South Sister St. Marys, Tasmania
The Hon Bryan Green MHA
Minister for Infrastructure Energy and Resources
PO Box 1470
GPO HOBART 7001
3 January 2006
Dear Minister,
You are aware of the withdrawal by residents of St Marys of their application to RMPAT for an Order to require Forestry Tasmania to delay forest operations on the above coupe until it had commissioned independent studies into the potential impact of those operations on the hydrology and land stability of the coupe and surrounding area.
The proceedings before RMPAT focussed attention on legal definitions of environmental harm and nuisance under EMPCA, which has diverted attention from other issues. I write to draw these issues to your attention, and to ask that you weigh community concerns about the non-wood values of the coupe in the balance against the financial returns estimated to be obtained from logging this coupe.
If, after weighing these in the balance, you form the opinion that the benefits to the St Marys community from not logging the coupe are of a higher order than the benefits to the Tasmanian community at large from logging the coupe, I ask that you instruct Forestry Tasmania to remove the coupe from its harvest schedule, revoke the dedication of the coupe as State Forest, and create it a Forest Reserve to meet the Objectives of Schedule 3 of the Forestry Act 1920, a Reserve requested unanimously at a Public Meeting called by the Break O'Day Council on 15th December 2004.
In asking you to weigh these issues in the balance, I refer you to Sec 7 of the Forestry Act 1920 which sets out the Objectives of Forestry Tasmania
'As a manager of forest land with a commitment to multiple use, the objectives of the corporation are to optimise-
- the economic returns from its wood production activities
- the benefits to the public and the State of the non-wood value of forests.'
In considering the non-wood values of South Sister, which include its water values, it needs to be recognised that South Sister is to St Marys as Mount Wellington is to Hobart. Residents at St Marys ask, 'Would you authorise the logging of Mount Wellington, at any level, whether 50% or otherwise'?
Opposition to the proposed forestry operations has not been opposition to forest operations per se. The issue with regard to South Sister has always been the potential impact of industrial operations of whatever degree or nature on a forested mountain of special significance to the local community, concern about a change to the existing equilibrium of the natural values of the area, about the need for protection of the values of a forested mountain with a unique combination of hydrological, geological, ecological, cultural, social, economic and visual factors, forming an integral part of the townscape of a town within its shadow, a significant asset to the economy of the town, a source of water to residents, and which occupies a significant place in the history, present life and future of the district.
What are the economic returns from the wood production operations planned for Coupe NI114A, and what are the factors determining those returns?
(1) The coupe covers a gross area of 163 ha, of which 108 ha are planned to be harvested, for an ouput of 8600 tonne of product, namely 7000 tonne of pulpwood, 800 m³ of Category 1 sawlogs and 800 m³ of Category 8 sawlog. Over a 30 year harvest cycle, the proposed harvest would represent a total output of 287 tonnes per year, or some 1.76 tonnes per hectare, about two ute loads.
The proposed output from South Sister would represent approximately 0.24% of the annual production of Forestry Tasmania of Sawlog, Veneer and Peeler production, and also 0.24% of annual hardwood pulpwood production.
(2) Forestry Tasmania will derive royalties from the sale of the timber, contractors will be paid for harvest and carting, and their customers will apply a mark-up to the mill door price to them to cover their chipping and milling costs, contribute to their overhead recovery and generate their profit.
Mr John Gay, CEO of Gunns Ltd, indicated (Examiner 3/12/2002) that royalty rate varies, 'we pay on average between $30-$40 M³ for veneer and sawlogs, and $14-$16 per tonne for pulp logs'. In September 2004, Mr Andy Corbould, Bass Acting District Forest Manager, provided written advice that the final product value of the timber to be logged at South Sister would average $217 per m³ of sawlog and $80 per tonne of pulpwood, representing the final sale value of the milled and chipped timber products. Subsequent advice by Forestry Tasmania was that the total value of the product from South Sister would be $800,000.
(3) In its advice of September 24, 2004, Forestry Tasmania stated that the sale value of the final milled timber products provided the true indication of the total income generated into the Tasmanian economy by the coupe. The following table shows the make-up of the final product value of Coupe NI114A. It is emphasised that the sale price is a one-off return achieved only once every (say) 30 years.
| Category 1 sawlogs | 800M³ | @ $35M³ | $28,000 | (3.5%) |
| Category 8 sawlogs | 800M³ | @ $15M³ | $12,000 | (1.5%) |
| Total Sawlog | 1600M³ | $40,000 | (5.0%) | |
| Pulpwood | 7000tonne | @ $13 tonne | $91,000 | (11.3%) |
| Total Royalties | 8600tonne | $131,000 | (16.3%) | |
| Contractor Cost | 8600 tonne | @ $36 tonne | $310,000 | (38.8%) |
| Delivered Mill Door | 8600 tonne | $441,000 | (55.1%) | |
| 81% Mark-up to cover Milling cost, overhead Contribution and Profit |
8600 tonne | $359,000 | (44.9%) | |
| Final Product Sale value | 8600 tonne | $800,000 | (100.0%) |
Over a 30 year harvest cycle, the average value of goods and services generated by logging South Sister would be $26,666 per year.
What would be the long term economic benefit to the residents of St Marys of logging this coupe? Harvesting and carting is scheduled to be completed within 9-10 weeks at a rate of 120-150 tonnes per day. The proposed operation is a Potential Sawlog Retention and Shelterwood system, which would involve minimal activity on completion of logging. There is no continuing or long-term economic benefit to St Marys from logging this coupe.
What is the short term economic benefit to St Marys in terms of additional employment or income generation? Royalties for South Sister trees will go to Forestry Tasmania, roading for the coupe was carried out by contractors from Scottsdale, harvesting and carting is to be carried out by Taslog from Lilydale, and the majority of the product will be delivered to the Tamar Valley. Apart from a few nights accommodation of contractors at the local hotel, the felling and removal of timber from South Sister will generate no income or additional employment for the town or surrounding district.
Logging South Sister has no short-term, continuing or long term economic benefit to the local community, and the income generated from the timber taken from South Sister will generate an annual income for the wider Tasmanian community of only $26,666, less than 20% of your own Ministerial Salary and Allowance. Would you allow Mt Wellington to be logged for $27,000 a year?
What are the social and community values to St Marys of not logging South Sister, what is the economic value to St Marys of South Sister unlogged, what is the value to the State of South Sister unlogged, what are the economic disadvantages to St Marys of South Sister logged?
St Marys was surveyed in 1857. It is a small country town in a remote area. It is a service centre for the surrounding District, providing retail, service station, hairdressing, newsagent, banking and eating facilities, school, police, hospital, post office, internet and library services, but with no manufacturing or wholesale activities since the closure of the cheese factory and a local sawmill. Traditionally it was the centre for local grazing and farming properties, and for 100 years from 1886 it was a railway town. Coal mining still provides local employment. However in today's global economy it possesses no comparative economic advantages that will sustain viable long term businesses or industries that will generate employment, income or wealth for the community in general, except for its location, its sense of place, and its environmental values.
It is the location and unique sense of place of St Marys, engendered by the natural values of the suite of surrounding forested mountains, that is the economic asset of the community, the economic flywheel which represent the economic future of the town and surrounding district in the 21st Century, the asset which is generating settlement and tourism, which is increasing the population, the rate base, and establishing tourist based businesses. A conservative estimate by a qualified economist has indicated an increased contribution to the local economy from tourism and increased settlement over 30 years of $14.4m at present day prices.
The location and sense of place of St Marys is the future of the town, recognised by the Town Signs at the 3 entrances to the town , which proclaim
St Marys - Town of the Eastern Highlands and Break O' Day Plains
described in the Tourism North East Tasmania website as
A small country town in a highland setting surrounded by pristine forests. Forests, waterfalls and magnificent lookouts are what you will find if you visit St Marys
and described in the Landcape evaluation Sheet for coupe NI114A as
Largely undisturbed forest and mountain scenery from all viewpoints with South Sister outcrop as the major focal point behind coupe
John Muir, a celebrated 19th C natural historian wrote
Thousands of tired, nerve shaken, over civilized people are beginning to find that going to the mountains is going home; that wilderness is a necessity; and that mountain parks and reservations are not just fountains of timber and irrigating rivers, but are fountains of life.
On Jan 4th 1896 , 'The Australasian' newspaper wrote in an article on "Picturesque Tasmania"
St Marys is well worth the attention of the Victorian and New South Wales tourist … the hill scenery of the district is its chief attraction
In describing the hill scenery, the tourist was referred to the 'romantically situated mountain hamlets of Germantown and Dublin Town, and to the highest hill in the district, 'The Sister', sometime called Mt Mary, and advised that there is a steep track, feasible for horsemen which leads over Mt Nicholas to the Cornwall Colliery, but that the lover of mountain prospects should not leave without ascending the mountain, the foot of the rocky summit of which can be reached on horseback. A climb of 20mins will take him to the summit, 2900ft above sea level.'
The unique combination of non-wood values of this particular coupe may be summarised by reference to Schedule 3 of the Forestry Act, Objectives of the Management of Forest reserves
'conserve natural biological and geological diversity, protect water catchments, conserve areas of cultural significance, encourage appropriate tourism , recreational use and enjoyment'
South Sister is an easily accessible tourist destination 10 mins from the town centre, it is a significant rock climbing site in Tasmania, it is recognised by Birds Australia as an outstanding bird habitat, it is the habitat of a number of listed endangered species, recent scientific investigations by experts in varied fields has found it to be a biodiversity hotspot, containing fungi, lichens, moths of outstanding value and rarity, indicating an unresearched site with a potential to be a major ecological treasure house, it is used by locals for recreational walking, riding and simply enjoying the rich diversity of the natural values of the area, it is a part of the cultural history and early German settlement of the area, including the Derricks Marsh droving track, it forms an integral historical precinct together with the Jubilee and Cardiff Coal Mine, including examples of early small scale logging practices used in cutting timber for the mines and railway, it has the potential to be integrated with a network of local walking tracks being developed within the heritage coal mining area of the district, it is an integral part of the St Marys townscape - it is St Marys' Mount Wellington.
This is a special mountain to St Marys, containing a unique combination of values. It is appreciated that from the point of view of Forestry Tasmania that this is just another wood source, and that its system of evaluation indicates that logging is compatible with these values. However, even a selective advanced shelterwood system with wildlife habitat clump will be unable to avoid substantially damaging the fabric of the area, the existing natural system of the place, the equilibrium and interconnectivity of the different values, the essential sense of the place.
A decision not to log this coupe, to declare it a reserve, would not set a precedent, because the combination of factors involved in this particular location is unique. In fact it has been stated in representations to Forestry Tasmania during the course of this matter that if the coupe were in a different location on the Mt Nicholas Range there would be no issues with the proposed operations.
It would represent a monumental public relations 'win' for Forestry Tasmania to demonstrate corporate social awareness, to say
'We believe that our evaluation of the coupe conforms to our obligations under the Forest Practices Code, we believe that the scientific evidence we have sought and obtained as a result of the proceedings before RMPAT justifies the certification of the Forest Practices Plan for the coupe, and we believe the withdrawal by the Save Our Sisters group from those proceedings indicates that there was no legal grounds under EMPCA for opposing selective logging of the area. There is no impediment to Forestry Tasmania proceeding to log Coupe NI114A. However, the combination of the economic, cultural, social and other values of South Sister to St Marys is an issue to which we are sympathetic. We recognise that they are so unique to this particular location as to justify a decision in accordance with Sec 7(b) of the Forestry Act not to proceed with forest operations on the coupe. Accordingly Forestry Tasmania will recommend that the coupe be declared a Forest Reserve.'
That would be a real win for Forestry Tasmania.
Yours sincerely
D W CLEMENT
5668 (1, 2, 13, 188)