South Sister St. Marys, Tasmania
From: Frances Daily
To: Graham Wilkinson
Cc: Peter Bird
Sent: Thursday, February 09, 2006 9:47 PM
[email addresses redacted]
Dear Graham,
Further to my earlier correspondence there are three additional topics that I would like to bring to your attention.
a) Subsidence over total coal extraction areas
Firstly, I have been in contact with Ralph Rallings and he has
informed me that he believes there to be additional subsidence on
Coupe NI 114A that has not yet been investigated. This subsidence
relates to the Jubilee Mine.
There are various areas of total extraction in the Jubilee Mine i.e. where pillars were extracted (after coal had been extracted from tunnels). These areas show up as hatched areas on the attached diagram ('Markings of Jubilee and Cardiff Mines' provided to me by Mineral Resources Tasmania a year or so ago).
In David Stapledon's Proof of Evidence (May 05) he describes one area, Site 8 (see attached Figure 1, Geology and Observations, Stapledon POE and Supplementary POE) as 'a swampy depression'. Ralph Rallings now believes that this feature is below one of the total extraction areas of Jubilee Mine (see attached drawing - Attachment 7 of Rallings' review paper which shows this relationship). In his review paper of January 2006 Rallings states:
'The relationship of the mine to the proposed harvesting needs to be clearly understood in order to assess the risks presented by the forestry operations. Attachment 7 shows the reputed location of the underground working with respect to Slides A and B, and Site 8 discussed by Stapledon (Ref 7). The mine entrance is at approx RL500.
There have been various hypotheses about the impact of the forestry operations on the mine and vice versa. The landslide feature above the total extraction zone (Site 8 in Ref 7 and Attachment 1) may be due to the mining. The trouble is that the elevation and slopes of the underground workings are not reliably known'.
For a clear diagrammatic representation of this please see Rallings' Attachment (Rallings Site 8 over Jubilee markings) which accompanies this email.
In addition to this Site 8, I would like to point out that there has also been total extraction of coal immediately west of Cardiff Mine. There is known subsidence over Cardiff Mine (apparently recently excluded from harvesting only after I alerted FPA to the existence of this subsidence a few months ago) but it is also possible that subsidence has already occurred (Site 8) or may occur over total extraction areas of Jubilee Mine e.g. west of Cardiff Mine.
b) slope of coal seam/tunnels of Jubilee Mine
Rallings also mentions in his review paper that if Slide B is well
drained as eluded to by McIntosh/Weldon 'Groundwater from below Slide
B could flow southwards towards the Jubilee mine entrance' (and
supported by Stapledon) then there are potential consequences for the
southern slopes of South Sister.
'One theory is that the workings slope downwards, towards the south, and are at a relatively high level in the vicinity of Slide B. In consequence it is possible that Slide B may be well-drained and that any significant rise in groundwater is unlikely to occur as a result of forestry operations. This might be so, however there is no reliable evidence to support this. (my bolding)
After comments had been made about the drainage of part of the mine close to Slide B, I contacted MRT to gather additional information about this area. I was informed that there are currently no boreholes which would help to establish the actual dip of the Jubilee seam hence no one currently knows whether drainage from Slide B is sufficient or not. Rallings shows in Attachment 7 that there are very few tunnels underlying Slide B and therefore Slide B may not be as well drained as thought by McIntosh/Weldon/Stapledon.
Rallings goes on to say in his review:
'It is uncertainties of this kind, ones that cannot be resolved without intensive investigation, that put an unfair burden of proof on the applicants.'
Lack of information and consideration for Jubilee
Mine
I believe that the location of the Jubilee Mine,
the areas of total extraction of coal, the slope of the tunnels/coal
seam, effects of the mine on the topography of the coupe (including
subsidence) etc have never been fully
investigated. In fact Forestry Tasmania did
not consider the Jubilee Mine prior to the certification of
the plan according to Paul Rosevear in a conversation I had with Steve
Manson and Paul following Minister Green's visit to South Sister on
February 11, 2005.
Secondly, I would like to provide you with some examples of unpredictable outcomes to South Sister's groundwater system since the upgrading of South Sister Road and the construction of the new coupe road (running east-west) in February 2005. These include the following:
1) Prior to the roading, there was a pool of water located on
Derrick's Marsh Road, which was often referred to by locals as 'The
Derrick's Marsh Road puddle'. I have walked regularly in the mountain
area for many years and have passed the puddle on many occasions. On
every occasion until a year ago, the Derrick's Marsh Road puddle had
always been full of water. However,
following the completion of roadworks at South Sister, I observed that
the puddle was completely dry. I had never before seen this
'puddle' dry, even during extended dry periods (nor had other locals
some of whom had lived in the area for more than 50 years).
I was shocked to see it dry and therefore continued to monitor the
water levels following completion of road works.
After more than one inch of rain between April 7 and 9, 2005, the
puddle was again full yet on April 12, 2005, it was almost completely
dry again. Rain on April 16 and 17 completely filled the puddle
again, yet on April 18 it had emptied considerably and on April 22 it
was dry.
It would appear that the puddle is emptying quickly whereas in the
past, it was possibly being filled (presumably by a spring) as quickly
as it was emptying. Roadworks/landing construction took place south
and east of the 'puddle' and there was evidence of heavy machinery
having passed through the 'puddle'. It continues to be dry except
during heavy rainfall when it empties again over a few days. Please
see document attached showing various photos of this 'puddle'.
Coincidentally, this area is in the vicinity of the above mentioned
Site 8 (which may or may not be related to the total extraction of
coal below).
2) On the South Sister Road just before the 'first bend' (as described by Forestry Tasmania in their Forest Practice Plan), two trees were pushed over when the road was being widened on or around February 28, 2005. On or around March 23, 2005, I noted a new spring in the batter drain adjacent to the road and directly beneath the fallen trees. I can verify that no spring existed in this batter drain previously - in fact this entire area (drain/gutter) was free from water except after heavy rains.
The relevance of these two examples of noteable changes to water on the coupe is that the groundwater system on South Sister is obviously very fragile. It is not predictable what groundwater changes may occur if harvesting goes ahead. No one knows what may happen to water supplies that are currently being used by local residents. This is why we are asking FT to refrain from logging the coupe. It will be too late to reverse if negative changes occur.
A newspaper article in the 'Examiner' Wednesday February 8, 2006 (p 31) stated that no trees had been spiked on South Sister and logging will commence soon.
It is of great concern to me that
This is reminiscent of exactly one year ago when
As a member of the general public I do expect that legitimate concerns are taken seriously, are investigated thoroughly and appropriate measures instituted. However when I read articles which say logging will go ahead before I have received satisfactory answers to my claims I feel extremely shocked, betrayed and irate. The forest of South Sister has been enjoyed by the general public for many years. To have something taken away which we consider rightfully ours when we have legitimate concerns regarding the safety of logging is most distressing.
Graham, I trust you will keep to your word and investigate the new
claims I have made. I trust you will communicate your response to me
in a timely manner prior to any final decision being
made about harvesting.
I am also still hopeful you will see the absolute necessity of
I look forward to your reply.
Kind Regards,
Frances
PS I am assuming you have all documents mentioned above i.e. David Stapledon Proof of Evidence and supplementary POE, Ralph Rallings' review document etc. If not, please let me know and I will email them all to you.
6254 (1, 4, 9, 200)