South Sister St. Marys, Tasmania

South Sister

community audit

Community Audit of Forest Practice Plan
for Coupe NI114A


The Forest Practices Plan (FPP) for the South Sister is seriously deficient in two respects. Firstly, it is deficient in terms of fact. For example, much information about the ecology, details of the operation and how the logging relates to the specific qualities of the coupe has not been included in the FPP. In addition, it is deficient in terms of the documents that set down its guiding principles. These are the Forest Practices Code (FPC)1 and the strategic planning documents, primarily the Bass Forest District Management Plan2.

These deficiencies have raised a series of comments and specific questions that are recorded below. The general comments precede the specific questions. For ease of reading, the questions follow the format of the FPP.


There are no plans to protect biodiversity (see Forest Management Plan p. 16, 'Forestry Tasmania is active in strategic planning for biodiversity.')
There is no 'strategic management plan' for the threatened species recorded on or around the coupe as mentioned in the Bass Forest District Management Plan (p 20).

There has been insufficient information gathered about many environmental and cultural values (water quality and flow, geomorphology, soils, biodiversity and threatened species, cultural heritage etc) which are required when planning a FPP (FPC p 4).

Erosion and Landslips
There has been an inadequate assessment of both erosion risk and landslides on this coupe and in the general area. Landslips have occurred over the entire Nicholas Range, Huntsman, South Sister, Cheeseberry Hill, German Town and other surrounding areas in ancient times as well as more recent times (past 50-100 years).

The FPC states that 'Forest operations should not result in a significant deviation from natural rates of erosion and landslides' (p 52).
Independent assessments by a Geotechnical consultant Stapledon, Road/Landslip Engineer Rallings and a Geomorphologist van der Maesen have all expressed concern that further slides post land disturbance is a high risk. Latinovic3 also states that 'over a period of time, landslides may develop'. Both Stapledon and Rallings refute the comments made by Peter McIntosh of Forest Practices Board:

'that almost all parent materials on slopes in Tasmania have formed in part by previous erosion under a different climate from that prevailing now and past "failure" or erosion is not necessarily an indication of present risk'4 (see attached reports).

Stapledon concludes that the risk of landslides in an area previously affected is very high - perhaps 75% (see reports attached). The presence of coal in this region appears to increase the risk of land slides (see Rallings report) with slides being recorded at Jubilee mine, Huntsman’s Cap5 and above the Mt Nicholas Mine6 within the past 50 years. In addition, in an email from Gaughwin7 to Andrew Crowden, FT in July 2003, she stated that 'coal mines are particularly sensitive to collapse if the workings were shallow. As well as the heritage matters it would well to stay at some distance from these'.

It is yet unclear whether blasting will occur on the coupe however any blasting may also have significant consequences for landslips.

With regard to soil erosion, a first report by Owen Ingles states that sheet erosion is likely if logging goes ahead. A further report is pending and will be forwarded when available.

Mining has occurred at the nearby Jubilee and Cardiff mines. A map of the mines shows major tunneling under the coupe. It would appear that there has been little consideration not only of their historical significance, but the presence of the very extended mine workings which may impact on the operation.

Cultural Heritage
There has been inadequate assessment and evaluation of cultural heritage with no recognition of stumps identified on the southern edge of the coupe left from local sawmilling operations in the past (see photos attached). In days gone by, a Forestry inspector would assess the volume of each tree removed by reference to the stump size. He would stamp the stump with his crown seal and then place a stone on top. This coupe is a significant heritage site embodying the interaction of local forestry resources, local sawmilling and the local railway history, justifying a track and interpretation sign. The failure to note and plot these sites in the Cultural Heritage evaluation and to make prescriptions for their protection by excluding these areas from roading/harvest activities represents a significant failure of planning which is required by the FPC.
In addition, the Sisters have been culturally significant for more than 200 years when Nicolas Baudin painted both South and North Sisters in 1802. It is also alleged that the English explorer Tobias Furneaux named what is now known as the North and South Sisters, 'The Sisters'.

Water quality and quantity
David Leaman, Geohydrologist, considers that logging this coupe will pose a major threat to the local residents' water supply (German Town, Gardiners Creek and Dublin Town) which is supported by Milodan Latinovic, (Geologist, Mineral Resources Tasmania)8. Leaman also postulates that St Marys’ town water supply may also be significantly affected as the coupe serves as the recharge area for the St Marys town bore (see Leaman Report 1 and Report 2 for more details).

Inadequate information has been collected by Forestry Tasmania and the Forest Practices Board to make a comprehensive assessment about the water catchment area of the south Sister. Many springs, soaks and wet areas on the coupe have not been identified by FT. Local residents have recorded an additional 24 sites that are shown on the map together with a list of coordinates. It is very likely that there are many more as yet unrecorded sites.

FT’s prescription for the German Town spring is insufficient when the catchment area for this spring is likely to be much greater than the buffer considered to be adequate by FT. A 300 meter buffer to springs has been provided in other areas in Tasmania19, however they do not consider it necessary for the German Town spring and a buffer of less than 100 metres is planned.

FT’s hydrology report by Sandra Roberts9 fails to address issues of groundwater, to obtain relevant information about local rainfall in the immediate area and to be aware of the local intense rainfall events which are not uncommon in this region. She does make the point however, that it is expected that there will be a reduction in water quantity for up to 56 years which is obviously of great significance to the local community.

Biodiversity and threatened species
There has been insufficient assessment to determine the known occurrences and potential habitat of threatened species (FPC p 61). Many threatened species have previously been recorded on or in very close proximity to the coupe and include

The FPP incorrectly identifies trees on the coupe e.g. Eucalyptus viminalis is not found on the coupe but rather E. dalrympleana showing an ignorance of even basic botany.

The Natural Values Sheets do not constitute an empirical assessment of known localities or occurrences of species with incorrect information for some species e.g. Blind Velvet Worm has been found on the coupe and yet it states that it is 'near coupe' (p 1, Fauna Evaluation sheet). The spotted tailed quoll has been recorded on the coupe yet there is no mention of this nor specific prescriptions made.
Plans for each threatened species are insufficient. Minimal details have been given and in some cases no plan has been provided e.g. sea eagles. No additional surveys have been carried out to ascertain the number of quolls, bandicoots, swift parrots etc that are found in the area.
Road locations have not been assessed for worms despite the FPP stating that 'main roads avoid known localities for this species' (p 7 FPP). Without assessment it is easy to say there will be no impact!

Logging of this coupe will result in destruction of habitat for many species, some of which are threatened. Scientific research carried out on the South Sister shows a large biodiversity and is considered a 'biodiversity hot spot' by Peter McQuillan. Six moths not previously recorded in a Tasmanian National Park have been recorded on the South Sister and ongoing studies continue to gather additional species. A large number of lichens (178 species) were recently identified by two prominent lichenologists Dr Gintaras Kantvilas and Professor Jack Elix10. Two of those identified appear to be new species and a further two are rare enough to be considered for listing on the Tasmanian Threatened Species list (see letter). A recent bird survey identified 36 birds on the coupe including all four robins resident in Tasmania – an unusual occurrence in the one area and a botanical survey (and assessment) in December 2004, recorded 86 species with an additional 10 species identified since then. Those who have surveyed the area or bushwalked, consider that this area has excellent habitat for many fauna – birds, mammals and insects and destruction and loss of under storey will lead to significant loss of habitat. Roy Skabo, President of Society for Growing Australian Plants, Launceston considers that the area is impressive. He, like many scientists and other concerned visitors, recommend further studies of the flora and fauna to document this important and bio-diverse area (see attached letter).

The FPP correctly states that this coupe is an important contact zone between the Blind and Giant Velvet Worms yet this 'line of parapatry', a highly significant conservation value has not been protected. Any logging is likely to lead to destruction or disturbance of this line of parapatry. The line of parapatry is a rare phenomenon with few examples documented in the world. It is the opinion of Alastair Richardson (Head, School of Zoology, University of Tasmania) that this line of parapatry should be treated like a threatened species11 which is supported by Peter McQuillan, Entomologist, University of Tasmania12. An extract from David Horner’s thesis on 'The ecology of Two Parapatric Species of Tasmanipatus ...' is attached to this report to provide more information about the parapatric line13.

There has been no commitment to protect the population of Euphrasia collina ssp. deflexifolia. No attempts have been made by FT to ascertain whether populations other than those previously recorded by Threatened Species Unit, Parks and Wildlife Service, Tasmania exist on the coupe. The FPP map shows some recorded sites but does not include all locations mentioned in the narrative. In recent weeks, local residents have recorded (and photographed) an additional 825 plants on and around the coupe (see map and coordinates). Some of these areas show no obvious disturbance indicating that Euphrasia may grow in both disturbed and non disturbed areas which is contrary to FT's opinion about known habitat. It is very likely that these plants grow on the entire coupe and more research is required.
There has been no research in Tasmania of this plant, pre and post logging therefore it is unknown what the consequences will be for this population post logging (or fire). The plant requires high moisture levels. Logging will result in destruction of under storey, high winds will dry soils more quickly, there will be less tree canopy and under storey cover. Conditions therefore may not be favourable for this plant to regenerate post logging.
Euphrasia is a semi-parasitic plant and in one area of Tasmania (Bruny Island) the plant has parasitized Spanish heath. The coupe is currently free from the heath however it is abundant in the general area and on the German Town Road/Top Marshes Road. It is possible that logging will introduce this weed leading to problems in management and control of heath if Euphrasia parasitizes it.

Logging of this entire coupe will destroy significant populations of Euphrasia. It would appear that NO prescriptions have been made to prevent this – rather, the contrary, with many Euphrasia populations in the proposed logging plan in danger of being destroyed.
The proposed logging of this coupe goes against the Recovery Plan for Euphrasia14 of which one objective states 'securing protection of existing populations from potentially detrimental changes in land use or disturbance patterns'.
The recommendation in the FPP(E. 1. (g)) that a post logging assessment be undertaken one to two years after logging is inadequate. With such a significant population of Euphrasia, NO logging should occur on this coupe.

Eucalyptus globulus can be found on this coupe with recent observations of swift parrot by numerous people (December 2004/January 2005). No prescription has been made to preserve this important habitat of the endangered (Tasmanian and Commonwealth listed) swift parrot.

FT’s survey for wedge-tailed eagles nests could only be described as cursory and further work is necessary to cover the area comprehensively and ascertain whether a nest is in the vicinity. Eagles are seen daily or every other day flying around the mountain with a suggestion from a local resident that a nest may be found in Struggle Gully. The entire coupe and surrounding forests are perfect habitat for eagles and additional attempts should be made to reduce the risk of harm if they are on or close to the coupe.

The habitat on the coupe is also very suitable for spotted tailed quolls with quolls having been previously recorded on the coupe. Sadly, no survey has been carried out and no prescriptions have been made for this vulnerable (Commonwealth List) and rare (Tasmania Threatened Species List) animal.

Weed Control
Prescriptions for weed control are unsatisfactory. There are large populations of both Spanish heath and gorse along the road to South Sister. It is very likely that the seeds of these destructive plants will have a good chance of populating the coupe if no washing of vehicles occurs at the entry or close to the entry of the coupe.

Wildlife Habitat Clumps
The large wildlife habitat clump (WHC) on the southwestern side of the coupe is less dense (less trees, little under storey) compared to much of the coupe. In addition, many trees have had their tops blown out or the entire tree has been blown over by wind (see photos)33. The map accompanying the notification form for natural and cultural values mentions this area as non commercial/swamp therefore FT has indeed identified it as having similar qualities as the residents. This seems rather irresponsible.

Fire Management Plan
The FPP has no fire management plan for this coupe but rather a district fire management plan. There FPP lacks details about fire containment, weather conditions, firebreaks, when and how to burn etc. The FPP mentions the necessity to show firebreaks on the FPP map however despite this, they are absent on the map (p 10 FPP).

Other comments
The plan lacks many important details yet it is often repetitive. At times it is contradictory (p 8, dot point 6), some sentences are nonsensical (p 2, dot point 24; p 7, dot point 1), at other times the prescriptions are not plans yet suggestions for the planning stage (page 9, dot point 2).

The certification date precedes other dates and includes the contractor’s dates with an almost two year time period between some of the signed dates. Pages 1 to 15 (inclusive) of the FPP, incorrectly identifies the coupe as N1114A instead of NI114A.


The Forest Practice Plan for Coupe NI 114A is deficient as it has failed to adequately assess various parameters required by the Forest Practice Code.

The risks of negative impacts are high. The risk of landslides post logging are perceived as very probable if there are landscape changes in this unstable area. Water quantity and quality of the local residents is likely to be harmed despite Forestry Tasmania and Forest Practice Boards assurances that water supplies will be adequate. Little is known about the source of St Marys’ water supply and therefore more research is required to obtain an accurate picture of the groundwater system and recharge area for St Marys.

Threatened species on and around the coupe are likely to be harmed by the proposed logging and in some cases, further destruction of their habitat may result in dire consequences for some species.

It would be premature of Forestry Tasmania to proceed with their current plan to log this coupe before further assessments and detailed studies have been carried out.

In my humble opinion, I would rate the overall FPP as of low standard and lacking in professionalism. A more thorough assessment is required and essential before any logging occurs on this coupe.

Dr Frances Daily B.M.B.S., D.T.M.H., DRANZCOG
February 5, 2005
For Save our Sisters

Specific questions and comments directed to FPB re proposed logging on South Sister - in .rtf (119 KB)
Appendix - full set of references pertaining to this audit
Complete audit in .rtf format (127 KB)

We have received a response to this dated 25 February, 2005.

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Reference 1 - Forest Practices Board (2000). Forest Practices Code, Forest Practices Board, Hobart, Tasmania

Reference 2 - Forestry Tasmania (2000). Bass Forest District Forest Management Plan - March 2000. Forestry Tasmania

Reference3 Latinovic, M. Letter to David Clement, January 7, 2005

Reference4 McIntosh, P.D. Comments by P.D. McIntosh on the Report: 'Appraisal of initial forest plan on South Sister - Nicholas Range: hydrological and landscape observations. D.E. Leaman, 22 November 2003' November 28, 2003. Some of his comments include the following:

'Dr Leaman has correctly attributed erosion of the dolerite to erosion in Glacial periods. It is likely that much of the uneven topography on the land surface related to cool climate processes such as freeze-thaw, solifluction and possibly permafrost. It is debatable whether 'much of the humpiness evident on the southern and eastern slopes of South Sister is due to previous failures'. It must also be pointed out that almost all soil parent materials on slopes in Tasmania have formed in part by previous erosion under a different climate from that now prevailing and past 'failure' or erosion is not necessarily an indication of present risk.'

Also included in these comments are excerpts from an email he sent to Andrew Crowden of Forestry Tasmania on October 14, 2003.

'As with most coupes on dolerite, the risks are few and normal Code provisions should ensure a good environmental outcome.'

Reference5 & 6 Personal Communication John McGiveron, former Operations Manager, Cornwall Coal NL

Reference7 Gaughwin, D. Email to Andrew Crowden July 28, 2003

Reference8 Latinovic, M. Letter to David Clement, January 7, 2005

Reference9 Roberts, S. South Sister and harvesting in NI 114A ,2004

Reference10 Dr Gintaras Kantvilas, Head of Herbarium, Tasmanian Museum and Art Gallery and Professor Jack Elix, Australian National University, Canberra

Reference11 Richardson, A. Letter to Dr Frances Daily, January 28, 2005

Reference12 McQuillan, P. What is special about Parapatric boundaries? January 24, 2005

Reference13 Horner, D. The Ecology of Two Parapatric Species of Tasmanipatus (Onychophora) T. barrette and T. anophthalmus, October 1995

Reference14 Potts, W.C. Recovery Plan for Threatened Tasmanian Lowland Euphrasia Species, Department of Primary Industries, Water and Environment, Hobart

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