Presentation to the
West Regional Forest Agreement
Independent Panel

 

March 2nd 2000

 

Serena O’Meley
on behalf of the
Geelong Community Forum
(final version)

 

 

 

Summary of Key Recommendations

• It is essential that the Independent Panel makes its report directly to the State Cabinet.
• The West Regional Forest Agreement should be abandoned or completely rewritten due to its incompatibility with current State ALP policy.
• The State Government should use the triggers set in place by the Australian Labor Party within the Federal RFA legislation which can be used to prevent the signing of an RFA which does not fully address issues of consultation or the full range of forest values.
• Clearfell logging of native forest should be immediately stopped and never be allowed to resume.
• Workers within the native timber logging industry should be given the option of government funded early retirement or retraining in plantation or alternative pulp industries such as straw and hemp. Some of the money for this could be derived from existing and projected management subsidies.
• Timber mills should be redirected to the plantation estate and small private operators given assistance to restructure.
• The feasibility of selective logging for art and high grade furniture applications should be investigated for those areas which fall outside proscribed water catchments
• Eco-tourism, apiary, medicinal plants, carbon sequestration and other non-timber values should be fully investigated for all native forests in Victoria.
• An independently funded semi-government department (e.g. Environment Assessment Council) should oversee protection of biodiversity and other forest management issues.
• The Department of Natural Resources and Environment should undergo a full review which removes conflicts of interest within management and addresses its lack transparency and accountability.
• Future meetings with the government on forest issues should include cross-ministerial representation (tourism, environment, regional development etc.) which acknowledges the diversity of values represented in our forests.

 

If the West RFA is signed we request the

following actions which draw upon State ALP policy:

• An immediate review of royalties, subsidies and management costs be undertaken into the public native timber logging industry. We require that all these costs be fully recovered from the industry, and that there be no further industry subsidies or restructuring money allocated by government.
• An independent audit of sustainable yield for all regions.
• An independent audit which estimates the worth of all forest values.
• Rights to residual logs to go only to those mills with the highest value adding record.
• A full hydrology study overseen by a balanced stakeholder committee, with the proviso that logging within all proscribed water catchments ceases immediately.
• Independent research into the best logging/silvicultural methods for a given area.
• The immediate appointment of a Commissioner for the Environment and an Environment Assessment Council, which is empowered to enforce fines and removal of licenses from those who breach the Code of Forest Practices.
• The Department of Natural Resources and Environment should undergo a full review which removes conflicts of interest within management and addresses its lack transparency and accountability.
• Future meetings with the government on forest issues should include cross-ministerial representation (tourism, environment, regional development etc.) which acknowledges the diversity of values represented in our forests.

 

Comments on Community Consultation

The Geelong Community Forum became involved with the West RFA in May of last year when we made the decision to hold our own public meeting because Geelong had been cut out of the consultation process. You have in your possession copies of the transcripts from that meeting and samples of correspondence from my organisation since that time. It would be fair to say that the RFA has dominated the activities of our organisation for the past 9 months. We have given it our best and it has defeated us.

Most of our members are not professional people but are ordinary members of the community who wish to participate in and enhance civic life. Our members have struggled through reams of jargon and error laden documentation in the firm and erroneous belief that any person of reasonable intelligence would be able to make sense of how our forests are managed. To some extent our submissions on the Comprehensive Regional Assessment (CRA) reflects this belief. They also reflect the belief that the RFA steering committee would correct the noted deficiencies in data, methodology and consultation procedures which many people have identified.

To choose just one example, there are discrepancies between the job figures cited in the CRA and those cited in the Social Assessment Report (SAR). In the first instance, jobs from a mill which is not in this region were included, in the second, job figures from a mill in Birregurra were apparently left out. Working off the figures in the SAR there are less than 150 people employed as contractors or sawmillers in the Otways. Geelong has seen the collapse of half a dozen industries, costing thousands of jobs, in recent years because of global forces. Why is the logging industry being protected from market forces when no one else is?

You already have our views of the consultations which took place during the term of the previous state government. The continuously shifting timelines alone were frustrating to those of us trying to raise broad community awareness and participation rates. Given these experiences you may be surprised that our members were deeply shocked with the belated, and staggered, release of the Consultation Papers. Many of our members felt that they had been lulled into a sense of false security by the new state government’s apparent commitment to improving the consultation process. Unfortunately the change in government did not signal a similar shake up in the Department of Natural Resources and Environment (NRE).

No matter what the intentions of the State Government were, the bottom line is that the proposed RFA is still fundamentally flawed. If the government chooses to accept the recommendations in this RFA they will never recover their credibility with the environment movement and the wider community.

We feel that it is time to come out from behind the shield of polite and conventional language and state the issues as we see them in the strongest possible terms.

 

As you will be aware Chapter 4 was an addenda and little more than a disgusting piece of propaganda for the logging industry. An entire table of Ecological Vegetation Communities was sent to replace an incorrect one included with the bound copy. The Aboriginal Issues Paper and the Sustainable Yield papers/addenda also did not arrive until eleven days later. Following a meeting with the Minister a senior NRE bureaucrat said that the RFA process was simply not able to take the broad sweep of Aboriginal issues into account.

Continuing on, the Water Summit papers appeared in the post just one day before the closing date for submissions; they do not include any interpretation or recommendations. The specially commissioned Tiger Quoll report is only available electronically, and only then because it was somehow leaked to the press. The Social Assessment Report, apparently released in January, which many people did not even receive, does not have the complete cross industry comparisons which many people believe to be essential for making a judgement about future uses of our forests. To add insult to injury the National Estate papers only arrived in the post - to some people - two days before the Geelong Independent Panel; we have been told that these papers list Riley’s Ridge for protection - the same area which is under attack by NRE!

The section on community consultation is a disgrace - it simply lists (some of) the concerns raised at public meetings but makes no attempt to analyse or integrate these issues into the consultation papers/directions report. Repeated requests for copies of minutes from these meetings led to an admission from one officer that not all the meetings were properly minuted. Similarly, repeated requests for minutes from our meeting with Mick Lumb have been ignored. The maps of the proposed reserves are not sufficiently scaled or marked with known landmarks for a non-forest worker to determine locations. Victoria’s Statewide Forest Resource Inventory, West RFA Maps (CD Rom) is incomplete for the Otways Region. No overlay maps have been provided which show the forest values which are supposedly being taken into account by the Janis criteria. No logging histories were provided. In addition we are not allowed to photocopy coupe plans which would have assisted us with making our submissions.

According to Premier Beattie, the Commonwealth has spent $30.8 million dollars on Victorian RFAs. We deserve better.

The deficiencies of the West RFA Consultation Papers are summed up best by independent consultant, Professor Tony Norton:

In my judgement, the government documentation prepared for the Western Victorian RFA is probably the most incomplete and poorly-based of any yet prepared for an RFA in Australia. Important lessons from other RFAs seem not to have been learnt. Although a number of valuable biophysical and ecological data sets were available to (or created for) the process, the analysis and use of these is typically poor. Integration of resource allocation and management issues across land tenures has largely been ignored. Analyses of the region's forestry sector are poor and significant omissions include a full discussion of the regional opportunities for softwood plantation processing, value-adding, employment growth and wealth creation.

 

We believe that much of the blame for these deficiencies in process and content must rest squarely upon the shoulders of bureaucrats at many levels within the forestry section of NRE. We believe this section is aligned and identified with the logging industry, as signalled by 33 of their jobs being included with the logging industry jobs in the Comprehensive Regional Assessment. We believe that their actions have lacked accountability and transparency throughout the consultation process.

We hold NRE responsible for sabotaging the final stages of the public consultation period. For example, following a meeting with the Minister, we were given a personal undertaking by a senior ministerial adviser that 100 copies of the consultation papers would be made available at our public meeting on the 8th February. He took an NRE departmental head aside and demanded a reprint or photocopies of the papers. Two officers arrived at the meeting with less than 20. This was our last chance to get broad based public participation in the West RFA.

NRE's decision to send logging crews into the most contentious areas within the Otways the very next day after our public meeting in Geelong put the final nail in the coffin. This action has meant that almost everyone directly involved in consultations in the Otway area has been diverted to blockades or advocating through the government and the media for the safety of the blockaders rather than concentrating on submissions. That observation includes this submission for the Panel.

We believe that the RFA process has little to do with good science or responsible economics. Professor Tony Norton, a distinguished ecologist, has already declared that clearfell logging is not ecologically sustainable and its impacts are largely untested. Cameron Steele has taken information from various scientific papers, applied some common sense, and demonstrated to our satisfaction a connection between clearfell logging and water yield loss independently of the work by the Otway Ranges Environment Network. We agree with the assessments of the Geelong Environment Council and the West Victorian Forest Protection Network, that the scattered, lineal reserves developed in the West RFA are not Comprehensive Adequate or Representative. We also wholeheartedly support the conclusions of the Otway Ranges Environment Network with regard to their economic analyses.

So why is this heavily subsidised, unsustainable and damaging industry still operating with impunity?

 

Rather than finding answers simply in science or statistics, we believe we have found them in politics:

• A timber industry with a powerful public relations machine and license to destroy irreplaceable habitat for negligible monetary gain (see Appendix 1).
• Some timber workers who are willing to use extreme violence to suppress legitimate protests but are not willing to fight to have their industry restructured in a sustainable way.
• A government department more self serving and conniving than Humphrey Appleby’s in ‘Yes Minister’.
• A state government ministry captured by its department and unduly swayed by the forestry union.
• A federal government held in the thrall of free market economic fundamentalism and the need to satisfy World Trade Organization dictates for export woodchips.

We have full confidence in the independence of this panel. However, no one can expect that the appointment of an Independent panel working to a ridiculously short time frame is going to cut through all these issues. This panel is not even empowered to make a direct recommendation to the state environment Minister.

At a State level, the power to determine ‘Our Water Our Forest Our Future’ lies somewhere between the Premier Steve Bracks, the Minister for Conservation and Environment, Sherryl Garbutt, The Minister for Regional Development, John Brumby and the Minister for Tourism, John Pandanzopoulos. That is why it is essential that this panel does make a public and direct submission to the Cabinet on the West RFA and does not rely upon the West RFA Steering Committee to take our views into consideration. That Committee has disqualified itself through sheer incompetence and collusion.

 

Why the ALP Cannot Accept this RFA as it Stands

Prior to the last State elections, and following the elections, the ALP made a number of clear commitments to the community. If the ALP adopts this RFA they will automatically be breaking a significant number of their pre-election promises:

Selections from the ALP West RFA Preelection Policies:

1) Labor supports Regional Forest Agreements (RFA’s) which provide for:

Ecologically sustainable wood production and wood product industries, maximising value adding opportunities and efficient use of wood resources.

It cannot be honestly claimed that this is a value adding industry when:

22% of the timber goes to sawlogs, and only 2.2% of that is made into appearance grade sawn timber.

8.9% is made into firewood, used as slabbage, strips & bearers and sawdust fines

69.1% is chipped.*

In addition, the pulp is valued added in Japan and then sold back to us.

By comparison, Dr Judy Clark has reported that "80% of Australia’s plantation timber is processed in manufacturing plants into sawn timber, wood panels and pulp and paper...[while] less than half of the native forest wood that we log today goes into the manufacturing industry." (Official Committee Hansard - Senate Rural and Regional Affairs and Transport Legislation Committee. RFA Bill 1998, Tuesday Feb. 1999. Melbourne).

* (Note: these are approximations based upon p.49 of the CRA. There are, as usual, discrepancies between the figures reported in the CRA between pp.45-50.

2) Labor does not support Regional Forest Agreements which do not include the meaningful participation of all the relevant parties, and which are not open and accountable. Labor does not support RFA’s that do not properly resolve competing uses in the forest based on the best available scientific evidence. Nor does Labor support RFA’s which do not properly take into account social, economic, environmental and indigenous heritage issues.

Even with the revised consultation period, this RFA does not competently address any of these issues, as discussed above. Therefore, the RFA can be disallowed in the Senate thanks to a clause which the Australian Labor Party inserted into the Howard Government’s Regional Forest Agreement legislation which requires that these objectives be met.

3) Labor believes the management of our precious forest resources requires open accountability and public scrutiny.

The suppression of the quoll papers coupled with the impossibly difficult task of obtaining documents pertaining to royalties, coupe plans and various industry audits speaks for itself.

4) Labor will encourage the use of funding available to the industry through the RFA process to assist with restructuring where the logging of native forests proves to be uneconomical.

Why have we heard nothing about industry restructures when it is common knowledge that the sawlog industry is uneconomical? This RFA money will disappear if the West RFA is signed.

5) Labor will undertake comprehensive hydrology research to determine the impact of logging on water yields and water quality in the proclaimed water catchments of the Otway State Forest.

NRE, in its total contempt for government policy, is currently allowing logging in the experimental site. To reintroduce Silvicultural Research in a new area could cost millions more than originally projected.

6) Labor will set up an independent review to ensure that royalties and charges cover all State management costs.

This is one of the few promises which the ALP could still feasibly hope to honour, and therefore deserves a more extensive discussion.

The ALP acknowledges within its preelection policy that the royalties paid on timber are between 30-60% below market value as shown in a report required under National Competition Policy, and produced by consultants KPMG (May 1999). There is no excuse for not immediately rescaling the royalties on timber. This also needs to keep in mind that log grades are often reclassified downwards as noted in the Auditor General’s Special Report 22. on the Timber Industry Strategy (May 1993).

In Victoria subsidies to the logging industry on State land have been estimated at $50 million dollars per annum by, A.K. Dragun (The Subsidisation of Logging in Victoria. La Trobe University, January, 1995).

Another study commissioned by the Commonwealth Government has more conservatively estimated these costs at $25 million dollars per annum (Subsidies to the Use of Natural Resources: Environmental Economics Research Paper No.2. National Institute of Economic and Industry Research for the Department of the Environment, Sport and Territories: Commonwealth of Australia [nd]).

The authors then go on to list hidden environmental subsidies apart from those associated directly with forest management, including losses associated with: soil erosion, flora and fauna and reduction in bio-diversity, water values, tourism and heritage impacts, greenhouse impacts, and fire damage from forestry operations.

Their notes on water catchment values refer to yet another suppressed report by the Victorian State Government (1994) which "is believed to verity the [Read, Sturgess and Associates] 1992 study conclusion that foregone water production has a higher value than logging (p.101)" in Thompson River Catchment.

We would also like to draw your attention to a recent forest fire near Kennedy’s Creek (Geelong Advertiser 13/1/00). The fire started in a logging storage facility and burnt out 70 hectares of native forest, took more than 200 NRE and CFA firefighters, 22 tankers, 7 4WD units and four aircraft to control. When these situations arise, how much money does it cost the State?

The authors of Research Paper no.2 note that "softwood stumpages (timber royalties) are, overall, significantly higher in Australia than those for hardwood and this tends to encourage production from native hardwood forests which are important repositories of biodiversity and other non-timber values (p.100)."

Similarly in a more recent report commissioned by the Commonwealth, Frances Grey et al. also note the effectual subsidies to native timber industry, while other factors cause rising costs within plantations. From a list of 22. market distortions which she ‘cobbled together’ from a series of reports and inquiries into the timber industry, the following seem to apply most directly to native timber harvesting:

1. The lack of marginal cost pricing.
2. The non-existence of effective commercial accounting systems.
3. Long-distance transport subsidies.
4. Non-payment of rental for use of public land.
5. Low royalties; ie. low log prices for timber.
6. Possible cross-subsidisation from community.
7. No liability for payment of a resource rental use.
8. No liability for payment of notional income tax (presumably meaning company tax)
9. No liability for local government rates.
10. No liability for sales tax on vehicles, plant and equipment.
11. Non, or low, payments of interested on borrowed capital.
12. Non-payment of dividends.
13. Low user charges for cost recovery from long-distance transport.
14. The dominant market role of state forestry agencies.
15. Failure to account for non-financial values in pre-logging operations either by exclusion of areas or by forestry codes of practice.
16. Failure to adequately assess the potential financial contribution from sales of goods and services such as water from the native forest.
17. Failure to separate commercial operations from regulatory functions.

(Estimating Values for Australia’s Native Forests. Environmental Economics Research Paper No.4. Frances Grey Consulting Economist At Large and Associates for the Department of Environment, Sport and Territories. Commonwealth of Australia [nd], p.44).

Her conclusions from the literature review notes that the assessment non-financial values is not occurring. "It would seem fair comment that if relatively simple choices between wood and water production are not being evaluated (e.g. Read and Sturgess, 1992), then other more complex interactions are also being neglected (p.45)."

We would like to think that if native timber harvesting were subject to market forces that the industry would be forced to use alternatives.

With serious financial issues such as these completely unresolved, indeed ignored, by the consultation papers, how can we possibly consider signing away our forests for 20 years.

Selections from A New Framework for Sustainable Forest Management in Victoria, December 14, 1999 Released by Minister Hon. Sherryl Garbutt, MP.

The revised framework for sustainable forest management released after the election shows the insidious influence of NRE upon the Minister’s decision-making:

1) The National Forest Policy Statement, the Victorian Timber Industry Strategy, the Code of Forest Practices for Timber Production, Victoria’s Biodiversity Strategy, and the Flora and Fauna Guarantee Act set a framework for forest management and a viable timber industry within an environmentally acceptable framework. They lay firm policy foundations for environmentally sustainable forest management. Regrettably they were not given sufficient attention by the former government.

On paper many of these sound good, but in practice they are disregarded. The following examples highlight the flaws in using these documents as a starting point for policy:

• The Auditor General’s Special Report no.22 (May 1993), is a devastating critique of the Timber Industry Strategy. Little if anything has changed.

• There are continual reports of breaches of the Code of Forest Practices for Timber Production, including harvesting upon slopes inclining more than 30% and harvesting inside buffer zones. The Code is rarely enforced and only relies upon a points system, rather than monetary fines. One conservationist has likened it to driving your car excessively over the speed limit and then slowing down to a crawl to even things up. If you were in your car you’d loose your license, with the CFP you wouldn’t even be fined.

• As members of OREN found to their cost, timber operations are exempted from the flora provisions in the Flora and Fauna Guarantee Act.

 

• The spot tailed quoll Action Plan no.15. requires that a minimum of 300 quolls be kept alive in the Otways. As was shown in the leaked quoll report (Chris Belcher 1999), NRE is in breach of the Action Plan, and presumably the Act, thanks to the secondary poisoning of quolls which eat rabbits killed by 1080 poison baits. These baits are carelessly laid by NRE to stop rabbits from eating ‘regeneration’ areas. Thanks to NRE’s mismanagement the spot tailed quoll may need to be added to the critically endangered list due to a catastrophic reduction in numbers.

• The National Forest Policy Statement requires that native forest harvesting be based upon the full cost of "efficient management of wood production" (1992: p. 21) including an adequate return to the community for the use of this public resource. As demonstrated above, this is simply not happening.

2) The management of Victoria’s native forests in the best interests of all Victorians represents a critical challenge. The Government is committed to putting in place new practices to better manage the multiple roles of our forests in maintaining our natural heritage, biodiversity, health and well-being.

These native forests must be managed in a way which recognises competing, but potentially reconcilable, demands...

We believe that it is fair to say that there is only one demand which is completely unreconcilable within the State Forests and that is clearfell logging. We would not need to have this outrageously expensive consultation process if logging was not the core value being promoted by the RFA. It is clear that the West RFA is not dedicated toward value adding, but is simply a mechanism to lift woodchip export controls, as the Consultation Paper section on ‘Resource Certainty’ reveals.

It is time that the most damaging and financially unsustainable value was taken out of the equation.

How does one measure the cost of driving a species to the brink of extinction? How important is water to the community? And what about the growing boom brought about by tourism?

To address, the last issue, the amount of money drawn to a community by tourism is phenomenal and more than eclipses the logging industry. Focusing on just the SurfCoast Shire, Henshall Hansen Associates et. al (The Economic Significance of Tourism to the SurfCoast Shire, October 1996) note that the industry contributes 1,970 direct jobs and $98 million dollars to the Shire. The same report notes that hinterland tourism has not been properly integrated with the coastal attractions. Since this report was released the tourism industry has grown exponentially, as can be seen from a newly released report by Tourism Victoria which estimates that tourism along the Great Ocean Road accounts for $883 million in expenditure from domestic visitors alone (National Visitor Survey 1998). If only a small percentage of the overall tourist dollar were redirected toward ecotourism opportunities in the hinterland, the logging industry could be bought and sold many times over.

The tourism analyses within all the documents produced by the West RFA Steering Committee have been embarrassingly slim. The tourism industry is clearly not compatible with clearfell logging which decimates the aesthetic values of an area. Claims that NRE fully ‘regenerate’ an area is nothing short of a public confidence trick. The result of their work is a monoculture, with no ground cover with evenly aged and spaced trees, and dead native animals. This is not the sort of forest that tourists drive hours to see.

Concluding Note

The Geelong Community Forum builds upon years of shared experience in community campaigning and lobbying. Our membership includes key people from over five political parties, and ranges from teenagers to senior citizens. We are fiercely independent and non-partisan in our approach to environmental and community issues. After investing nine months in the Regional Forest Agreement process we have reached the following decision:

If the State and Federal governments adopt this RFA we will not allow the forest issue to be retired into the background while the Otways and other areas are quietly destroyed over the next 20years. The responsibility for something as important as our forest heritage, water supplies and economic well-being cannot continue to be shifted on to marginalised groups of young people who are easy targets in the press, and physically vulnerable in the forests. These young people deserve all our gratitude and support. In partnership with a growing statewide alliance of community and conservation groups, we will dedicate a minimum of two years to mainstreaming this issue across party platforms and throughout the community.

We are confident that the campaign to stop clearfell logging will gain an unstoppable momentum across the State.