South Sister St. Marys, Tasmania

South Sister

request for revocation of plan ...

Mr G Wilkinson
Chief Forest Practices Officer
Forest Practices Board
30 Patrick Street

Dear Mr Wilkinson

Coupe NI114A - FPP - Failure to meet F P Code Requirements
Request for Revocation of Forest Practices Plan.

I refer to the diagram on page 48 of the Forest Practices Code, to your advice to me 23/12/04 (FOI 3/04) advising of the interconnection of surface and groundwater, to the Guidelines For Forestry Operations on Soils formed in dolerite slope deposits (Dolerite Talus) P D McIntosh 4 January 2002, and to the map and co-ordinates provided to Mr S Manson by Dr F Daily showing the location of springs and seepages on the coupe not located by Forestry Tasmania in its planning of the coupe.

Having regard to those matters, the Forest Practices Plan for this coupe is defective, in that it has made no prescription to ensure that 'no roads or snig tracks or machinery will pass within a 90 degree arc with radius 30m upstream from any seepage' as 'there will be subsurface conduits liable to be damaged by machinery', as prescribed in the Guidelines. The area involved on this coupe would be significant, and the potential danger to the groundwater transmission system of not conforming to this guideline would represent a significant risk. I ask that you revoke the Plan on this ground.

Dr McIntosh may argue that the Guideline refers (a) only to seepages and springs flowing directly into streams (b) that the environment risk is to contamination of water in streams only (c) that soils are to have an erodibility rating of at least moderate. However, I draw these factors to your attention:

Your own advice of 23 December that 'the Code takes a systems or catchment approach to the management of water, recognising that groundwater and surface water (in its various forms) are interconnected and therefore have to be managed in an integrated manner' would appear particularly relevant to (a) and (b) above.

The issue of the degree of erodibility of the soil in question is more complex, as it rases issues of the judgement of Dr McIntosh in making his determination of the erodibilty class of the soils of the coupe.

Arising from a FOI request, I obtained documentation from a Forestry Tasmania file relating to the planning of coupe NI114A.

Soil and Water Evaluation Sheets (6) dated 19/08/03, 6/10/03 and 20/12/04, together with supporting emails, consistently show a description reflected for 'Dolerite Talus' as 'slight to moderate to severe erosion', a description reflected in the various draft cover sheets for the Forest Practices Plan also in the file, which designated the erodibility class of the parent rock as 'moderate', which would of course meet the requirement for the exclusion of roads, machines, etc from a 90 degree 30m radius arc above springs. However, at the last minute, the classification was changed so that on the certified plan it is shown as 'low'. No scientific justification appears to support this change of classification. In the absence of any scientific reason for such a change, there must be concern that this is in fact an error, in which case the exclusion zones above the located springs should apply.

This issue has the potential to significantly alter the prescriptions to be included in the Plan, and I would appreciate your early response to my request for revocation.

Yours sincerely,

(Mr) D. W. Clement
cc: Mr E Rolley, Mr K Evans, Mr S Manson, Mr W Jones
cc: EDO

We have received no response for days

Default Colours Less Contrast More contrast

5123 (1, 2, 4, 122)