South Sister St. Marys, Tasmania
Senior Landscape Planner
Forest Practices Authority
30 Patrick Street
HOBART 7000
23 January 2006
Dear Sir,
I refer to the Landscape evaluation for the above plan, and the consequent prescription that the LMO should be Apparent Alteration, when on the basis of the issues raised below it may more properly be Inevident Alteration. I ask on behalf of local residents associated together as SAVE OUR SISTERS that you re-evaluate the coupe for landscape purposes.
Emails between Mr B Chetwynd and Andrew Crowden 16/9/04 and 21/9/04 state that 'This one will be interesting'
We submit that the evaluation is defective, specifically:-
The 'key public viewpoints and locations' used by Forestry Tasmania from which assessments have been made are not those which would be selected by local residents or the casual observer as providing locations from which the coupe area is most commonly seen during the daily round of residents and/or which provide the most comprehensive views relevant to the variables required to be taken into account by the Manual for Forest Landscape management.
The locations in Beaumaris, Scamander, Falmouth, and Tasman Highway, Falmouth artificially bias and weight the evaluation, considering the distance involved between those viewpoints and the coupe, and the proportion of the coupe which could be visible from those locations.
The locations at Gray Road and Esk Main Road are not those which provide the clearest and most detailed view of the coupe. The nominated locations do not adequately represent the viewing experience of the proposed coupe area from within the town of St Marys.
Having regard to the requirement of the Forest Practices Code that planning will involve consultation with relevant persons and organisations, which individuals or local community groups were consulted by Forestry Tasmania in the process of selecting these locations, and what was their advice? If there was no such consultation, on what basis were these particular locations selected by Forestry Tasmania, and by who? The Manual for Forest Landscape management requires that local knowledge be considered to relate photographs to field reality
There are at least 5 other locations to the south of the coupe, on the Esk Main Road and within the town, which would qualify as key public viewpoints and locations and which provide a far more detailed and comprehensive view of the coupe area than those relied upon for the evaluation. The locations selected by Forestry Tasmania fail to provide a fair picture, and must automatically lead to an assessment of a lower level of visual significance than will result from more appropriate locations.
The evaluation contains no reference to the view from a key public location, from on top of the South Sister peak, a tourist destination. In this respect, Mr Crowden stated 'there are some photos from the lookout on top of South Sister, and I will attempt to find them next week' (16/9/04). Did he subsequently find them, did he take his own photographs, did he visit the peak, where are the assessments and prescriptions from this key location, from which the observer looks down directly onto the coupe? How does lack of assessment comply with the Forestry Tourism Protocol?
The categorisation of Scenic Quality as M from all the viewpoints selected by Forestry Tasmania would be disputed in respect of those locations. However, a more appropriate choice of locations would certainly result in a classification of H on the basis of criteria contained within the Landscape Manual, which together with the Y results in respect of skyline would result in LMOs of A rather than B, so changing the prescription to Inevident Alteration.
Assessment of this particular coupe cannot be considered in isolation from the South Sister peak, as it is an integral part of the peak, and it is the peak which draws the viewers attention to the coupe, which comprises the skirt of the peak. The High Scenic Quality criteria for the north -East Highlands refers to mountains and peaks with dramatic forms rising from surrounding lands, and in this context the coupe cannot be separated from the peak.
In this respect the concept of 'inspirational' values contained in the Forest Practices Code 2000 (page 72), which apply equally to landscape values, also need to be considered in assessing this area.
As residents of the District, rather than casual observers or passers-by, the impact of forest operations will be detrimental to our daily visual amenity and landscape enjoyment. of South Sister peak and the surrounding slopes, of which coupe NI114A is an integral part. As described in the evaluation the landscape comprises 'largely undisturbed forest and mountain scenery from all viewpoints with South Sister outcrop as the major focal point behind the coupe'. The view is an essential part of the sense of place of St Marys, and of the St Marys townscape, forming a vital component of the cyclorama of forested mountains surrounding St Marys, described in The Australasian (1896) and recognised today on the town sign 'St Marys, Town of the Eastern Highlands and Break O Day Plains'.
From the more appropriate locations referred to in 1 above, it is possible to distinguish individual trees on the coupe from within the town and it is simply not true that the effect of thinning of the forest canopy will be lessened by the coupe terrain or by distance. The Manual for Forest Landscape Management specifically states that middleground is the most critical zone, as the observer sees the finer details in the landscape, especially when the ground is above the observer and foreshortened, so that it becomes Near Foreground with even more detail revealed of the individual landscape components, a comment that applies totally to the viewing of the coupe area from the more appropriate locations on Gray Road and the Esk Main Road.
The Manual also states that a landscape viewed in glimpses from a moving vehicle will not be seen in detail, and that the longer the observer views a landscape, the greater their appreciation of its visual characteristics and the greater their awareness of any alteration to that landscape. If visitors spend 5 minutes or more at any viewpoint, they recognise major and more subtle contrasts. As time passes, changes in lighting and other variables add to the viewer's perception of the landscape. Landscapes viewed for a longer period of time are more important than those viewed only briefly
The assessments, and so the consequent prescriptions, fail to take into account criteria contained within the Manual for Forest Landscape Management, as required by the Forest Practices Code. In this respect, the diary entries and field notes of Mr Crowden of Forestry Tasmania would be needed to substantiate any claims that these issues were in fact taken into account in assessing the landscape values of the coupe. As required by the Manual 'landscape analysis should be documented for each stage of planning'.
There is no evidence that consideration has been given in assessing the potential impact of forest operations on scenic quality to variable factors such as different times of day, different conditions of light, different atmospheric conditions, and different times of the year. The Manual emphasise that the visual impact of landscape varies with the way in which it is lit, that the intensity and direction of light on the landscape changes during the day and throughout the year as the sun's position changes relative to the land surface- sunlight striking on the land surface at different angles changes the degree of visual dominance of the elements of the landscape. The Manual requires that assessments be made before mid morning and after mid afternoon to capitalise on side lighting, and that evaluation should not take place in early morning or late evening.
The Forest Practices Plan in respect of Landscape is flawed, in that the evaluation by Forestry Tasmania failed to meet the requirements of the Forest Practices Code to conform to the Manual for Forest Landscape Management in significant respects.
We ask that the planning be redone to ensure that there will be reasonable protection of landscape values from the impact of forest operations on the coupe, and that the planning take into account the requirements of the Code and the Manual in respect of consultation and local knowledge during the planning process.
D W CLEMENT
For and on behalf of Save Our Sisters
We have received no response for days
5340 (1, 3, 12, 210)