Friends of the Forest
9 April 2010
Mr Keiran McNamara
Dear Mr McNamara,
Survey for Declared Rare and Priority Flora in Warrup Forest Block
The Bridgetown Greenbushes Friends of the Forest are concerned about several aspects of the environmental impacts of the plans to carry out logging activities in Warrup Compartment 06, in the Shire of Bridgetown-Greenbushes and hence in the area of special interest of this Group.
In this letter we address one of these concerns, the apparent lack of any adequate survey for Declared Rare and Priority Flora by your Department of the areas the Forest Products Commission is about to log.
We hold this concern because we are aware that four Declared Rare Flora species and five Priority Flora species have been recorded in the general vicinity of Warrup Compartment 06 and have the reasonable view that the lack of survey means this is likely to underestimate the actual number of such flora in the vicinity of Warrup Compartment 06.
While this is only one of our concerns, we believe that an adequate survey for Declared Rare and Priority Flora is one activity that your Department (particularly given its role in flora protection) and the Bridgetown Greenbushes Friends of the Forest should be able to agree should be carried out properly before the significant ground disturbance associated with logging operations is initiated.
We are aware that your Department may not have enough staff to carry out such surveys in all proposed logging areas in a timely fashion. We have therefore initiated discussions with suitably qualified consultants with a view to appointing them to carry out such surveys in Warrup Compartment 06. For this reason we are seeking permission from your Department to carry out the appropriate Declared Rare and Priority Flora surveys in Warrup Compartment 06.
We assure you that all normal protocols, such as the possession of the appropriate flora collection licences, would be properly adhered to and any other normal requirements of your Department complied with. Also, we intend that photographs would be taken of Declared Rare Flora, rather than specimens being collected, so that there would be no direct impact of the survey on such flora.
We are aware that your Department requires surveys for Declared Rare and Priority Flora to be carried out at the appropriate times of the year. Consequently, we propose to carry out Autumn/Winter and Spring/Early Summer surveys to ensure that we meet such requirements.
As well as seeking permission to carry out the surveys, we seek assurances that ground-disturbing activities will not commence prior to the surveys being carried out.
While we disagree with the intentions of your Department to allow logging in Warrup Compartment 06, we believe that our organisation and your organisation should be able to agree that the collection of the appropriate scientific data to allow proper assessment of the environmental impacts of logging in areas such as Warrup Compartment 06 should not be the issue. It should be taken for granted that appropriately qualified persons should be able to carry out such work in accordance with a proper scientific ethos. Therefore, we would be more than willing for appropriate personnel from your Department to work with our flora survey team so that both organisations can have confidence in the results of the survey.
I look forward to your positive response.