Chapter 3
Other key issues
Introduction
3.1
This chapter examines other key issues raised in evidence to the
inquiry, including:
-
the process followed for the 2014 modification;
-
cultural heritage issues;
-
the potential impacts of the excision proposal; and
-
the possible international reaction to the proposal, including
the World Heritage Committee's likely response.
Process followed for the 2014 modification
3.2
As noted in the previous chapter, the Department of the Environment's
evidence made clear that the starting premise for the boundary modification
proposal was the commitment made by the coalition during the 2013 federal
election campaign to seek a reduction in the World Heritage boundary.[1]
3.3
The Department of the Environment advised that it was asked to undertake
a review of the 2013 extension after the Minister wrote to the Chair of the
World Heritage Committee on 18 December 2013. The Minister requested the
Department of the Environment to prepare the minor boundary modification for
submission to the World Heritage Centre by 31 January 2014.[2]
3.4
In response to the committee's questioning on this issue, the Department
of the Environment indicated that it was given only a few weeks to prepare the
dossier provided to the World Heritage Committee:
In early January 2014, departmental staff met with the
Minister for the Environment, the Hon Greg Hunt MP to discuss principles for
preparing the first draft of the minor boundary modification. The first draft
map of the proposed excisions was prepared by the Department following this
meeting and provided to the Minister on 21 January 2014. The final map was
provided on 29 January 2014.[3]
3.5
The Department also advised that it:
...consulted with the Department of Agriculture in relation to
data. The Department and the Department of Agriculture also sought information
from the Tasmanian Government. Beyond this, the review was largely informed by
information that the Department already had access to including composite
aerial photographs and other remotely sensed imagery, and data publicly
available from the Tasmanian Government.[4]
3.6
The Department advised that 'a range of factors were considered in
preparing the minor boundary modification proposal to meet the Government's
election commitment'. The Department indicated that this included:
-
a review of the world heritage values;
-
use of available maps and data to identify areas within the
extension that clearly show signs of previous disturbance from forestry
activities;
-
the need to create a coherent and sensible management boundary;
-
connectivity between the property and national parks or other
formal reserves that existed prior to June 2013; and
-
the retention of as much tall wet eucalypt forest, giant trees
and habitat for nationally listed threatened species as possible while also
providing access for improved economic returns for Tasmania.[5]
3.7
In terms of consultation processes and expert advice on the proposal,
the Department of the Environment advised that:
Departmental staff provided advice on the values and the
requirements for the Australian government's submission. No independent
scientific or heritage expert peer review was undertaken.[6]
3.8
A departmental representative added that:
...the consultation with the community around the government's
election commitment was undertaken by members of the now government during the
election campaign. The department did not add to that consultation between the
period of being asked to prepare the dossier and its submission at the end of
January.[7]
3.9
The Department also advised that it 'did not undertake any field visits
as part of preparing the revised boundary modification requests', and nor did
it have access to Forestry Tasmania's coupe data.[8]
3.10
During the committee's Canberra hearing, the Department of Agriculture
advised that it had provided data to the Department of the Environment on the
distribution of plantations, and also data relating to special species timber
resources.[9]
In response to the committee's questioning as to the need for the data relating
to special species timber, the Department of the Environment advised:
In advising the government on the possible options that might
be available for a minor boundary modification, we wanted to take into account
the potential alternative uses that had raised concern in Tasmania, and so we
used all of the available data layers that we had. The process of reserve
boundary design often involves overlaying competing issues...[10]
3.11
However, several submitters and witnesses queried the adequacy of this
process. Concern was expressed that the 2014 proposal 'has not been through any
consultation process whatsoever'.[11]
It was also suggested that the motivation for the proposal was purely political
and not based on scientific evidence nor world heritage criteria and values.[12]
In their joint submission, The Wilderness Society, ACF and Environment Tasmania
submitted that the 2014 proposal fails to identify or address the Outstanding
Universal Values affected by the proposed excision and is 'demonstrably flawed
in its arguments, lacks genuine evidence and supportive information and is
politically motivated'.[13]
3.12
Indeed, the process for the proposed 2014 modification was contrasted by
some with the process leading up to the 2013 listing, as discussed in the
previous chapter.[14]
For example, the Wilderness Society, ACF and Environment Tasmania submitted
that the 2014 minor boundary modification proposal:
...provides a stark contrast to the comprehensive and
persuasive arguments of 2013. Very little real information is provided. The
claim that the areas proposed for excision 'contain logged/degraded' areas is
used ad nauseum as a one-size-fits-all argument irrespective of context
or validity. No statistics or maps pertaining to the 'logged/degraded areas'
are provided. No arguments of substance are advanced. Key issues are ignored.
No back-up materials in the form of references, illustrations or appendices are
provided. It is devoid of references to past requests made by the World
Heritage Committee with respect to the Tasmanian Wilderness.[15]
3.13
Ms Anne McConnell, Vice-President of the Tasmanian National Parks
Association, similarly told the committee of the Association's concern:
...that the proposal for withdrawing some of those areas does
not seem to have gone into a lot of detail on what the existing values in those
areas are and what will be lost and what will not be lost.[16]
3.14
In same vein, Australian ICOMOS submitted that it is:
...alarmed that this proposal by the Australian Government
fails to respect that due process was followed by the World Heritage Committee
and that Outstanding Universal Value has been established as the prerequisite
for the decision to support the 2013 Boundary Modification. We hence query how
the Australian government states it believes the excision of identified areas
from the property will enhance the credibility of the World Heritage listing.
The opposite seems more likely.[17]
3.15
Australian ICOMOS concluded that:
...the proposal appears to be driven by political and economic
imperatives arising from the recent change of Federal government in Australia,
and by ongoing lobbying in relation to the proposed changes to the way logging
is managed in the State of Tasmania. This is made clear in points 5 and 6 of
the Australian Government submission to UNESCO.[18]
Minor or significant boundary
modifications
3.16
As noted in Chapter 1, modifications to boundaries of World Heritage
properties are covered under the Operational Guidelines and can be considered
either 'minor' or 'significant'. There was some discussion during the committee's
inquiry as to whether the Government's current proposal can be considered a
minor boundary modification, and indeed whether the previous 2013 extension
should have been treated as a significant rather than a minor modification.
2014 proposal
3.17
Several submitters and witnesses suggested that the proposal would not qualify
as a minor modification but should be considered a significant modification due
to its impacts on the Tasmanian Wilderness World Heritage Area.[19]
For example, Mr Peter Hitchcock, a world heritage consultant, told the
committee that paragraph 163 of the Operational Guidelines:
...requires that any proposal for a minor modification of a
boundary does not affect its outstanding universal value. My advice is that the
proposal does affect the outstanding universal value of the World Heritage
area. Therefore, arguably, it should not be considered a minor modification.[20]
3.18
Mr Adam Beeson from the EDO (Tas) noted that an application by Tanzania
for removal of an area, for the purposes of building a uranium mine, was
considered a significant modification by the World Heritage Committee even
though it was removing only one per cent of the area in question.[21]
He therefore suggested that:
...this proposal should not be framed as a minor modification.
The most relevant decision of the World Heritage Committee in relation to the
Selous Game Reserve in Tanzania suggests that altering boundaries to allow for
resource exploitation, which plainly this application is, should be done via
the significant modification process. It would strengthen the convention for
this to be the position, as applying for a significant modification is a longer
and more in-depth process than for a minor modification.[22]
3.19
ANEDO argued that because the objective of the World Heritage Convention
is preservation, the process for removing areas should be more rigorous than
the process of extending boundaries. ANEDO therefore believed that 'applications
to reduce the area of a listed property, particularly if motivated by
resource exploitation, should be characterised as significant modifications'.
ANEDO argued that this view 'is supported by the past practice of the World
Heritage Committee'.[23]
3.20
In relation to this issue, representatives of the Department of the
Environment advised that the Operational Guidelines:
...distinguish between minor and significant modifications on
the basis of their impact on the outstanding universal value of the property.
Boundary modifications should enhance protection of the property's outstanding
universal value through contribution to the criteria for which the property was
inscribed on the World Heritage List, the integrity and/or authenticity of the
property and aspects of its protection and management.[24]
2013 extension
3.21
Some witnesses also suggested that the 2013 extension should not have
been treated as a minor modification, since it was an increase of over 10 per
cent of the original area.[25]
For example, Mr Denman of the Tasmanian Special Timbers Alliance suggested
that, given that the 2013 extension was around 12 per cent of the original
area, it was a not a 'minor' adjustment and, as such, it should have undergone
a full assessment.[26]
The Huon Resource Development Group called the 10 per cent figure an 'absolute
upper limit'.[27]
3.22
Other witnesses described the number of 10 per cent as a 'rough guide'
and a 'rule of thumb'.[28]
For example, Mr Tom Baxter advised that the Operational Guidelines indicate
that it is not just about the size of the modification, but also the impact of
the modification on the outstanding universal value.[29]
Mr Beeson from the EDO (Tas) similarly explained that modifications need to be
considered in the context of the objectives of the convention, and as such 'it
is not just about the land area, it is about the purpose for the modification'.[30]
3.23
ANEDO pointed out that the IUCN advisory report to the World Heritage
Committee had in any case addressed this issue in 2013. The advisory report
stated:
IUCN notes that the size of the property is around the
unofficial upper level for consideration as a minor boundary modification
(which has been considered as typically c.10%). IUCN considers that it is
reasonable and appropriate for the Committee to approve the proposal through
the minor modification process, given (a) the clear and established position of
the World Heritage Committee noted in its past decisions, (b) the degree of
past consideration of these issues by the Committee and Advisory Bodies,
including via both evaluation and monitoring missions, and (c) clear analysis
provided in the proposal regarding its values, integrity, protection and
management.[31]
3.24
A representative from the Department of the Environment confirmed that
'the 10 per cent figure in the operational guidelines for minor boundary
modification is a general guide to state parties'.[32]
She further advised that the World Heritage Committee had been 'disposed to
accept' Australia's application in 2013, particularly since it 'had requested
for a number of years that it receive such an increase in the property's area'.[33]
Cultural heritage issues
3.25
A number of submitters raised cultural heritage as an issue, both in
relation to the original June 2013 extension and the current proposed
modification. As Australian ICOMOS pointed out:
Any assessment of World Heritage values and the current
proposal for a boundary modification in the TWWHA [Tasmanian Wilderness World
Heritage] cannot be undertaken in isolation of the significant cultural
heritage values related to the WHA and its surrounds.[34]
3.26
In approving the June 2013 extension, the World Heritage Committee noted
that:
...the proposed minor boundary modification has been submitted
under natural criteria only although it appears to contain significant cultural
attributes that relate to those located within the inscribed property.[35]
3.27
The World Heritage Committee requested that Australia address the
following concerns regarding the cultural values of the property:
- Undertake further study and consultation with the
Tasmanian Aboriginal community in order to provide more detailed information on
the cultural value of the additional areas and how these relate to the
Outstanding Universal Value of the existing property;
- Provide detailed information on the legal provisions for
the protection of cultural heritage in the extended property;
- Provide detailed information on the management
arrangements for cultural heritage and in particular for the control of access
to archaeological sites and sites of cultural significance.[36]
3.28
At the time the Tasmanian Wilderness World Heritage extension proposal
was approved by the World Heritage Committee, the then Minister for the
Environment, the Hon Tony Burke MP, acknowledged that, while the natural values
had been listed, 'there was still more work to be done in protecting the
cultural values'.[37]
On 19 June 2013, the Minister therefore announced funding for a study to 'help
identify cultural values in the Tasmanian Wilderness World Heritage Area'. The
Minister noted that:
There are known sites of Aboriginal cultural heritage value
recorded within the proposed boundary modification...However, further work is
required to better understand and articulate how these sites, especially those
in the proposed boundary modification, contribute to the Tasmanian Wilderness'
Outstanding Universal Value.[38]
3.29
The Minister stated that 'the study will be designed and undertaken in
close consultation with the Aboriginal community in Tasmania' and would be
'forwarded to the World Heritage Committee in February 2015'.[39]
3.30
The Australian Government's 2014 proposal acknowledges that the cultural
values of the 2013 extension:
...require further study and consultation with the Tasmanian
Aboriginal community in order to better document and understand how these
relate to the Outstanding Universal Value. The current proposal retains many of
these important features within the property.[40]
3.31
Australian ICOMOS submitted that:
While we had concerns that the 2013 proposed boundary
modification did not include an assessment of cultural values, the 2013
decision has more by accident than design provided for the inclusion and hence
protection of some places of significant cultural value...[41]
3.32
Indeed, several submissions and witnesses identified culturally
significant sites in the areas proposed to be excised from the extended World
Heritage Area.[42]
For example, Australian ICOMOS identified sites such as:
-
Nanwoon Cave (in the Mount Wedge-Upper Florentine Section);
-
Navarre Plains area (Upper Derwent Section); and
-
the Recherche Bay West area (Recherche Section).[43]
3.33
Mr Peter Hitchcock informed the committee that his research indicated
that at least 24 Aboriginal cultural sites may be adversely impacted by the
proposed delisting.[44]
3.34
The Law Council of Australia strongly supported ongoing consultation
with Tasmanian Aboriginal communities regarding the management of the listed
property and recommended the Australian Government:
-
undertake the cultural heritage protection studies, reporting,
and consultation activities requested by the World Heritage Committee; and
-
ensure adequate resources are made available for the
identification of cultural heritage values in the Tasmanian Wilderness World
Heritage Area and development of management strategies to protect those values.[45]
3.35
However, as the Tasmanian National Parks Association submitted, 'the
full significance of the cultural values relating to previous Aboriginal
occupation in the areas marked for revocation is yet to be determined'.[46]
3.36
For this reason, a number of submitters and witnesses told the committee
that it is premature for the Government to be pursuing this modification prior
to the completion of the assessment of the cultural values assessment. For
example, Australian ICOMOS noted that Australia is required to report on its
assessment of cultural values to the 39th session of the World
Heritage Committee in 2014, and as such 'it is premature to be proposing any
modification before that time'.[47]
3.37
The Tasmanian Aboriginal Centre agreed, stating that it is 'stunned'
that the Government is:
...seeking to repeal the TWWHA boundaries without undertaking
full and proper consultation with the Tasmanian Aboriginal Community, in order
to determine the Aboriginal Cultural values as requested by the WHC [World
Heritage Committee]. Until an extensive assessment of the Aboriginal Cultural
Values conducted by the Aboriginal Community has occurred, both the Government
and the World Heritage Council will not be able to make informed decisions.[48]
3.38
Several submitters also expressed concern as to the status of the study
to help identify cultural values in the Tasmanian Wilderness World Heritage
Area.[49]
For example, Australian ICOMOS submitted that:
We have not been able to gain a reassurance that the $500,000
committed last year by the Federal Labour government to undertake the cultural
assessment will be forthcoming under the Federal Coalition government.[50]
3.39
In response to questioning on the status of the cultural heritage
assessment, the Department of the Environment advised that that the 'project
has not yet commenced and funding has not yet been provided'.[51]
Impacts on the Tasmanian Wilderness World Heritage Area
3.40
Several submitters and witnesses expressed concern about the impact that
the proposed removal of areas would have on the values and integrity of the
Tasmanian Wilderness World Heritage Area. It was suggested that the removal of
areas alone would diminish the values and seriously damage the integrity of the
Tasmanian Wilderness World Heritage Area.[52]
Mr Hitchcock told the committee that:
The proposed delisting will have a serious impact on the
outstanding universal values—as defined in the operational guides—of the Word
Heritage area. Firstly, there will be a serious impact on the integrity of the
World Heritage area, especially in regard to the tall eucalypt forests. I
should point out that at present the tall eucalypt forests in the Tasmanian
World Heritage area represent the world's premier example of temperate tall
eucalypt forests. The truncation of these forests by the proposed delisting
would seriously detract from the outstanding universal value of these
magnificent forests.[53]
3.41
Mr Bayley from The Wilderness Society told the committee that the Tasmanian
Wilderness World Heritage Area:
...was greatly enhanced by this 2013 minor modification—the
giant hardwood trees of the Styx Valley; other extensive tracts of a connected
band of tall eucalypt forests up the eastern boundary of the World Heritage
Area; intricate and spectacular cave systems, such as in the Florentine and
Mole Creek; rainforests in Dove River; and the forested slopes of the Great
Western Tiers. It absolutely added to the integrity of the property.[54]
3.42
The Wilderness Society, ACF and Environment Tasmania submitted that 'the
impact of the proposed excisions on the Outstanding Universal Values, integrity
and management of the Tasmanian Wilderness would be severe', including:
-
significant loss of old growth forest, including tall-eucalypts
and rainforest;
-
loss of scenic viewfields;
-
loss and fragmentation of habitat of threatened species;
-
loss of significant areas of karst and glacial landscapes;
-
loss of integrity in certain key catchments;
-
disrupted ecological processes involving the dynamic
relationships between eucalypt forest, buttongrass and rainforest;
-
loss of Aboriginal cultural heritage sites; and
-
loss of effective management boundaries along several sections of
the eastern and northern boundaries of the Tasmanian Wilderness.[55]
3.43
Several submitters and witnesses emphasised that the proposed excision
would result in a 'serious loss of boundary integrity'. Mr Peter Hitchcock, for
example, told the committee that:
Notwithstanding statements to the contrary in the submission,
the new boundary that would result from the proposed delisting is
ill-considered, and would be regarded as seriously compromising the integrity
of the existing World Heritage boundary.[56]
3.44
Indeed, Mr Hitchcock described the new boundary as a 'very much more complicated
boundary, as well as leaving out important items of conservation value'. He
went on to state:
The proposed delisting creates absolute havoc, creating a
boundary which in some cases is quite laughable, unfortunately. It would turn
the clock back in a lot of places, adopting quite inappropriate boundaries. I
tabled the matter of the Navarre Plains, where it re-creates a boundary which
was previously seen to be quite inappropriate, not just in terms of management
but in terms of protection of that important glacial precinct.[57]
3.45
Mr Hitchcock provided the revised boundary in the Great Western Tiers
area as an example of an inappropriate change:
The removal, which appears to be very ad hoc, of a number of
areas on the Great Western Tiers means that the boundary now becomes quite
inappropriate. In places, the boundary runs along the top of the cliff, dives
down to the bottom of the hill, down to the low lands, follows the low lands
for a little while and then goes back up to the tops of the cliffs. In other
words, it becomes a completely inappropriate boundary for any World Heritage
area.[58]
3.46
Mr Law for The Wilderness Society agreed that the new boundary would be
more complex and would complicate management of the property. Mr Law concluded
that 'overall the integrity of the World Heritage Area will be reduced if that
excision ahead'.[59]
3.47
Professor Brendan Mackey concluded that:
...any argument that excising these 74,000 hectares will
somehow enhance the integrity and connectivity flies in the face of the facts
and scientific understanding...the proposed excision will lead to worse not
better outcomes for boundary coherence, connectivity and the retention of
heritage values.[60]
3.48
Concerns about the impact of the proposed excision were exacerbated by
the prospect that the areas are likely to be opened up for forestry activities,
as discussed elsewhere in this report.[61]
3.49
In relation to the world heritage values, the Department of the
Environment advised that:
The current boundary of the Tasmanian Wilderness World
Heritage Area remains in place and the values of the property continue to be
protected under national environment law until a decision on a new boundary is
adopted by the World Heritage Committee, in which case any areas that the
Committee agreed to remove would no longer have World Heritage status.[62]
Possible international reaction to the proposal
3.50
Another key issue raised in evidence was the impacts of the proposed
excision on Australia's international reputation and obligations. Several
submitters and witnesses expressed concern that the proposal and possible delisting
of areas would damage Australia's international standing and reputation on
matters of environmental protection.[63]
Several witnesses described it as 'embarrassing'.[64]
For example, Mr Law stated that:
...a proposal as threadbare and lacking in factual information
and as oblivious to World Heritage values as the proposal before it this time
will bring Australia into disrepute at that international level.[65]
3.51
Mr Bayley from The Wilderness Society was concerned that the excision
proposal is 'incredibly insulting to the World Heritage Committee' and was
'snubbing the work that they have done over decades and the unilateral decision
that they made last year to list this property on all four natural heritage
values criteria'.[66]
3.52
ANEDO was similarly concerned that the 2014 proposal 'may be construed
as insulting' because 'the clear implication would be that the Australian
Government believes the [World Heritage] Committee got it wrong in 2013'.[67]
3.53
Several submitters were also concerned that the proposed removal would
breach Australia's international treaty obligations. For example, the Tasmanian
National Parks Association pointed out that, under the World Heritage
Convention, Australia has acknowledged in article 4 its duty to 'do all that it
can...to ensure the identification, protection, conservation, presentation and
transmission to future generations of the cultural and natural heritage
situated within its territory.'[68]
3.54
It was argued that the World Heritage Committee, by inscribing the
extension on the World Heritage List, had 'legally acknowledged their
outstanding universal value' and that 'delisting, then logging, these forests
would contravene Australia's treaty obligations'.[69]
3.55
Mr Law for The Wilderness Society declared that:
By putting forward this proposal, the Australian government
is in breach of its international obligations under the World Heritage
Convention already and has been grossly misleading and deceitful towards the
Australian public in its use of the term 'logged/degraded areas'.[70]
3.56
Mr Adam Beeson from the EDO (Tas) expressed further concern that the
proposal could 'weaken the World Heritage Convention', and that it is
inappropriate 'for state parties to be bringing in domestic political
considerations to what they say to the World Heritage Committee'.[71]
Precedents for reductions in World
Heritage Areas
3.57
Others were concerned about the potential precedent that Australia might
be setting with its proposal. For example, ANEDO argued that:
Modifying properties on the basis of domestic political whim
is a bad precedent to set...This precedent could open the flood gates for
signatories to the Convention to seek modification or removal of properties to
satisfy domestic political demands. More broadly it sets a precedent that
matters not the subject of the Convention can be invoked in order to modify
boundaries and, by extension, to list and de-list properties.[72]
3.58
Friends of the Earth also supported this argument and commented that:
...advanced economies like Australia should be leading the way
globally on matters of environmental protection. If a country like Australia
seeks to reduce existing environmental protections through de-listing of high
conservation ecosystems, this would set a negative example to other nations in the
world.[73]
3.59
Submitters, including the Law Council, noted that there are examples of
request to modify boundaries to excise areas from listed World Heritage
properties. However, these are small in number and modification is unusual. The
Law Council noted that there have only been a limited number of requests to
modify boundaries to excise areas from listed World Heritage properties.[74]
3.60
For example, the Law Council noted that the World Heritage Committee
approved Tanzania's request to exclude an area from the Selous Game Reserve in
2011 to facilitate mining, in light of the 'exceptional' economic situation
facing Tanzania and included a number of conditions. According to the Law
Council, a request by the Government of Guinea to reduce the Mt Nimba Nature
Reserve to allow for mining was rejected in 1991 and the property was
subsequently added to the World Heritage In-Danger list.[75]
3.61
On the other hand, in 1995, the Law Council observed that the Willandra
Lakes World Heritage Area in Australia was reduced by around 30 per cent,
because the World Heritage Committee 'was satisfied that the revised boundaries
better reflected the areas in which the cultural and natural values of the
property were located and would allow better management of those values'.[76]
3.62
Given these examples, the Law Council commented that 'it would be
unusual for the boundary of a World Heritage Area...to be modified without
evidence of a significant change in ecological conditions which compromises the
world heritage values of the area'.[77]
The Law Council further concluded that the previous examples demonstrate that
boundary modifications:
...will be considered [by the World Heritage Committee] only
in exceptional circumstances and where there is clear evidence of management
strategies to improve management of Outstanding Universal Values across the
balance of the listed property.[78]
3.63
ANEDO similarly noted that 'past practice indicates boundary
modifications are usually sought in the form of extensions, rather than
reductions'.[79]
Mr Geoff Law agreed that 'the World Heritage Committee does not take lightly
delisting areas'.[80]
3.64
In response to the committee's questioning on this issue, a
representative of the Department of the Environment advised that:
...the operational guidelines state that they are required to
enhance the property, and it is unusual, if not unprecedented, for that to be
achieved through the reduction in area of a property, unless there is a
corresponding addition of another area elsewhere.[81]
Possible response of the World Heritage Committee
3.65
There was some speculation during the committee's inquiry as to the
World Heritage Committee's likely response to the proposal, with some suggesting
that it could reject the proposal.[82]
ANEDO expressed the view that:
The approval of this minor modification request, in light of
previous decisions of the World Heritage Committee, would be extraordinary and
its prospects of success must be considered remote.[83]
3.66
Others warned that the 2014 proposal could ultimately result in the
placement of the entire Tasmanian Wilderness Area on the 'World Heritage in
Danger' list.[84]
3.67
The Department of the Environment advised that 'it is anticipated that a
draft decision of the World Heritage Committee will be released on 16 May' 2014
and that the final decision will be made at the 38th session of the
World Heritage Committee between 15 and 25 June.[85]
The Department further advised that there are four possible decisions that the
World Heritage Committee could make:
The World Heritage Committee could choose to accept the
Australian government's request for the minor boundary modification. They could
reject it outright. They could refer it back to us for additional information
that would require us to submit it either the following year or, at the very
least, within three years for further consideration by the committee. Or they
could defer it for substantial revision or a more in-depth assessment, which
would result in the request of the Australian government being evaluated over
an 18-month period and then going to the meeting two years hence.[86]
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