South Sister St. Marys, Tasmania

South Sister

appeal to representative ...

From: David Clement
To: Mr. M. Polley
Cc: Mr. D. Llewellyn
Sent: Sunday, February 13, 2005 5:42 PM
[Email addresses redacted]

Mr Polley,

I write to you as a member for Lyons, and because of your personal connections with the Mt Nicholas, Cornwall, South Sister and St Marys area, as is the case with Mr Llewellyn to whom I have coped this e-mail, together with the other members for Lyons.

I refer to the roading and pulpwood operation proposed by Forestry Tasmania within Coupe NI114A at South Sister, German Town, St Marys, a highland coupe of some 163 ha at an altitude of 600m-700m on the side of a mountain overlooking the town of St Marys and comprising the recharge area for the water catchment supplying locals and the town with their water, derived from groundwater sourced from the coupe site. This coupe is located within a rainfall regime characterised by frequent intermittent intense rainfall events, which generate obvious risks of landslides, which have occurred. Severe rainfall in 1911, 1929, 1956, 1969, and 1974 associated with landslip indicate a potential for such an event in the near future.

Within this context, I draw to your attention that in the planning for this coupe, Forestry Tasmania have been unaware of the rainfall characteristics of this site, a fact confirmed in meetings of residents with Forestry Tasmania and in written evaluations prepared to support its application for a Forest Practices Plan to be certified by the Forest Practices Board.

In preparing this plan, now certified by the Board, with the imprimatur of the Chief Forest Practices Officer, Mr Graham Wilkinson, that the planning for the coupe appeared 'very thorough'.

Forestry Tasmania were required by the Forest Practices Code to 'prevent unacceptable rates of landslide' (page 52), recognising that the 'risk (or hazard) on any site is related to site factors, such as rainfall intensity' (page 52), and that 'forest operations should not result from a significant deviation from natural rates of landslide' (page 52)

The Forest Practice Plan (page 8) contains a prescription that the area of the coupe which includes coal mine workings of the old Cardiff Coal Mine will be excluded from roading and harvesting operations and that operations 'will be kept well clear of the workings due to risk of collapse of coal mines'. As the Forest Practices Board specialist commented in her evaluation 'it would be well to stay some distance from these'

The Cardiff mine workings represent a very small area in the northeast corner of the coupe, an area already excluded from logging because it comprises significant area of threatened species Eucalyptus brookeriana.

However, the Planning Coordinator for the coupe, Mr Paul Rosevears of Forestry Tasmania, has now acknowledged, on Friday 11th February, when accompanying the Minister for Forest, Mr Bryan Green, on a visit to the coupe at South Sister, to Dr Frances Daily, a spokesperson for the 'Save Our Sisters' group concerned with the threat posed to the local environment and water supplies by the proposed logging, that it was unaware of the existence of another abandoned coal mine in the area, the Jubilee Mine.

It is inconceivable that Forestry Tasmania, charged under the Forest Practices Code to collect all relevant site information relating to a coupe that they propose to log, to ensure that they cause no environmental harm, could overlook an abandoned underground coal mine underlying the coupe, with workings covering some 300 acres and filled with water, closed down due to water infiltration, faulting, and roof falls, within an area characterised by geological faults and fractures and past landslips!!!

Failure to be aware of the unique and significant rainfall characteristics of the coupe is by itself a failure of due diligence, duty of care and represents rank incompetence, but failure to determine that an abandoned coal mine underlies more than 50% of the proposed logging area is negligence of such a high order that questions need to be asked regarding the failure of due diligence, duty of care and risk assessment undertaken by Forestry Tasmania in planning this coupe, and of the due diligence process undertaken by the Forest Practices Board in certifying the Forest Practices Plan.

Against this background, I ask that you request your colleague, Mr Bryan Green, the responsible Minister, to instruct Forestry Tasmania not to proceed with any forest operation on this coupe until comprehensive risk assessments have been conducted by a panel of appropriately qualified independent scientific and professional experts into the threat posed to land stability and groundwater resources by forest operations, and further, that an independent enquiry be established into the planning and certification process undertaken for this coupe by Forestry Tasmania and the Forest Practices Board, given the obvious and documented evidence of negligence and failure to observe the requirements of the Forest Practices Code, as required by the Forest Practices Act 1985, and to observe the Forestry Act 1920.

I look forward to your response and advice.


David Clement

We have received no response for days

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