South Sister St. Marys, Tasmania

South Sister

more questions unanswered ...

From: David Clement
To: Mr. Steve Manson
Cc: Dr. Graham Wilkinson
Sent: Sunday, February 06, 2005 1:20 PM
[email addresses redacted]

Subject: Forest Practices Plan South Sister - Representations

Dear Mr Manson,

I refer to the presentation by FT of the Forest Practices Plan for Coupe NI114A (or should it be N1114A?) last Friday 28th Jan 2005. I am responding to your invitation to submit any concerns about the Plan, its Evaluations and the planning process for the coupe.

You are aware of my general concern at the lack of site specific assessment, surveys and studies and the failure to obtain relevant data specific to the coupe, particularly in respect of groundwater regimes and landslip risk, and related issues such as erosion, run-off, climatic conditions, etc.

Accordingly, I raise the following issues, not exclusively, which do not seem to have been addressed or adequately addressed, having regard to the provisions and requirements of the Forest Practices Code to ensure reasonable protection of the environment and not to cause environmental harm or nuisance.

1. Having regard to the assertion by Dr O G Ingles that the soil of the coupe is susceptible to sheet erosion, and that it is 'absolutely imperative' that a good ground cover be maintained at all times, and what must be out of the question is any burning after logging, as that would be just as bad as clearfelling if it was done just before heavy rains, will FT amend the Plan to exclude any burning of any type, high intensity, low intensity, top disposal, whatever, particularly having regard to the pattern of random high intensity rainfall at the location?

2. There is no provision in the Plan that no road or snig track or machinery will pass within a 90 degree arc within 50 m upslope of any seepage or spring within the coupe.

3. The Plan contains no reference to temperature conditions within the coupe, and anticipated changes as a result of the removal of canopy cover and understorey. What planning has been undertaken to determine the risk of frost and cold air incursion impacting on regeneration growth or even mature trees?

4. The Plan contains no reference to assessments of the groundwater system within the coupe, and how it will be protected from the impact of roading and harvest operations. Has Forestry Tasmania undertaken or accessed studies specific to the site in respect of the permeability, transivity, direction of flow, fracture planes and faults of the various strata of the groundwater system and linkages within the coupe to be aware of how groundwater moves through the landscape of the coupe to allow prescriptions to be made to protect the system from disturbance from forest operations?

5. Is FT satisfied that it has conducted adequate and thorough studies within the coupe to determine the location of all sub-surface conduits so that no snigging will be conducted along the lines of subsurface drainage?

6. Will all roads, spurs and tracks be revegetated immediately on completion of operations?

7. What specific provisions are contained within the Plan to minimise soil disturbance at the junctions of snigging tracks with landings?

8. On what scientific evidence does P McIntosh advise that 'it is possible that a very small proportion of the (town) bore water may derive from NI114A'?
On what scientific evidence is it assessed that no part of NI114A is within the direct water catchment of the town water bore?
On what scientific basis can it be concluded that both 'no part' and 'a very small part' of the town bore water is derived from Coupe NI114A?

9. Why does the Plan state (page 1) 'No' the operation is not within a town water catchment, but in Evaluation Sheet 6 (Soil and Water) state 'Yes' it is within a town water supply catchment?

10. Does Table 1 in the Roberts 2004 report show that for an annual rainfall of 1400mm per year on the coupe there could be an average 24% increase in water yield from the coupe for up to 9 years after harvest, followed by a reduction of 185 thereafter over the following 56 years - representing an average increase of 112 Ml per year over years 1-9, followed by an average decline of 83 Ml per year for the next 56 years?

11. Does FT recognise that vibrations from roading and harvesting machinery and from log trucks, from falling trees, and from blasting may initiate land slides, and what prescriptions has it made in this coupe to prevent this from happening?

12. Does the Plan contain prescriptions that there will be no removal of trees upslope of past landslide activity?

13. Having regard to the advice Gaughwin to Crowden email 28/7/03 'coal mines are particularly susceptible to collapse', and to the contents of the Sloane and Weldon report 1987 in the possession of FT which refers to the water within the Jubilee Mine as a town water resource, has FT conducted any assessment of the potential impact of Forest Operations on land stability, water resources and the heritage value of the Jubilee Mine?

14. The Plan states H1(B) pg 9, 'browsing control will be undertaken if necessary using current approved FT methods'. What does that mean?
Will FT give an unequivocal, categorical assurance that no chemical control methods will be used on or around the coupe, for any purpose, at any time, that no pesticides, herbicides, insecticides, sterilisants, or any other potential chemical contaminants of the environment will be emitted, deposited, released, discharged or applied, and further that no aerial spraying will be undertaken as part of the forest operations of this coupe? If FT do intend to use chemical substances, compounds and the like, what are their names, for what purpose will they be applied, where, at what rate, how frequently, and by what method?

15. Will FT acknowledge that disturbance to the water supplies of residents, both around the coupe and within the St Marys Water District, and landslips, would significantly impact on the amenity and property values of those people? Will FT advise the royalties that it will receive from the harvest volume from this coupe so that an informed social/economic appraisal and cost benefit analysis can be undertaken in respect of this coupe?

16. Has FT undertaken any site specific study of the rate of soil formation on the coupe?

17. What studies have been undertaken by FT and/or what information has been obtained (from where) to determine and assess the specific site characteristics of the coupe in respect of climatic parameters, such as rainfall, wind, temperature, sun duration, and evapo-transpiration?

18. Does Dr McIntosh have long experience of logging without causing landslides on locations with a similar combination of geological, topographic, drainage, soils, and climatic conditions as Coupe NI114A?

19. In the Plan, what does 'minimise soil disturbance' mean in terms of operational practices and instructions to operators and contractors, and how will these practices and instructions be supervised?

20. Where are the 'potential landslip areas' referred to in Sheet 6 and in the email Crowden to McIntosh 22/7/03? Where is the map of these areas, has the Road Engineer identified these areas yet?

21. Is FT satisfied that it has adequately surveyed the coupe to determine the existence and positions of all springs, soaks, seepages, and swampy areas to allow adequate prescriptions to be made for their protection? Where are these features located?

22. How does FT justify the use of C1 equipment on the coupe having regard to the physical characteristics of the coupe, in respect of climate, soils, land stability, and drainage, particularly in respect of the potential for accelerated erosion of soils and increased runoff resulting from operations?

23. What are the titles, authors, and dates of the documents referred to on page 4 of the Plan as containing the 'modelling and analysis of water flows', and are they attached to the Plan?

24. What modelling or surveys have been conducted for the coupe to show the impact of forest operations on ground moisture content, given that an increase in moisture content will increase the vulnerability of the slopes downhill to landslides?

25. Having regard to the pattern of intense rainfall events in the area, how will FT prevent accelerated erosion of soils on the coupe within the context of roading and snig construction, harvest operations, and the removal of understorey and the forest floor mantle?

26. The Roberts Report 2004 is wrong in asserting that rainfall is evenly distributed throughout the year. Germantown ranks among the highest point rainfall events in Tasmania with over 500mm in a few hours in 1974, while the long term pattern is for random, high rainfall events. In this context, why have the watercourses not been upgraded to Class 3 ( FP Code pg56) as being in a high rainfall area in eastern Tasmania?

27. Will FT commission an independent geomorphic study of the slopes downhill of the proposed coupe and in the NE corner of the coupe, directed towards landslide failures:

I look forward to your response to the above.


David Clement

We have been waiting days for a reply.

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