South Sister St. Marys, Tasmania
Mr M Wapstra
Senior Ecologist
Forest Practices Board
30 Patrick Street
HOBART
22 June 2005
Your Ref C486
Dear Mr Wapstra,
Thank you for your reply of 17 June regarding the above.
The pragmatic approach you advocate, identification by machine operators, seems to run contrary to the conclusions reached in the article you wrote ' Designing Better Wildlife Habitat Clumps'. Also, the modifications and qualifications inserted to your original prescription could result in a series of uncoordinated decisions being made by different individual operators when confronted by outcrops that it was ' not practical' to protect that particular outcrop; the end result would not be the range of representative outcrops intended as the desired outcome, possibly no protected outcrops at all!
I raise the following issues of training, procedure and safety:-
1. Will the machine operators be accredited as botanists under the Nationally Based Competency Standards, or will they undergo a relevant documented training programme to allow them to competently carry out the evaluations that will be required to provide the protection required by the Plan E.1.h Flora (Lichens), as required by Sec 5.1(f) of the Contractor's Agreement with Forestry Tasmania?
2. Sec 26 of the Contractor's Agreement requires that Forestry Tasmania take all measurements and provide the necessary marks on site to ensure that the contractor can properly execute the requirements of the certified Plan. This requires prior identification and flagging of outcrops, rather than a decision making progress on the run during forest operations.
3. Does the proposed procedure meet the required safety policies and
prescriptions? You have stated: "essentially, machine operators will
not be wanting to drive over most sites I see as rocky outcrops",
which you describe as ranging "from the massive to the much smaller
i.e. house through to car size", and you warn that there may be
"difficulties in identifying such sites" because " many are
almost completely covered in dense undergrowth".
There would seem to be a potential for machine damage and personal accident
in the 'pragmatic' procedure you advocate.
It is appreciated that you may not feel it necessary personally to make a site assessment, but in the circumstances referred to above, it would seem the required range of representative outcrops should be identified and flagged prior to the start of operations by appropriately qualified officers, rather than requiring machine operators to do so during those operations. You have acknowledged that some disturbance may in fact occur due to difficulties in identifying sites.
In this respect, your reference to "the information I have provided to District Planners is of sufficient detail to allow them to manage rocky outcrops appropriately" is of little consequence unless a range of representative outcrops are identified and clearly marked before operations start, to ensure that the required machine exclusion zones are established and that the protective measures required for each site is clearly documented for operators.
I refer you to your Email of 23 February to Mr A Corbould referring to the requirements of the FPC to minimise or avoid disturbance to significant biological values in localised environments such as rocky knolls. You refer to the decades taken to form cryptogamic mats on outcrops, and that even slight damage would pose a risk to the continuation of the species concerned remaining onsite post-harvest.
To conform to the Code requirements and your own professional opinion, pre-harvest identification and marking in accordance with the guidelines you have provided would appear mandatory, and I ask that you advise District Planning Officers to this end.
I look forward to your response.
D W Clement
4918 (1, 4, 45, 91)