South Sister St. Marys, Tasmania
Isobel Stanley
Chair
Forest Practices Authority
30 Patrick Street
HOBART
3rd January 2006
Dear Ms Stanley,
I refer to my letter of 22nd December providing information to support action by the Authority to revoke or vary the above Plan. This information was restricted to issues relevant to certification of the Plan on 4 January 2005, and the variation in February 2005. You will, however, be aware of the subsequent application to RMPAT made under the EMPCA by local residents of St Marys, and the history of that application.
The following matters included in the Proof of Evidence of Dr P McIntosh (8 August 2005), have been drawn to my attention. I provide this information to the Authority as supplementary information to that included in my letter of 22nd December 2005. Given the contradictions, elementary errors, and the false and misleading statements made by Dr McIntosh in respect of water matters at South Sister, no reliance can be placed on any matter regarding water upon which he has provided an opinion in respect of Coupe NI114A.
I also provide evidence of misleading information provided by Forestry Tasmania in its website with regard to water matters relating to the coupe
(i) As previously advised to you, in his 'Brief Review' he asserts (copy attached)
St Marys Railway Station bore is located in a catchment of approximately 30km². The coupe NI114A has an area of 120ha which is 4% of the area of the railway Station bore catchment
(ii) In his Proof Of Evidence Part 2, page 1 (copy attached) referring to an opinion by Dr D E Leaman (letter to D W Clement, 23 Jan 2005) Dr McIntosh states
Leaman wrote concerning the St Marys water catchment (which covers an area of approximately 22km²)
Reference to the original letter of Dr Leaman (copy attached) shows that he made no reference to the area of the catchment, that the figure of 22km² originates from Dr McIntosh. He repeats (copy attached) this assertion of catchment area of 22km² at page 8 of his Proof
(iii) In his Proof of Evidence Part 3, page 5 (copy attached) Dr McIntosh abandons scientific method and evidence and resorts to 'common sense', introduces yet another measure of the catchment, another measure of the coupe, and changes his assessment of the coupe area from 4% of the catchment to 0.1%
common sense suggests that it is most unlikely that a borehole located in a catchment of 220,000 ha could derive its water principally from an area of about 150ha (less than 0.1% of the total catchment area)
Within two reports, Dr McIntosh has introduced two (2) measures of coupe NI114A, 120ha and 150ha, compared with the actual coupe area of 163ha, has referred to three (3) measures of the St Marys Railway Station bore catchment, 30km², 22km², and 220,000ha, and has calculated the coupe area as 4% of the catchment area on the one hand, and as 0.1% on the other hand. Using different combinations of his various measures, the coupe could also represent 5.4% of the catchment, 7.4% of the catchment, or 6.8% of the catchment. It is self evident that no reliance can be placed on the evidence, opinion or conclusions reached by Dr McIntosh in respect of water.
4% is the figure quoted on the website of Forestry Tasmania (copy attached) as evidence of a negligible impact of forest operations on local water supplies, so putting the false and misleading result of Dr McIntosh on the public record.
It is also notable that the paragraph 'Water management' in the attached website contains no reference to the physical pathways of the groundwater system, because Forestry Tasmania has no knowledge of the system. The Plan fails to make any prescriptions for the reasonable protection of such water values within the coupe, ignoring the fundamental water characteristic of the coupe, that its hydrology is dependent on subsurface systems.
The website is misleading in a further respect - it refers to 'a slight increase in water availability for the first several years of harvesting' without reference to the fact that the source for this statement (Roberts 2004, pg 9 - attached) also indicates that an average reduction in water yield of up to 18% for as much as 56 years could be experienced after the initial 9-18 years after harvest. Forestry Tasmania has been selective in its use of a scientific document, with the result that the information provided to the public is misleading.
Further to the last paragraph of my letter of 22nd December, referring to the need for assessment of the groundwater system of South Sister, I attach a suggested monitoring programme prepared by Dr D E Leaman.
Should you require, I am able also to supply you with a summary of statements made by all scientific experts providing opinion on the water values of South Sister over the past 2 years, all confirming that there is no knowledge of the groundwater system of the coupe and surrounding area.
In this one respect, Dr McIntosh is correct: in his Brief Review (attached) he states:-
Given the present state of knowledge, it is pointless to try to model exact effects of harvest on the bore supply
The information provided to you is information relevant to the power of the Authority under Sec 24A(1) to revoke a certified forest practices plan.
I look forward to your acknowledgement and early reply to my letter of 22/12/05 and the points raised above, and in the circumstances I have outlined ask that you instruct Forestry Tasmania to undertake no forest operations in coupe NI114A until the Authority has made a determination on these matters.
Yours sincerely,
D W CLEMENT
No response for days
5644 (3, 16, 36, 76)