceans Australian Whale Sanctuary The EPBC Act established the Australian Whale Sanctuary, which covers the Commonwealth marine area, as well as any State or Territory coastal waters prescribed under the regulations. All cetaceans (whales, dolphins and porpoises) found in the Australian Whale Sanctuary are protected under the EPBC Act. The Act also imposes restrictions on actions concerning cetaceans in waters beyond the outer limits of the Australian Whale Sanctuary. However, these restrictions only apply to actions taken by Australian citizens and permanent residents, Australian corporations, Australian vessels, the crews of Australian vessels, the Commonwealth and Commonwealth agencies. 6

7 Permit requirement Under Part 13, Division 3, a permit is required to do any of the following: kill, injure, take, trade, keep, move or interfere with a cetacean in the Australian Whale Sanctuary or on the high seas (the requirement to obtain a permit for activities on the high seas only applies to Australians); or possess a cetacean or any part of a cetacean that has been killed or taken illegally. However, there are a number of exemptions from these requirements. In this regard, a permit is not required for (amongst other things): actions provided for in, and taken in accordance with, a recovery plan or a wildlife conservation plan for the relevant species; actions that are necessary to relieve or prevent the suffering of a cetacean; actions that are reasonably necessary to prevent risk to human health; actions that are reasonably necessary to deal with an emergency involving a serious threat to human life of property; actions that occur as the result of an unavoidable accident; and actions taken in accordance with a management plan that has been accredited under Part 13, Division 3 (provided the cetacean is not a member of a listed threatened species). Notification requirement If a person harms, injures, takes, trades or interferes with a cetacean without a permit, and the act is not an offence by virtue of the operation of one of the available exemptions, the person is required to notify Environment Australia within 7 days of becoming aware of the action. 4.3 Penalties Maximum penalties for taking an action without a required permit include 2 years imprisonment and/or a fine of up to $110,000 (for an individual) or $550,000 (for a corporation). Fines of up to $33,000 can also be imposed on a person who contravenes a condition of a permit. 4.4 Appeals against permit decisions Members of the public whose interests are affected by a decision of the Minister to grant a permit can appeal to the Commonwealth Administrative Appeals Tribunal ( AAT ) if they are dissatisfied with the decision. Appeals to the AAT can be on the basis of the merits of the decision, rather than simply on matters of law. You should contact a qualified legal practitioner (such as the Environmental Defender s Office) if you are considering lodging an appeal against a permit decision. 5. WILDLIFE CONSERVATION PLANS (Part 13, Division 5) Under Part 13, Division 5, the Minister may prepare wildlife conservation plans for listed marine species and cetaceans. These plans must be prepared in consultation with the States and Territories, unless the relevant species is only found in the Commonwealth marine area. These plans are not legally binding, although Commonwealth agencies are required to take all reasonable steps to act in accordance with them. Wildlife conservation plans will identify habitats that are important to the survival of the relevant species and set out a process to ensure the continued survival of the species and protection of these habitats. Importantly, in many instances, they will facilitate the provision of government funding for the conservation and protection of these species. In this regard, the Minister can give financial and technical assistance to any person to help implement a wildlife conservation plan. 7

8 6. STRATEGIC ASSESSMENTS (Part 10) 6.1 What is a strategic assessment? Strategic assessments involve the assessment of the impacts of actions taken under a policy, plan or program on a matter or matters protected under Part 3 of the Act. This process enables the cumulative impacts of actions taken under the policy, plan or program to be assessed. It also enables the Minister to evaluate the contents of the relevant policy, plan or program to ensure that relevant environmental issues have been taken into account and to ensure they contain appropriate mitigation measures. 6.2 How are strategic assessments started? Strategic assessments can only be undertaken with the agreement of both the Minister and the person or body responsible for the adoption or implementation of the policy, plan or program. However, the EPBC Act requires the Australian Fisheries Management Authority (or the Minister for Agriculture, Fisheries and Forestry where appropriate) to enter into an agreement for the strategic assessment of all management plans and policies for Commonwealth managed fisheries. 6.3 How are strategic assessments carried out? The process that is required to be followed for the purposes of a strategic assessment will usually be set out in the agreement between the Minister and the body responsible for the adoption or implementation of the relevant policy, plan or program. However, strategic assessments will usually involve the following steps. Step 1 Step 2 Step 3 Step 4 Step 5 The strategic assessment process is initiated by an agreement being made between the Minister and the person who is responsible for the preparation or implementation of the policy, plan or program. The agreement will determine what matters protected under Part 3 of the Act are relevant for the purposes of the assessment. After the agreement has been made, the proponent is required to prepare draft terms of reference for a report on the impacts to which the agreement relates and release of the terms of reference for public comment. A draft report must be prepared in accordance with the final terms of reference, released for public comment and then submitted to the Minister. After the submission of the report, the Minister is provided with the opportunity to make recommendations on changes to the relevant policy, plan or program and can endorse the plan if the changes are made to the policy, plan or program and the report adequately addresses the impacts to which the agreement relates. Once the Minister has endorsed the policy, plan or program, he/she has a broad discretion as to whether to exempt actions taken under the policy, plan or program from relevant aspects of the standard assessment and approval process. 6.4 Implications of strategic assessments As noted in Step 6 above, if the Minister endorses a policy, plan or program at the completion of a strategic assessment, he/she can exempt actions that are taken under the policy, plan or program from certain elements of the standard approval and/or assessment process. In this regard, the Minister can decide to assess an action that requires approval under the Act in a less onerous manner if the action is taken under a policy, plan or program that was subject to a strategic assessment. So, for example, rather than requiring a public environment report to be prepared for an action, the Minister may decide that the assessment can be carried out by way of preliminary documentation. The Minister can also exempt 8

9 actions taken in accordance with a policy, plan or program that has been endorsed and subsequently accredited under the Act from the approval and assessment requirements. However, if the Minister endorses a management plan or policy for a Commonwealth managed fishery, he/she must accredit the management plan or policy and exempt actions taken in accordance with the plan or policy from the provisions in Part 3 that relate to the Commonwealth marine environment and Commonwealth managed fisheries (ie ss.23 and 24A see above). 6.5 Guidelines for strategic assessments Guidelines for the Ecologically Sustainable Management of Fisheries have been prepared which are intended to assist in the strategic assessment of Commonwealth managed fisheries and the environmental assessment of export fisheries for the purposes of the wildlife trade provisions in Part 13A of the Act. The guidelines are available at: 7. OPPORTUNITIES FOR PUBLIC INVOLVEMENT 7.1 Nominating threatened species, ecological communities and threatening processes The nomination process Any person can nominate a native species, ecological community or threatening process for inclusion on the lists of threatened species, threatened ecological communities and key threatening processes. Nomination forms are currently found at: Nominations are submitted to the Minister, who is required to forward all nominations to the Threatened Species Scientific Committee ( TSSC ) within 10 business days for an assessment on whether the native species, ecological community or threatening process meets the listing criteria (unless the Minister determines the nomination is vexatious, frivolous or not made in good faith, in which case the nomination can be rejected without an assessment being carried out). The TSSC has 12 months to provide its assessment to the Minister. After the TSSC submits its assessment to the Minister, he/she has 90 days to decide whether or not to include the native species, ecological community or threatening process on the relevant list. There is no statutory process for the provision of public comments on nominations. However, the Minister has instituted a practice of calling for public comments on all nominations after the TSSC has submitted its assessment. Notices calling for public comments on nominations are published on Environment Australia s website at: Copies of the TSSC s assessment and reasons for the Minister s decisions can be obtained on request (and may also be published on Environment Australia s website). Advice on preparing nominations may be obtained from the Threatened Species Network (see below for contact details) and the EPBC Unit. Why are nominations important? Inclusion of species and ecological communities on these lists is important for several reasons, including the following. Listed threatened species (except extinct and conservation dependent species) and ecological communities (except vulnerable ecological communities) are matters of national environmental importance and, therefore, are protected under Part 3 of the Act. Members of listed threatened species (except conservation dependent species) and ecological communities are protected under Part 13 in relation to actions taken in Commonwealth areas. 9

10 The Minister can include habitat that is critical to the survival of a listed threatened species or ecological community on the Register of Critical Habitat. Habitat on the register that is in a Commonwealth area is protected under Part 13 of the Act. There are stringent controls on the export of members of listed threatened species and specimens derived from listed threatened species under Part 13A. Recovery plans or wildlife conservation plans can be prepared (and in many cases, must be prepared) for listed threatened species and ecological communities. These plans set out steps required to protect and conserve the relevant species or community and can result in the provision of government funding for the implementation of the plan. The listing of a species or ecological community as threatened under the EPBC Act can substantially improve the prospects of obtaining government assistance for projects associated with their protection and conservation. In this regard, listed threatened species and ecological communities are a priority area for funding under the Natural Heritage Trust. 7.2 Wildlife conservation plans As discussed above, the Minister can make wildlife conservation plans to aid in the protection, conservation and management of listed marine species or cetaceans that occur in Australia or an external territory. Before making a wildlife conservation plan, the Minister is required to invite members of the public to comment on the proposed plan and must consider these comments when making his/her final decision in relation to the plan. The Minister may also provide financial and technical assistance to any person to implement a wildlife conservation plan. 7.3 Public participation in the assessment and approval process As noted above, members of the public will usually be given an opportunity to comment on referrals and actions undergoing assessment under the Act. For more information on public participation in the approval and assessment process, see the EPBC Unit Fact Sheet on Public Participation. 7.4 Public participation in the permit process registration for consultation In order to be notified of permit applications, you must be included on the register for consultation about permit applications under s.266a. Once a year, the Minister will publish a notice on Environment Australia s website inviting members of the public to register their names on the public consultation register. To register, all you need to do is write to the Minister during the period specified in the notice and ask to be included on the register. Once you are included on the register, you will receive notice of all permit applications made under Part 13 (ie those relating to actions in Commonwealth areas concerning listed marine species, cetaceans, listed threatened species and ecological communities, and listed migratory species) and be asked to provide comments on whether the permits should be issued. You will have a minimum of 5 days to submit your comments. 7.5 Strategic Assessments As noted above, there are opportunities for members of the public to participate in strategic assessments. In this regard, members of the public will be provided with an opportunity to comment on draft terms of reference for strategic assessments and draft strategic assessment reports. 10

11 8. WHERE TO GO FOR FURTHER INFORMATION The EPBC Act and related information is available on Environment Australia s website at: EPBC Unit Website: Ph: (02) Fax: (02) epbc@wwf.org.au Environment Australia Community Information Unit Ph: ciu@ea.gov.au Compliance and Enforcement Ph: (02) compliance@ea.gov.au WWF Australia Website: Phone: enquiries@wwf.org.au Humane Society International Website: Phone: (02) enquiries@hsi.org.au Tasmanian Conservation Trust Website: Phone: (03) tct@southcom.com.au Threatened Species Network Website: National Environmental Defender s Office Network Website: Warning!! This fact sheet has been prepared for information purposes only. WWF Australia, Humane Society International and the Tasmanian Conservation Trust shall not be liable for any loss or damage that may be occasioned directly or indirectly through the use of, or reliance on, the contents of this document. 11