Community Audit of Forest Practice
Plan for Coupe NI114A

Introduction
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) and the strategic planning documents, primarily the Bass Forest District Management Plan. 

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.

GENERAL COMMENTS
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.  Latinovic 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" (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 Cap and above the Mt Nicholas Mine within the past 50 years.   In addition, in an email from Gaughwin 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 (see report).  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 (see map of coal mines attached).  

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).  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 reports 1 and 2 attached 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 an attached map (including 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 Tasmania, 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 Roberts 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
•Blind Velvet Worm
•Giant Velvet Worm
•Spotted tailed quoll
•Wedge tailed eagle
•Eastern barred bandicoot
•Euphrasia collina ssp deflexifolia
•Swift parrots
•Grey goshawks.   

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 (see attached draft report).  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 Elix.  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 and list of lichens identified attached).  A recent bird survey identified 36 birds on the coupe including all four robins resident in Tasmania – an unusual occurrence in the one area (see Lloyd report) and a botanical survey in December 2004, recorded 86 species with an additional 10 species identified since then (see Dudley report).  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 species which is supported by Peter McQuillan, Entomologist, University of Tasmania (see reports attached for more information).  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 line. 

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 attached).  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 Euphrasia 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 comprehensively cover the area and ascertain whether a nest is in the vicinity.  Eagles are seen daily or second daily flying around the mountain with a suggestion from a local resident that a nest can 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).   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.

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.  

Specific questions and comments about FPP PWJ0010 

Cover Sheet FPP No: PWJ0010
The forest type has not been correctly identified – there is no E. viminalis found on this coupe (E. dalrympleana can be mistaken for E. viminalis) nor E. ovata or E. amygdalina.
The operation is within a town water catchment – St Marys-  yet this is denied on the cover sheet.  

Page 1 FPP

B. ACCESS TO THE FOREST

Road maintenance
“Dry to shoulder weather roading only”
Review of the Bureau of Meteorology readings from 6 rain measuring sites around South Sister indicates that there is no dry or shoulder weather in this area.  Roading is due to commence in February yet review of the rainfall in German Town for a 43 year period between 1930 and 1976 and 2004 reveals that February had the highest rainfall recorded on 6 occasions during this time i.e. of all months, February scored the highest rainfall 6 times (6 years of a possible 43).  December recorded the maximum rainfall on five occasions, January, May, July, October and November all experienced the highest monthly rainfall on four occasions and March, April and August scored the highest monthly rainfall on three occasions. Each month recorded the highest rainfall at sometime during this time period. 

It would appear that it is difficult to predict when the best time for roading should occur however from the above it would be suggested that February is not a good choice!
Qu 1. What are FT’s comments about the above statement?

“Road clearing will be of minimum width to reduce the extent of soil disturbance, particularly within streamside reserves, but sufficient trees should be removed to allow the road to dry and to provide adequate line of sight” (p 12 FPC)
Qu 2
2(a) What will happen to E. Brookeriana at the start of the South Sister Road?  Will any trees be removed to widen the road?

Qu 2(b)
What width will the road shoulder be for the 1.2 km upgrade?
Minimizing the destruction of Euphrasia species should be a priority (see page 1 FPP dot point 19).  Since Euphrasia occurs on this road, what is the plan?

Qu 2 (c) 
What is the plan for the road and shoulder adjacent to the Cardiff Coal Mine area and spring?  The FPC states that the width of the road should ensure the road is dry.  The first part of the South Sister Road gets little sun.  The road is always wet around the Cardiff Coal Mine due to a spring, even in relatively dry times.  How will this be solved?

“Avoid road location in …areas where roading would substantially affect significant other values” p 6 FPC 
Qu 2 (d) 
It would appear that significant other values have been overlooked e.g. Euphrasia, E. brookeriana, blind and Giant Velvet Worms, spring near Cardiff mine and the mine itself.  Have surveys been carried out?

Qu 2 (e)
One passing lane will be constructed on the 1.2 km upgrade to reach Class 3 classification.  
Will this area be checked for velvet worms or Euphrasia collina ssp deflexifolia?

Qu 3
“0.8kms of newly constructed class 3 spur roads will be constructed and maintained by FT…….The proposed construction of the class 3 road along the existing power line easement is acceptable without restrictions.  While the species does occur along this easement, it is likely to establish along the new road drains and batters from either soil-stored seed or local seed sources”
3 (a) What evidence does FT have that Euphrasia will establish itself along the new road drains?  
3 (b) Is it possible to upgrade the current Derrick’s Marsh track so a significant Euphrasia colony remains relatively undisturbed?  
3 (c) Why hasn’t the Euphrasia along this Derrick’s Marsh track between recorded on the FPP map?

“The first “bend” that requires straightening should be disturbed on one side of the road only if practical…….If this disturbed soil and rock can be placed into adjacent areas (e.g. the disturbed ground on the southern side of the bend) this is desirable.  
3 (d) There are Euphrasia plants on the southern side of the road that should be protected i.e. no soil, plants or rocks removed from the northern side of the road should be placed here.  

3 (e) In addition, the land on the southern side is private land.  Is “dumping” of vegetation possible?  Where will it be placed? (see above)

3 (f) The area that is to be straightened has many large rocks.  What are the plans for these rocks?  Moving them?  Blasting them?  What will the impact of blasting be (the Jubilee Mine workings are in close proximity).

3 (g)
Has FT checked whether there are Blind Velvet Worms or Euphrasia at this site?

“The species also occurs locally in areas unlikely to be substantially disturbed e.g. along the track just to the north of the easement”.

3 (h) 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 recorded by DPIWE exist on the coupe. The current map does not include all locations mentioned in the FPP.  
In recent weeks, local residents have recorded (and photographed) an additional 825 plants on and around the coupe.  Some of these areas are growing where there has is no obvious disturbance indicating that Euphrasia may grow in both disturbed and non disturbed areas.  It is very likely that these plants grow on the entire coupe (see map).  
There has been no research in Tasmania into 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 (less ability to maintain water); high winds will dry soils more quickly with less tree and under storey cover.  Conditions therefore may not be favourable for this plant to regenerate post logging.  

Plants have been found close to landings yet the FPP states that if these landings are topographically most suitable, they can remain providing heavily populated areas are avoided.  This is rather contradictory!   Compaction of ground on these landings will further result in reduced regeneration at these sites.    
Euphrasia is a semi-parasitic plant and in one area of Tasmania (Bruny Island) has parasitized Spanish heath.  The coupe is currently free from the heath however it is abundant in the general area.  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 Euphrasia (Wendy Potts, DPIWE, 2000) of which one objective states:
“securing protection of existing populations from potentially detrimental changes in land use or disturbance patterns”.  

The recommendation (E. 1. (g)) in the FPP 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.

3 (i) Will logging proceed after the plant has seeded? 

3 (j) Are road workers (and loggers) provided training or information about Euphrasia collina ssp deflexifolia so they can identify the plant and hence protect it?

“The roading engineer will identify any potential sites that may be cause for concern” (landslides)  
3 (k) Has the roading engineer visited the coupe?  If so, has s/he recommended any sites that need special attention to avoid concentrating water around land slip areas?  
3 (l) What is the engineer’s recommendation around the Cardiff mine site?  This area is very steep and a permanent spring is also present.  Two landslips have occurred not far from this area in the past.  Have the maps of the Jubilee and Cardiff Mines been studied?

p 2 FPP

Qu 4
4(a) What material will be used for silt traps?  (bales of hay??)
4(b) Who will inspect and maintain the roads, silt traps etc?

Harvesting of the Timber
“Timber harvesting will be planned and carried out to minimize long term impact on the environment.......”
The area is a well known landslip area.  Any logging could lead to further landslips (see below).
Euphrasia collina ssp deflexifolia has been identified by FT as a key population however destruction of the species will occur.  There will be no protection.  
The Blind Velvet Worm and spotted tailed quoll’s habitats will be significantly destroyed by forestry operations.  
The line of parapatry (geographical line demarcating the two species) may be destroyed or disrupted.
There is a significant threat to the springs on the mountain which may have a long term impact on not only the environment but those drawing water from the coupe.   
Qu 5
With all these factors at risk, can this operation be called “minimizing long term impact”?!

Qu 6
6 (a) When will the Forestry Supervisor and contractor walk the coupe to inspect the boundaries? 

1. Snig Tracks and Landings

Landings

Qu 7
“Landings should not be placed immediately adjacent to sections of road flagged as important sites for Euphrasia……If however these areas are topographically most suitable for a landing site, it is acceptable to create a minimum width access track from the road to the landing, provided that every effort is made to avoid areas heavily populated with the species….”
FT has been less than thorough in their assessment of Euphrasia sites.  Despite mentioning colonies in the narrative at the first “bend”, along the track to Derrick’s Marsh and Dublin Town Rd, they are not marked on the FPP map. See map by local residents (which is incomplete i.e. it is very likely that there are other as yet unidentified plants).

“Excavators will not be operated within the area of the overhead power line clearing..”  The coupe post logging will be nothing more than a criss cross of tracks - powerlines, Telstra track, roads, spurs and snigs effectively degrading the forest completely.

Qu 8
“Landings may be moved from the position indicated on the FPP map…”
8 (a) For what reasons will landings be moved or added?
8 (b) What is the definition of ‘safety concerns’. 

Snig Tracks
Qu 9
“Snigging directions are indicated on the FPP map to ensure that there is little impact on the Velvet Worms”
This sentence is nonsensical.  The number of snig tracks may have an impact but not the direction of the snigs!
At least one Blind Velvet Worm site has been identified on the map.  No prescriptions have been made to protect this area.

p3
Qu 10
“Avoid snigging through Tea Tree and Cutting Grass flats
Cutting grass flats and tea tree areas are common on the coupe.  
How will these areas be avoided?

Qu 11
What materials will be used for cording and matting snig tracks? Will it be old rotting logs, the site of the Blind Velvet Worm? 

Qu 12
What are the indicators and criteria for starting and stopping logging and road construction during wet weather? 

Qu 13
Who will monitor whether machinery enters wildlife habitat clumps? 

pp 4
The large wildlife habitat clump (WHC) on the southwestern side of the coupe is less dense (less trees, little under storey) compared to the 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).   The map accompanying the notification form for natural and cultural values also mentions that this area as “non commercial/swamp”.  It would seem rather irresponsible to exempt this area from logging because of its non commercial value rather than its value as a habitat clump.

Qu 14
In Karen Richards’ report of 24 June 2003 (FPB Zoologist) she recommends that the number of WHCs should be increased in the coupe to at least 15 and that damper areas are captured.
Obviously one large clump has been decided upon (as mentioned above) however, is this area damper than other areas?  With the high winds experienced here it is doubtful. 

5. Streamside Management and Special Water Quality Protection Measure
“There are four class 4 watercourses within the harvest boundary”
The initial planning map by Andrew Crowden received in August 2004, has 5 additional Class 4 watercourses marked on the map.  

Qu 15
15 (a) Why are there only 4 class 4 watercourses marked on the map and mentioned in the FPP?
No mention has been made of the spring adjacent to Cardiff Coal Mine (and others found by residents)

“additional watercourses and or drainage lines that may be located within the harvest boundary……..These will be treated as per the provisions outlined in the FPC…”
15 (b) Does this mean a 10 metre buffer?  If so, how will the contractors know they are there if they are not marked on the map/marked in the field?

P 55 FPC
15 (c)“All water courses require protection during forest operations”
What protection will they get?

P57 FPC
“Wider streamside reserves, including reserves on Class 4 watercourses, should be specified in FPP where necessary to protect:
•Significant recreational, water supply, landscape, habitat or conservation values”
15 (d) This has only occurred for the German Town spring although the buffer allowed is insufficient to prevent quality problems.  Having regard to the report “Forestry, Water yield and water quality”, relating to the Koonya Forest, why is there not a prescription requiring forestry operations to be distanced 300 metres from the German Town spring?

15 (d) In addition, no measures have been taken for other “significant” water sites.  

P58 FPC
No additional measures have been provided for domestic water intakes taking water from the south eastern part of the coupe.  

Qu 16 Why haven’t some of the springs and watercourses been upgraded to Class 3? 
P 57 FPC “Significant springs will be treated as Class 3 or 4 watercourses”

“Machines will not be taken within 10 of the border of any swamp or area with obvious surfaces seepage except at properly corded crossing points.  Where ill defined, the edges should be marked prior to the commencement of operations” p48 FPC
Qu 17 Have all these areas been marked?  They are certainly not on the map!

“Seepage areas may require additional upslope protection to prevent sediment entering water courses” p 48 FPC
Qu 18
Have these seepage areas been identified and additional protection been provided?

Local residents have marked a total of 24 springs, watercourses, soaks on the coupe.

D. Restoration

Qu 19
“..bark and waste wood heaps…..cleared to mineral earth”
What is the definition of mineral earth?  The area is extremely rocky and therefore much damage can be done if cleared to mineral earth.  Rocks act as habitat areas and their removal will result in reduced habitat for fauna.

Qu 20 
How can burning bark heaps be controlled so they do not continue to smolder for months?

pp 5

4. Fire Breaks

Qu 21
“Firebreaks will be kept trafficable at all times”
21 (a) Where will fire breaks be placed? When will they be made? (around the harvest coupe? Bark and waste wood heaps? Along the border between the coupe and informal reserve?  Along waterways?  Along the E. Brookeriana reserve?
21 (b)Will it be possible to keep them trafficable at all times?  
21 (c) Will firebreaks be marked on the map? (according to FPP p 10 they should be marked on the map).
21 (d) There is no fire management plan in the FPP (as mentioned above)
21 (e) These is no mention of minimizing environmental damage to water courses during construction of the firebreaks (p 91 FPC)

1. Flora 
Qu 22 What effort will be made to prevent fire escaping into the informal reserve, WHC, streamside reserves?

Qu 23
“The areas of E. brookeriana forest should be protected …… (except for safety reasons indicated in Section 1 above”

23 (a) What are the safety reasons that may lead to disturbances of the E. brookeriana?
“some low intensity burning is acceptable (but probably unnecessary)”  This contradicts 
P 92 FPC which states that:
“In forest where fire is not necessary for establishing regeneration, steep slopes should only be burnt if required for fire protection”
23 (b) Is there a plan to burn the E. brookeriana areas or will this area be excluded?

pp 6
“The South Sister Road/Dublin Town Rd intersection…”
There is no intersection between these two roads i.e. incorrect identification of intersection has been made.

Qu 24
Please explain what is meant by this reference
24 (b) Where is the upgrading going to take place and why is this necessary? 
The FPP states that no Euphrasia has been recorded along this section.  
24 (c) Has FT surveyed this site for Euphrasia?
For information on Euphrasia collina ssp deflexifolia see pages 8 and 9 above

Qu 26
Where will machines be washed down prior to entering the coupe?  They should be washed after passing up German Town Rd (heath and gorse line the road verges) and before going up South Sister Road.  Is this possible?
Will trucks also be washed down?
Who will inspect and monitor this?
No action has been taken in recent years about the gorse population mentioned above therefore what appropriate action may be taken if outbreaks occur post logging?

p 7

Qu 27
(a) and (d) Blind and Giant Velvet Worms
The FPP states that this coupe is an important contact zone between the Blind and Giant Velvet Worms.  The line of parapatry is a highly significant conservation value however, there is no protection of this.  Any logging is likely to lead to destruction or disturbance of this line of parapatry.
No action plan for identification or protection of their habitat exists in the FPP.

“Areas of clumps exceed the requirement for Giant Velvet Worm”
Qu 28 Please outline the requirement and its reference.

FPP - Low intensity fuel burns are recommended.  
Any burning will result in reduced habitat for both worms and therefore burning should be avoided.  

“Roading …are acceptable provided that permanent features such as …main roads avoid known localities for this species” and “ Quarries and main roads must avoid known localities for this species”.
Qu 29
Has there been any assessment of worms in the area that will be “straightened”, the area of the passing lane and the area that will become new road?  The above statements suggest that they should have been.

“The number and size of wildlife habitat clumps should be increased……and be protected from disturbance”
See p 12 above for comments about Wildlife Habitat Clumps

(b) Eastern Barred Bandicoot
There has been no assessment to determine the known occurrences and potential habitat of the Eastern Barred Bandicoot. It has been recorded close by and may also occur on the South Sister. 

(c) Spotted tail quoll
The FPP admits that the coupe is a key site for the Spotted-tail Quoll but there is no plan to protect them. (See Code p. 61) 
The map and FPP do not fit the prescriptions for the protection of the species as laid down in the code.   No prescriptions and presumably no site visit has been made by FPB despite quolls being recorded on this coupe (Threatened Species Unit data, Parks and Wildlife Service, November 2004).  
The wildlife habitat clump of the southwestern side of the coupe has little habitat for the quoll.  Much of their habitat will be destroyed by the logging.
See “Linking Landscape Ecology and Management to Population viability Analysis”, p 263 ‘…..is at most risk of extinction from logging’ (reference to Spotted-tail Quoll)).

(e) Wedge Tailed Eagle

There has been an incomplete assessment to determine the known occurrences (i.e. nest) of the Wedge-tailed Eagle (the area is prime habitat for wedge tailed eagles).
Linking Landscape Ecology and Management to Populations viability Analysis, p 252, ‘Once harvesting activities are introduced the fate of the eagle worsens, facing an extinction risk of between 75% and 97% because of logging.’

Residents would consider that only a cursory attempt has been made to locate an eagle’s nest which is insufficient when locals report almost daily sightings of wedge tailed eagles around the South Sister.  Recommendations in the FPP are totally inadequate according to the FPC p61

(f) White bellied sea eagle
There has been no assessment or mention of the White bellied sea eagle which has been sighted in this area and the Fingal Valley.  

No mention of swift parrots has been made, nor any surveys carried out.  
No prescriptions for Eucalyptus globulus are included in the FPP.

The Prescriptions provided by Karen Richards, FPB Zoologist state that fauna evaluations must not be undertaken more than 6 months prior to the implementation of a FPP (p 2 Reply Form, Karen Richards, 24 June 2003).  As this statement was made more than eighteen months ago, it would be interesting to know whether FT has followed this up.  

3. Landscape Management
Viewing points of the South Sister have not included views from the summit or South Sister Rd.    All of these views will be significantly affected.
Qu 30 Why haven’t these views been included in the assessment?

p8
4. CULTURAL HERITAGE
1. Archaeology

This coupe is an historical cultural site.  It is a place of cultural, social and scientific significance which warrants protection (see p 25 Forest District Management Plan)

There has been no identification, recording and assessment of cultural heritage (FPC p 70), 
“…protection of cultural heritage should be achieved through identification, recording and assessment, and subsequent management by prescription or reservation” 
and p 71 “relevant information on sites or areas of cultural heritage significance, or potential significance, should be recorded”
“When any cultural heritage sites or features associated with them (e.g. …sawmill remains)…..a Forest Practices Officer will be notified.  This site will be assessed and recorded prior to further disturbance” p 72, FPC
“Planning will involve the collection of site information” (FPC p3), which will be the basis of the FPP.  

Qu 31 Cultural significance of South Sister
•Stumps from previous sawmilling have been located on the southern section of the coupe (see photos of stones left on stumps) 
FT has not identified these areas despite the necessity to do so (see above)
•Other Historical significance – 
•Cardiff Coal mine (have maps and other information been collected?)
•Jubilee Mine (have maps and other information been collected?) 
•droving cattle (have any locals been consulted about the use of the South Sister after early European settlement?)
•Recreation significance – iconic, magnificent vistas of the north of Tasmania, bushwalking, climbing, horse riding, bird watching, caving etc
•Scientific value

Qu 32 Which locals have been consulted about “natural and cultural values”? (p 6 FPC)

Forestry Tasmania have been negligent and failed in due diligence and duty of care in failing to locate, record and assess this heritage site, and in failing to make appropriate prescriptions for its protection, in breach of the requirements of the FPC 2000.

“Protection of significant sites should be achieved by ….changing the location of operations” p 72 FPC. 
This statement indicates that this site can be exempt from logging.

There is no proposal for joint management of tracks used for recreational purposes and or appropriate cultural interpretation (see Forest Management Plan p 25)  

There is no evidence of the provisions of a high priority of quality tourism and recreation and education experiences on the South Sister (Forest Management Plan, p 25, 26)

2. Cardiff Coal Mine
Proposed widening of the road for a passing lane may impinge on the Cardiff Coal Mine
Qu 33 Has the entire mine been excluded from the logging?  Have maps of the area been scrutinized?

5. Geomorphology
Landslips have occurred over the entire Nicholas Range, Huntsman, South Sister, Cheeseberry Hill.
It would appear that little assessment has been made of the risk of further slips.  
FPC states that FT should consult with locals regarding “unstable areas” p 6 FPC.  
Qu 34 Has this been done?  
Qu 35 Have those who worked on the Jubilee and Cardiff Mines been consulted?  Have MRT documents been ascertained?  
Qu 36 Have locals living around the mountain been consulted?
Qu 37 Which specialists have been consulted?  Is Peter McIntosh suitably qualified?  Please see reports from Stapledon, Rallings and van der Maesen for comments and recommendations regarding risk of further landslips.  

“Forest operations should not result in a significant deviation from natural rates of erosion and landslides” p 52 FPC
Owen Ingles says sheet erosion is likely if logging goes ahead (see report)
Stapledon concludes that the risk of landslides is very high with land disturbance and in other areas where there have been previous landslides, the risk is at least 75%.
McIntosh’s comments "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 and indication of present risk" have been refuted by the various reports (Stapledon report 1 and Rallings).
Qu 38 How is FT going to ensure “prevention of unacceptable rates of erosion, nutrient loss and landslides and excessive compaction, puddling and mixing of top soils and sub soils, during and after forest operations” p 52 FPC
It would appear that this statement may preclude logging on this coupe

“During planning for forest operations consideration will be given to the erodibility, load bearing capacity, depth and susceptibility to soil nutrient loss and landslides of different soil types” p 52 FPC

P 53 FPC 
“A specialist should be consulted if unusual landform features such as hummocky ground, seepages or evidence of shallow subsurface drainage through the soil”
Qu 39 Has a specialist been consulted?  
“….the area assessed for landslide hazard”
It would appear that the assessment for landslide has been inadequate!

Qu 40 Has FT asked for an investigation by a geomorphologist or geological engineer?

6. Soil and water

Sixth dot point “No part of NI114A………” has two clauses which are contradictory.  
Qu 41 What evidence is there that “no part of NI114A is within the direct water catchment of the town water bore?”  Please provide information and references
Many springs, water holes, watercourses, marshes and soaks have not been marked on the map therefore it is unlikely that they will all be protected by full 10 metre streamside reserves.   (see attached map for all springs, water holes, watercourses currently mapped by local residents) 
As all springs are likely to have larger catchments than 10m, a buffer zone of 10m is insufficient

Qu 42 How do FT propose to minimize topsoil disturbance? 

 “During road construction take care with culvert placement to avoid concentrating water in or above potential landslide areas”
Qu 43 Has an assessment been made of landslide risk along roadways?

“Where….unstable areas are known to be present, surveys or hazard mapping should be done to assist in the location or relocation of the roads”  p 7 FPC
Qu 44 Has this been done?

F MANAGEMENT OF FUELS ETC

Qu 45 Where will fuels and greases be kept?  
They should not be kept close to watercourses or swamps and yet much of this coupe has evidence of watercourses and swamps.  
Qu 46 How can a spill be contained on rocky ground?

G Establishing forests (Reforestation)
1. Site preparation procedures
This section appears to be rather scant considering the factors which need to be considered (p 74 and 75 FPC) “…and where appropriate, detailed in the FPP.” e.g. altitude, exposure, slope, rainfall, soil type, erodibility, depth etc …….

“Excavator heaping may be required in order to improve seedbed or to manage fuels”.  
What is the significance of this statement?

 “In steep country harvesting should not proceed unless successful regeneration of eucalypts and other scrub or vegetative cover can reasonable be assured within three years of completion of harvesting or burning”. P 28 FPC
Qu 47 Can we assume that trees will regenerate when there are fierce winds on the side of the mountain, there are enormous amounts of rocks etc?

2. Burning
p 9

“Consult the FPB Zoologist as a survey is required”   
Qu 48 Has a survey been carried out?  And for what?  Blind Velvet Worms?  Other fauna?

“Fire must be prevented from entering the overhead power line clearing.
Fire must be excluded from any above ground Telstra junction box identified within the coupe boundary.”
“Burning  of streamside reserves and streamside vegetation adjoining Class 4 watercourses should be avoided “wherever practicable”  p 28 FPC

Qu 49 Will firebreaks be put in to prevent entry into power line, Telstra line and streamside reserves?  
Qu 50 How can all streamside reserves be protected?
Qu 51 How will the German Town spring be protected
Qu 52  What are the prescriptions?

5. Weed control
This section is repeated

6. Fertiliser applications
“Not applicable”
Qu 53 Does this mean that in two years when the survey has been completed and there is insufficient regrowth, no fertilizers will be used?

H Maintaining forests
(B)Browsing
“Coupe will be monitored regularly for browsing” 
Qu 54 Who will be monitoring?

“Browsing control will be undertaken if necessary using current approved FT methods”.  Qu 55 Do these methods include 1080 or other chemicals such as atrazine, simazine etc?  
A written assurance by Steve Manson to Frances Daily in November 2004 stated no 1080 would be used (email can be supplied).  

 p 10
Maps
Info not yet received/not on map (yet mentioned in the FPP as being included on the map)
•Reforestation treatment
•Special treatment areas
•Sites of natural and cultural significance
•Stream crossings
•Section boundaries including wet/dry logging areas, cable/conventional logging, reforestation treatments such as burning, sowing, windrowing, cultivating planting and areas to be reserved.  
•Cultivation and windrow direction
•Firebreaks

p 11
Incorrect date by Kris Bezemer (31.12.05)

p12
Gunns signatoree has signed on Jan 6, 2005 (1 day after the presumed signing by FPB officer).

Summary

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.

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

REFERENCES

Bacon, C.A.  The Mount Nicholas Coal Field, August 1, 1983 (UR1983_41).  Accessed at  February 5, 2005

Dudley, T. South Sister Coupe (NI 114A), proposed for logging.  Environmental Assessment, December 2004

Dudley, T. Botanical Survey of South Sister (proposed logging coupe), December 2004

Forest Practices Board (2000). Forest Practices Code, Forest Practices Board, Hobart, Tasmania

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

Forestry Tasmania, Forest Practices Plan No. PWJ0010, January 5, 2004

Forestry Tasmania, Notification Form Natural and Cultural Values.  Andrew Crowden, May 16, 2003

Forestry Tasmania, Natural and Cultural Values Evaluation Sheet 1. Flora, Andrew Crowden, July 14, 2003

Forestry Tasmania, Natural and Cultural Values Evaluation Sheet 2. Fauna, Andrew Crowden, July 15, 2003 and December 16, 2004

Forestry Tasmania, Natural and Cultural Values Evaluation Sheet 3. Geomorphology, Andrew Crowden, July 22, 2003

Forestry Tasmania, Natural and Cultural Values Evaluation Sheet 4. Cultural Heritage, Andrew Crowden, July 28, 2003

Forestry Tasmania, Natural and Cultural Values Evaluation Sheet 5. Landscape, Andrew Crowden, May 16, 2003, December 14, 2003

Forestry Tasmania, Natural and Cultural Values Evaluation Sheet 6. Soil and Water, Andrew Crowden, August 19, 2003 and December 20, 2004

Fox, J. C.et al, Linking landscape ecology and management to population viability analysis: Part 2 – PVA for eleven forest dependent species, February 2004

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

Ingles, O.  Letter to Lesley Niklason, October 28, 2004

Kantvilas, G. Letter to Dr Frances Daily, January 31, 2005

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

Leaman, D.E.“Appraisal of initial forest plan on South Sister – Nicholas Range: Hydrological and Landscape observations” November 20, 2003 

Leaman, D.E. “Comments on Forest Practices Board Criticisms (by P.D. McIntosh) of my appraisal of initial forest plan on South Sister” December 4, 2003

Leaman, D.E. Letter to David Clement, January 23, 2005

Lloyd, S. Re Forestry operations at Coupe NI 114A South Sister. January 21, 2005

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

McIntosh, P.D.  Forestry, Water Yields and water quality on the Koonya uplands, Tasmania, October 22, 2004

McQuillan, P. Comments on a visit to South Sister near St Marys, Tasmania (Draft) September 2004

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

Mineral Resources Tasmania.  Map of Jubilee and Cardiff Mines.  Undated.

Natural Values Report, Parks and Wildlife Service GIS Tasmania (sent by Eve Lazarus to Frances Daily by email on November 25, 2004)

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

Rallings, R. Coupe NI 114A, Landslide Risk Assessment, February 3, 2005

Richards, K.  Reply Form Natural and Cultural Values. June 24, 2003

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

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

Skabo, R. Letter to Dr Frances Daily, January 14, 2005

Stapledon, D. Initial Forest Plan, South Sister– Nicholas Range. Comments on reports by D.E. Leaman and P.D. McIntosh, October 6, 2004

Stapledon, D.  Letter to Dr Frances Daily, January 30, 2005

van der Maesen, L. Observations of the area known as South Sister, St Marys, Tasmania. January 2005