South Sister St. Marys, Tasmania

South Sister Correspondence

more misunderstanding ...

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

Dear Mr Wilkinson,

Coupe NI114A South Sister 'Failure of Planning'
Request for Revocation of Forest Practices Plan

You are aware of my concerns at the impact on local water supplies of forest operations on the above coupe. You will also be aware that I have sought the opinion of Dr D E Leaman on this issue.

I am concerned at comments made by Dr McIntosh about views expressed by Dr Leaman, and your endorsement of these views. I particularly refer to your letter of 28 November 2003 to Julia Weston and Frank Giles in which you advised that 'Dr McIntosh has found that Dr Leaman's report contains errors' and to your subsequent letter to them of 7 Jan 2004 in which you advised that both you and Dr McIntosh were still of the same opinion, 'we stand by our earlier advice'.

Ignoring the issue of your own qualifications as a hydrologist, the issue of Dr McIntosh's understanding of the hydrological setting of South Sister is of fundamental relevance to the validity of the certified plan for this coupe in respect of the protection of water, given the reliance that you place on his expert opinion.

I refer you to one issue, as an example of possible other misunderstandings by Dr McIntosh of the water cycle at South Sister.

Leaman 22/11/03 stated, 'the upper part of South Sister is a typical 'dry' Tasmanian mountain. It may provide sheet runoff during and immediately after rain events, but it possesses no well-defined streams above the elevation of 600m. This means subsurface distribution of the water is important, the hydrology of the mountain depends on the constituent rocks and their groundwater storage'.

McIntosh opined 28/11/03 that 'the statement that the upper part of South Sister is a typically 'dry' Tasmanian mountain contradicts the earlier statement about the 'high rainfall area of South Sister'.

Leaman rejoindered 4/12/03 'my statements about South Sister being a 'dry' mountain in a high rainfall area are not contradictory. He ignores my explanation, which contrasts 'surface' water with 'subsurface water'.

Dr McIntosh seems to have overlooked the basic difference between total annual rainfall and the frequency and intensity of rainfall days. This issue is well addressed by Agrawal P C 1976 Variability and trend of annual rainfall in Chatisgarth region, Madhya Pradesh, and in an article closer to the area in question and expressed in terms comprehensive to the layman 'The Rains at St Marys', Mesibov R, Tasmanian Naturalist 123: 5 -11 (2001).

Further, a report by Ingles (2005) states, 'the small zone about the South Sister has the most serious rainfall intensity in the State. The 1-hour, 2 year, average rainfall intensity is some 45 mm per hour, while the 72 hour, 50-year recurrence intensity exceeds 4.5 mm per hour (Institution of Engineers Australia (1987) Australian Rainfall and Runoff; A Guide to Flood Estimation).

To the casual reader, this suggests that Coupe NI114A acts as a sponge, a recharge area for a groundwater storage and transmission system, topped up by periodic high rainfall events, but in all other respects a dry Tasmanian Mountain for most of the time, an analysis with which any local resident would agree.

Are you prepared to amend your earlier agreement with Dr McIntosh that the statement by Dr Leaman was contradictory, or do you still hold to that opinion? Your response goes to the heart of the credibility of Dr McIntosh as an expert on water issues, given the elementary nature of the issues involved.

Dr McIntosh's apparent conceptual problems in the matter of rainfall frequency and intensity, together with his apparent lack of familiarity with the factual rainfall regime of South Sister, have further implications with regard to the issue of soil stability on and around the coupe, on which he is again the Board's expert of choice. Ingles (2005) states, 'it is the combination of intensity and duration (of rainfall) which leads to major landslips of disastrous proportions (Lumb 1975)'. This comment needs to be taken into account with those of Rallings R, Stapledon D, Latinovic M, Sloane DJ and others already forwarded to you relating to landslide risk at South Sister, also reports in the public domain (Bacon C A) regarding Jubilee Mine.

You are aware of the documented acknowledgment by Dr Roberts, that she is not qualified as a hydro-geologist, of her documented belief that it would be 'ridiculous' to seek the necessary information on the groundwater system at South Sister, as it would only be relevant to that location and have no wider application, her failure (like Dr McIntosh) to recognise the significance of the Cullenswood rainfall statistics used for her report, and her conclusion contained within her report that 'the best we can do is speculate'. I assert that in those circumstances the Roberts (2004) report is of little relevance or value to the planning of coupe NI114A in respect of the protection of the water values of the area. Consequently the 'Brief Review' by Dr McIntosh of the report is also meaningless, and the conclusions reached in that review have no scientific justification and are unproven.

I ask again that you revoke the certification of the Forest Practices Plan for this coupe, on the grounds that the Plan contains no adequate prescriptions for the protection of the water resources of the coupe and surrounding area, and that both Dr McIntosh and Dr Roberts have demonstrated that they have insufficient knowledge and understanding of groundwater, both generally and particularly in respect of the coupe, for their opinions to have any scientific justification.

I ask for your immediate attention in this matter, given the announced intention of Forestry Tasmania to commence operations during this week, which represents such a fundamental breach of the consultative process initiated by Mr S Manson on 28 January, that a Complaint has been made to the Ombudsman.

Your Sincerely,

D W Clement (Mr)
Cc: Mr E Rolley, Mr K Evans, Mr W Jones, Mr S Manson

We have received no response for days

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