28 September 1999

Catharine Masters
Forests Taskforce
Department of the Prime Minister and Cabinet
3-5 National Circuit
Barton ACT 2600

Dear Catharine

Re: Regional Forest Agreement, West Victoria.

This submission to the RFA West Victoria, CRA Report Vol 1 July 1999, is presented on behalf of the Friends of Bannockburn Bush.

It addresses five key areas of concern:

1. Conservation of biodiversity and the Flora and Fauna Guarantee Act 1988

2. The common wealth of the people of Victoria

3. Conservation of water resources

4. The inequity of the public consultation process

5. Lack of community faith in the Department of Natural Resources and Environment under Minister Tehan and Premier Kennett.

1. Conservation of biodiversity and the Flora and Fauna Guarantee Act 1988

Public information material endorsed by Premier Kennett and Environment Minister Tehan states unequivocally, of the prime importance of conserving our biodiversity and speaks proudly of the many Acts, agreements and regulations that enforce this protection. ( Victoria’s Biodiversity series of booklets. NRE 1998.)

Contrasting sharply with this public information is the Flora and Fauna Guarantee (Forest Produce Harvesting ) Order 1998, 15 December, in which the Minister Tehan allows the destruction of protected flora when associated with timber harvesting or road works authorised under the Forests Act 1958.

We do not understand how the logging and roading processes alter in any way the importance of the conservation of biodiversity. Presumably the original FFG act was produced to offer protection from the very same processes that are being exempted. What greater threat to native vegetation do we have than clearing, clear felling and road building?

Total biodiversity.

Modern studies of 16sRNA have demonstrated that the overwhelming majority of our genetic diversity resides in microbial DNA and RNA. Yet there was not a single reference to the microbe groups in CRA Vol 1. The more conspicuous and readily identifiable large plant and animal species were mentioned but not the most significant nutrient and carbon cycling organisms which are not only crucial for healthy forest growth but which suffer most from the destructive processes associated with clearing, soil disturbance, burning and altered hydrology.

Are data on microbial function being gathered.?

What is known of the microbial flora of the litter layers and streams? How much work has been done on the role of microbes in recycling forest litter after felling operations?

Has the role of soil based microbial mats in nutrient processing been considered?

Re CRA Section 12.8 page 194. Aquatic fauna species assessment. The CRA outlines the many risks but concludes in a far too con-committal way regarding protection measures. Generalisations such as "aimed at protecting" and "guidelines can be developed" are used which do nothing to reassure the Otways limnologists, microbiologists, icthyologists or entomologists.

Very little is known about the invertebrates of the Otways except that whenever you look you will find new species. Taking this fact together with the ease with which the toothless FFG act is ignored and the rather fragile Otways Forest Management Plans, we are not satisfied that our biodiversity is being appropriately valued.

2. The common wealth of the people of Victoria

Setting aside the contentious issue of indigenous land rights, our founders had the foresight (after some community provocation) to set aside land for conservation and forest production uses. The intention was to provide building materials, recreation, employment and wealth for the citizens of Victoria. The forests were not valued so much in their own right, but seen as a resource for our use.

Times have changed. The community has become more aware and more concerned over environmental issues, particularly given Australia’s shameful extinction record. Unfortunately, the "utilisation" mentality persists in some areas. The Victorian Department of Natural Resources and Environment, DNRE was previously known as the DCNR, Department of Conservation and Natural Resources.

The significance of our genetic heritage is now being recognised. The Deep Ecology movement has highlighted the problems of "species imperialism." Current economic analysis of the logging processes in the Otways show that the industry as a whole is not only operating at a loss it is also threatening income from other more environmentally sustainable activities as tourism.

There are many people in the State who would be very happy to call a long overdue halt to our subsidy of the woodchipping industry.

We would be very interested to learn what per capita value is derived from logging operations in the Otways. Any audit should include environmental, social, water supply and economic values. We would be most surprised if the resulting value was not negative.

Our local timber needs can be met by farm forestry. Our native forests are better off vertical.

3. Conservation of water resources

The study, Determinants of water quality and aspects of water production in the Upper Barwon catchment system, conducted by the consulting firm Gutteridge Haskins and Davey for the DCFL (Department of Conservation, Forests and Lands) in 1985 by P. F. Clinnick, page 8, places the value of water from a given area of forest ( $162,800 ) over a typical rotation as twice that ($87,500) derived from logging.

The study, Hardwood harvesting and Water quality in the Otways by P.W. Farrell and P.M. Novotny November 1995 for the Research branch of the State Forests and Lands Service, makes these comments in the summary:

"The relationship between water quality and hardwood harvesting was investigated for the West Barham catchment..... Harvesting was found to have a moderate effect on water quality in sub-catchments that had been harvested between 1976 and 1983. .....Poor drainage from compacted areas such as roads, snig tracks and log landings was identified as the key factor responsible for these effects.

An intense storm in March 1983, with an average recurrence interval of 10-17 years, produced significant effects in the West Barham Catchment.

....In contrast, harvesting of additional areas specifically for pulpwood potentially involves a greater hazard to water quality, particularly if further road construction and stream crossings are required."

Barwon Water and NRE are currently planning to log within the East Barwon catchment and to construct a major road to facilitate this activity.

Geelong is currently facing a water crisis. The fact that we have been on water restrictions for more than a year helps to underline these analyses. Clinnick’s figures are probably conservative when longer term economic impacts such as the limits to establishment of new industry is considered. At least one potential investor has rejected Geelong as a site for new plant due to the unreliability of the water supply. Farrell’s work did not consider the woodchip driven aspects of the clearfelling process nor the difficulties the NRE has adhering to the OFMP.

Logging costs too much.

What do we have to show for the destruction?

4. The inequity of the public consultation process

While the deadline in practical terms for RFA submissions in West Victoria is close, it has to be recognised that the west region CRA is one of the most complex and controversial in Australia, yet it has been allocated only 6 months in comparison to the 18 months or more allocated to other Victorian regions. On top of this, Victoria is in crisis with its government and NRE officers have not attended public consultations citing the "caretaker mode" as justification.

And on top of that the citizens of Geelong would have been completely excluded from the public consultation process if firm action had not been taken by environmental groups. It was necessary to force a public meeting in Geelong to gain a say in a process that effected us all very deeply through our water supply, through our desire for local economic viability and through our concern for the conservation of biodiversity.

Geelong had to be stamped back onto the RFA map.

On top again is the significant absence of volume 2 of the CRA at the time of writing. (RFA website last updated Aug 18 )

In addition, the CRA west document, although very heavy, contains very little information by which to assess the viability and sustainability of current forestry practices in Victoria. Material available in the public arena has been far more informative and reliable.

Issues of key concern, such as water supply are glossed over and many significant studies have been ignored or worse, deliberately excluded.

It has been very difficult for people such as myself, who work full time and already have many community commitments to find the time to verify information and to source other essential documents.

5. Lack of community faith in the Department of Natural Resources and Environment under Minister Tehan and Premier Kennett.

While many concerned scientists, politicians and environmentalists have called for and even commenced ( the ill fated SSP ) further research into the effects of logging and roading operations on water quality and quantity in the Otways, efforts are still being made by NRE to discount, ignore or discredit overwhelming evidence of the triply problematic effects of logging Otway Catchments; common wealth costs, biodiversity costs and water supply costs. Not to mention the religious or "God’s Earth" argument.

In short the RFA process has become a joke in Victoria and the only way to even pretend to achieve a lasting agreement is to allow at least another six months for proper consideration of the issues.

It could be added that if the current Liberal government is toppled, it should be much easier to hold frank and open talks with NRE officers.

Friends and conservation colleagues within both NRE and Barwon Water are embarrassed by the lack of accountability of their superiors.

Summary

This submission makes three main requests:

• Any RFA covering the Otways must prohibit any logging in water supply catchments.
• At least a further six months of real public consultation is required for any reasonable and lasting RFA for this region.
• Appropriate consideration must be given to microbial biodiversity as these often overlooked organism are essential to functioning ecosystems. Victorian Universities and the consultants SKM (Sinclair Knight Mertz), are well equipped to conduct such studies.

 

Yours sincerely

Stuart McCallum
Friends of Bannockburn Bush
Geelong Community Forum