South Sister St. Marys, Tasmania
Chief Forest Practices Officer
Forest Practices Authority
30 Patrick Street
HOBART 7000
13 October 2006
Dear Sir
1 I write to bring to your attention evidence regarding the occurrence of the Spotted Tail Quoll around South Sister and the adjoining areas of the Mt Nicholas Range.
The Forest Practices Code 2000 refers to the conservation of threatened species by prescription in accordance with the Duty of Care policy, and that fauna conservation will be considered in all stages of forest management, particularly addressing the requirements of threatened species and communities I ask that the Authority re-evaluate the prescriptions for fauna protection on Coupe NI114A in light of this new evidence.
The original evaluation on 2003/07/15, updated on 2004/12/16 identified suitable habitat for the eastern and spotted tail quoll on the coupe. While it was stated that it was 'particularly important' that such habitat was captured by the standard Code provisions for fauna, no specific prescriptions were included in Plan PWJ 0010 for the coupe.
The Peer Review Form for the coupe (attached), prepared by Peter Johnstone on 2004/11/12 only 24 days before the FPP was certified, including the intervening Christmas and New Year periods, states 'Fauna SP values are out of date'.
As part of a survey programme of the incidence of DFTD undertaken by DPIW, Shelly Lachish, a PhD student of the School of Integrative Biology at the University of Queensland has been undertaking a programme of trapping and recording information about Sarcophilus harrisii on the Mt Nicholas Range, including South Sister, during late September and early October 2006.
She caught and recorded information on 31 Tasmanian Devils, of which 21 were free of DFTD. Twenty nine (29) were less than 3 years old, 2 were 3 years old. A local resident on South Sister has found Devil dens in the area.
Shelly also caught 11 Spotted Tailed Quolls (and 11 Eastern Quolls).
Until now the Threatened Species Unit has records of only 7 sightings of Dasyurus maculatus in this area, derived from a recording process over many years. Now, in one short trapping programme over a few days, the number of sightings of this animal has increased by almost 160%.
Given its classification as 'Rare', this population concentration in such a restricted area is of such significance as to justify a dedicated site investigation by FPA specialists. Reliance on the habitat retention measures prescribed in the Forest Practices Code for fauna in general in areas subject to production forestry activities does not represent an appropriate level of site investigation and prescription for the protection of a rare species.
2 This latest evidence provides yet further confirmation that the South Sister area contains a very special combination of natural values, such as E. brookeriana, Euphasia collina ssp. deflexifolia, Blind and Giant Velvet Worms and Line of Parapatry, wedge tailed eagles, eastern barred bandicoot, devils, eastern and spotted quolls, etc. The Tasmanian Herbarium (Dr. Gintas Kantvilas) reports that there is a remarkable diversity of lichen species, including a new species, a very uncommon species, a species known only on South Sister, a very rare lichen with only one record and that the area is lichenologically significant, requiring specific management prescriptions. Dr. Peter McQuillan has recorded numerous invertebrates, including at least 90 species of moth, of which 3 species are not previously recorded in Tasmania. The Ratkowskys have identified numerous fungi. The President of Birds Tasmania identified over 40 bird species in a one day field trip including all 4 species of robin. An environmental assessment of the coupe area identified over 90 different dicots, monocots and ferns.
These findings represent but the tip of the iceberg as far as the flora and fauna values of the area are concerned - the South Sister area is as bio-diversity hotspot, which needs to be maintained in its present physical state to allow detailed, scientific investigation over time into what appears to be a unique bio region.
On each occasion that a qualified scientist or expert has visited South Sister to carry out a detailed and specific evaluation, there has been a 'find' of particular interest within their chosen field. This area is a unique area of natural scientific interest containing a combination of values which result from its location, elevation, rainfall, cloud mountain characteristics, groundwater and springs, etc, which, ironically, has only been revealed because of the concerns raised by the proposal to log it. There is little doubt that this small area surrounding South Sister peak has the potential to provide exciting finds for natural scientists in many fields for many years to come if its present state of natural dynamic equilibrium is left undisturbed. It is a veritable hot spot of bio-diversity.
I attach for your information a copy of an Environmental Assessment of the coupe (Dudley 2004), Comments on a visit to South Sister (McQuillan 2004), Report on a survey of nocturnal Moth species occuring on South Sister (McQuillan 2004), Preliminary species list of lichens from South Sister (Kantvilas 2005), What is special about parapatric boundaries (McQuillan) and Blind Velvet Worms (Threatened Fauna Manual).
The absence of more threatened species records in the South Sister area reflects an absence of investigation of the area to date, rather than an absence of species.
Given the marginal economic value of the proposed timber harvest, compared with the apparent significance of the area in respect of its bio-diversity values, I hope that the FPA can give the most careful consideration to this new evidence. There is no complaint about the standard evaluation process carried out in assessing fauna site values in preparing the FPP, but it now appears that as a result of specific investigations which go beyond the normal requirements, this particular area appears to have both individual values of high conservation significance, and a combination of values which result in a bio-diversity Index whose sum is greater than the value of the individual parts.
It is significant that the environmental assessment of the coupe conducted in 2004 by Mr. Todd Dudley made specific reference to the need for habitat preservation to protect the Spotted Quoll, almost two years before the discovery of a large local population.
I look forward to your response to this new evidence relating to the spotted quoll, and hope that the FPA agrees that this justifies a further detailed and specific investigation of the site to confirm and possibly extend these findings, with a view to providing for the adequate protection of this species.
Yours faithfully
David Clement
For and on behalf of Save Our Sisters
5139 (1, 2, 6, 154)