South Sister St. Marys, Tasmania
Mr Mark Wapstra
Senior Ecologist
Forest Practices Board
30 Patrick Street
HOBART
15 June 2005
Dear Mr Wapstra,
I am writing in respect of suggestions and statements you have made in respect of rocky outcrops at South Sister, as provided to me by Graham Wilkinson, and to ask that you review your suggestion regarding identification of such outcrops.
On 11th February, 2005 you provided to Mr A Corbould, Forestry Tasmania, a report on 'Natural and Cultural Values' in respect of the above coupe. This report contained a section 'Other Issues - lichens' which concluded with a recommendation that the existing certified Plan PWJ0010 be varied "to include a statement that aims to protect representative rocky outcrops throughout the coupe". You provided a suggested wording for this statement, with the caveat that "you may need to modify (this) for the FPP".
On 17th February, 2005, an Application for a Variation To Certified Forest Practices Plan PWJ0010 was applied for by Peter Johnstone of Forestry Tasmania and approved by Peter Johnstone of Forestry Tasmania, with the consent of the landowners, contractors and processors. Included in several variations to the Plan was the insertion of a new section 'E.1 h Flora (lichens) Machinery Exclusion Zone around rocky outcrops', which repeated, without any modification, the Statement you had suggested to Mr Corbould on 11th February.
On 23rd February 2005, you sent an email to Messrs Corbould, Johnstone and Crowden of Forestry Tasmania, with a copy to the Chief Forest Practices Officer, Graham Wilkinson, in which you referred to 'your (Corbould et al) phone messages and discussion', stating that "I am now aware that I need to provide a clarifying statement or two with respect to the management of rocky outcrop". You then provided a revised wording of your original statement, presumably for a further variation of the Plan.
It follows that the changes made to your original suggested statement reflect issues raised by Forestry Tasmania in the 'phone messages and discussion' referred to in your email, after FT itself had applied for and approved your original statement only days before. Indeed you say "I did indicate that the wording was 'suggested' and 'may need to be modified for the FPP' - I made this statement to prevent the 'current situation'".
The changes comprised (1) deletions from your original statement, and (2) qualifications (3) amendments and (4) additions to the original statement.
1. Deletions:- trees likely to fall into the machinery exclusion zone should be left standing (if safe to do so).
2. Qualification (in brackets)
3. Modification:-
'Trees should not be felled from the rocky outcrop of from 5m of the
downside slope of the rocky outcrop and one tree length on the upslope
side', is changed to, 'where practical, trees should not be felled
from the larger rocky outcrops e.g. 5m of more in height, of from within 5
m of such rocky outcrops - from the immediate base of the
outcrop'.
4. Additions:
"Representative rocky outcrops should be managed throughout the harvest
area. The term 'representative' is intended to refer to a range of
sizes of rock outcrop across the range of topographies and aspects present
on the coupe" "recognising that the dense understorey may reduce the
opportunity for locating outcrops prior to some machinery
disturbance"
Having regard to the issues referred to by you in respect of Pages 59 and 60 of the Forest Practices Code in respect of native vegetation, localised environments, and significant biological values, and your reference to the threats to the cryptogamic mats from 'even slight damage' it is difficult to understand why you believe that a field visit by you to the coupe is not required to identify outcrops to be included in the representative range, instead asserting that 'sites do not need to be formally identified prior to harvesting or other activities', and that they could be identified as harvesting and snigging took place.
You state "essentially, machine operators will not be wanting to drive over most sites I see as 'rocky outcrops'. I did not expect every rocky outcrop would be managed, rather a representative range through the coupe from the massive to the much smaller i.e. house through to car size, some from upper slopes, some on the flatter bench, some on the lower slopes".
Given the significant biological values involved and the obvious difficulties in definition and interpretation of the sites involved, you could resolve the situation by a field visit to locate, identify and flag a representative range of outcrops throughout the coupe. You have identified the difficulties faced by machine operators in identifying sites during the course of operations: an ad hoc process of identification by machine operators while engaged in felling and snigging is unlikely to result in a representative range of outcrops being selected across the coupe. Outcrops need to be identified before snig trances are located not vice versa to avoid damage during snigging, and machine operators do not have the knowledge or expertise to identify and differentiate between outcrops on the basis of the relative significance of the mats covering them.
Together with the qualifications of 'wherever practical' etc, which have been introduced into the prescription, it would seem that ad hoc identification of outcrops by machine operators throughout the coupe while felling and snigging and the simultaneous establishment of a machinery exclusion zone by a machine operator who is having difficult of identifying an outcrop almost completely covered in dense undergrowth, is unlikely to achieve the desired outcome.
You have identified the primary objective of the management of the rocky outcrops is to ensure that the species currently on site are afforded the maximum likelihood of remaining onsite post-harvest on a range of representative outcrops throughout the coupe, as a result of the microclimate and unique environment they inhabit remaining undisturbed. This outcome requires identification by you of the exact sites, establishment and flagging of specific machine exclusion zones, and mandatory prescriptions to ensure that the sites are undisturbed.
You stated in the matter of Gunns v Kingborough Council that finding a threatened species after logging was not expected because it was unlikely loggers would recognise any, and that drivers and officers were not expected to be botanists. And yet in the case of coupe NI 114A you seem prepared to delegate your role to machine operators, despite your own statement that there might be difficult in identifying outcrops, and the need to assess the most significant outcrops in ecological terms across the whole coupe. You are completely right in both respects, and no general description provided as a guide to unqualified operators can be an adequate substitute for the exercise of your own professional knowledge and qualifications.
I also draw to your attention the issues raised in an article co-authored by you, Designing Better Wildlife Habitat Clumps, particularly the conclusion that 'The clumps that are clearly flagged around the edges tend to be the most intact and with the least disturbance around the edges'.
In these circumstances, I ask that you review your decision that a field trip by you is not required, and that you visit the coupe to locate, identify and flag a range of representative outcrops so as to ensure that the outcome you have professionally identified is achieved.
I look forward to your response.
D W Clement
[Cc Mr G Wilkinson]
6677 (3, 11, 32, 71)