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[2022] NSWLEC 75
Land and Environment Court (NSW)
2021-12-17
Moore J, Ms J
Original judgment source is linked above.
Introduction
The Corporation's offending conduct
The Corporation's guilty pleas
The sentencing hearing
Representation at the sentencing hearing
The Statement of Agreed Facts on Sentence
The Supplementary Statement of Agreed Facts on Sentence
Diagram 1: Approximate location of the five disused mineshafts and bat tunnel at the site. The Disused Mineshaft is Shaft 1. Source: Expert report of Amy Rowles dated 1 November 2020, p 7. 6. Approximately four kilometres north of the site is a long solid rock horizontal tunnel with Eastern Horseshoe Bats and large guano deposits. 7. The Disused Mineshaft in question is 7.5m deep, with an opening at the top of the spoil mound of 4.3 x 3.7m and narrowing to a vertical rock shaft of 1.3m x 2.3m. An image of the opening of the Disused Mineshaft, taken on 28 September 2021, is at Tab 1 of this statement of facts. 8. The Disused Mineshaft contains a horizontal adit extending in a north-west direction at the base of the shaft. 9. During an inspection at dusk on 28 September 2021, Ms Rowles observed an Eastern Horseshoe Bat circling in the top section of the shaft but did not see whether it had exited from the horizontal adit. On 29 September 2021, Ms Rowles observed one Eastern Horseshoe Bat exiting and re-entering the horizontal adit. EASTERN HORSEHOE BAT 10. The Eastern Horseshoe Bay is not listed as a threatened species under the Biodiversity Conservation Act 2016 or under its predecessor, the Threatened Species Conservation Act 1995. 11. The population of the Eastern Horseshoe Bat in the Dampier Forest is likely to engage in nightly movements to forage within a few kilometres adjacent to their roost location but also, over the course of months, to move between a network of suitable roosts, perhaps up to 30km distant. The occurrence of the Eastern Horseshoe Bat in southern NSW is constrained by the presence of subterranean roosts with suitable dimensions, such as disused mineshafts, a microclimate of high humidity and suitable foraging habitat of about two kilometres of the roost. The species depends on a network of roost sites and does not reside permanently at one roost site. 12. Populations of this species in central and southeast NSW are thought to have declined over the past few decades, however, it is not known if the population in the Dampier Forest, or southern NSW in general, is declining, stable or increasing. An image of Eastern Horseshoe Bat is included at Tab 2 to this statement of facts. 13. Trees were felled over an area of 0.2ha out of a 0.5ha exclusion zone. This had the potential to significantly increase solar radiation and increased desiccation of the forest stand. Solar radiation on the mouth of the mineshaft from the North would have increased due to the tree removal in this direction, however, this would have been lessened by trees within 16m of the shaft being retained. This has the potential to impact the temperature and wind profile within the exclusion zone and alter the microclimate of the Disused Mineshaft. In light of the depth of the horizontal adit from the surface and measurements taken on 28-29 September 2021 (by an ecologist retained by the defendant) of the temperature and humidity at the base of the shaft, any impact on the vegetation is not likely to change the temperature and humidity of the horizontal adit to any significant degree. 14. Noise and possible vibration arising from logging machinery and tree felling had the potential to disturb Eastern Horseshoe Bats roosting in the Disused Mineshaft by arousing Eastern Horseshoe Bats from their daytime torpor, causing bats to fly around or exit the roost during the daytime, thereby reducing their energy levels and increasing predation risk from diurnal bird predators. There was potential for collapse of the roost, obstruction of the roost entrance from vegetation or a change in vegetation structure caused by the felling, but there is no evidence that any of these occurred. 15. Exclusion zones surrounding subterranean roost entrances serve to maintain the microclimate within the roost by preventing changes to the forest profile. This is significant for the Eastern Horseshoe Bat, compared to other cave roosting bat species in the region, for which very high humidity, typically higher than 85%, is considered essential for the survival of the species. It is not possible to know if the microclimate of the mineshaft was altered to some degree as a result of the clearing (without a before and after experiment or study). ENVIRONMENTAL HARM: s 13.12(1)(a) 16. It is likely the logging of trees on 2 May 2019 in the exclusion zone around the Disused Mineshaft caused some harm to any Eastern Horseshoe Bats that were roosting in the adit at the time, due to the noise and vibration in the exclusion zone from the tree felling and use of machinery. The extent of harm is considered to be minor due to: a. the time of year that the clearing occurred which was not during winter or the maternity season for any microbat species, thus any energy loss for any bats flying in, around or out of the roost, would not have been significant due to suitable weather conditions for foraging, most likely occurring at night; b. the short length of time the disturbance took place; c. the presence of other known roost sites within 150m of the Disused Mineshaft providing alternative roosting sites; and d. the immediate area around the roost entrance remaining intact. 17. A loss of dozen or more bats would represent a potentially significant incremental increase in overall mortality rates for the local population. There is no evidence that any bats were lost.
The evidence
Introduction
The Forestry Act 2012
The Biodiversity Conservation Act 2016
The Crimes (Sentencing Procedure) Act 1999
The Criminal Procedure Act 1986
The Fines Act 1996
The maximum penalty for the offence
Introduction
The extent of harm caused
The Prosecutor's submissions on harm
The submissions for the Corporation
Practical prevention measures
Foreseeability of harm
Control over the causes of the offending conduct
Consideration
Introduction
Introduction
Environmental harm
Prior offences
The Corporation is a good corporate citizen?
The likelihood of reoffending
The Corporation's prospects of rehabilitation
Contrition and remorse
The Corporation's guilty plea
The extent of assistance given to the Prosecutor
Characterisation of the Corporation's offending conduct
Introduction
The Prosecutor's submissions
Submissions for the Corporation
Consideration
Introduction
Specific deterrence
General deterrence
Introduction
The Prosecutor's submissions
The Corporation's submissions
Consideration
Introduction
The submissions for the Prosecutor
The submissions for the Corporation
Conclusion on the appropriate starting sentences
The Corporation's guilty pleas
Introduction
The Prosecutor's position
The Corporation's position
Consideration
A publication order
Diversion of portion of the penalty to a research project
The potential for training orders
Introduction
Environment Protection Authority v Barnes
Introduction
The Prosecutor's submissions
The Corporation's submissions
Consideration
A general costs order
The Prosecutor's investigation costs
Orders
Annexure C ANNEXURE "C" The Forestry Corporation of New South Wales convicted of offences in relation to harvesting operations in Dampier State Forest in 2019 Forestry Corporation NSW has been convicted in the Land and Environment Court for an offence under the Forestry Act 2012 (NSW) for breaching three conditions of its integrated forestry operations approval. Forestry Corporation NSW breached its approval by failing to carry out its licensed activities in Compartment 3133 of Dampier State Forest, near Bodalla. During the harvesting operations, on 2 May 2019, the Forestry Corporation failed to mark an environmentally sensitive area in the field. As a result, trees were felled within and around the exclusion zone for the subterranean bat roost for the Eastern Horseshoe Bat. The harvesting operations did not cause actual harm to the subterranean bat roost, but likely caused minor harm to any Eastern Horseshoe Bats roosting at the time. There was also a risk of actual harm in the circumstances of this incident. The prosecution was brought by the NSW Environment Protection Authority (the EPA). The Forestry Corporation cooperated with the EPA during the investigation and pleaded guilty to the offences. The Forestry Corporation has been fined a total of $185,000 and ordered to pay an additional amount of $45,000 to the Australasian Bat Society Inc to undertake research into the impacts of a 2019/2020 wildfire on a key roost of the Eastern Horseshoe Bat on the South Coast. The Forestry Corporation has also agreed to pay the EPA's legal costs as agreed or assessed. This notice was placed by order of the Land and Environment Court of NSW and was paid for by the Forestry Corporation. DISCLAIMER - Every effort has been made to comply with suppression orders or statutory provisions prohibiting publication that may apply to this judgment or decision. The onus remains on any person using material in the judgment or decision to ensure that the intended use of that material does not breach any such order or provision. Further enquiries may be directed to the Registry of the Court or Tribunal in which it was generated. Decision last updated: 23 June 2022
Environment Protection Authority
Forestry Corporation of NSW
etary, Department of Planning, Industry and Veen v The Queen (1979) 143 CLR 458; [1979] HCA 7 Veen v The Queen (No 2) (1988) 164 CLR 465; [1988] HCA 14 Walden v Hensler (1987)163 CLR 561; [1987] HCA 54 Category: Principal judgment Parties: Environment Protection Authority (Prosecutor) Forestry Corporation of NSW (Defendant) Representation: Counsel: Ms G Wright SC (Prosecutor) Mr I Hemmings SC/Ms J McKelvey, barrister (Defendant)
[2005] HCA 25
(1993) 32 NSWLR 683
(2013) 199 LGERA 1
(2013) 199 LGERA 236
(2006) 148 LGERA 299
(1989) 167 CLR 348
(2005) 229 CLR 357
(2011) 244 CLR 120
(2009) 170 LGERA 253
(1999) 199 CLR 270
(1979) 2 NSWLR 582
(2000) 49 NSWLR 383
(1979) 143 CLR 458
(1988) 164 CLR 465
(1987) 163 CLR 561