Regional Assessment Report
This submission has been written on behalf
of the Geelong Community Forum by Serena O’Meley (Section
One) and Cameron Steele (Section Two)
ONE - Serena O’Meley
Chapter 1. Background to the RFA Process
Comments upon Methodology
It is of concern to our members that
the CRA is being released in two stages. According to
CRA(1) "The Directions Report builds upon information
contained in the CRA report and the results of
consultations with the community" (p.4, my italics).
This raises important methodological questions from the
Firstly, it is unclear when the second
CRA will be released, but advice from officers within
Agriculture, Fisheries and Forestry suggests that this
could be concurrent with the release of the Directions
Report. It is of grave concern that elements of data referred
to in CRA(1) will not be available until the release of
the second report.
Secondly, the Geelong community was not
included in initial consultations and was not informed
of funding opportunities to assist with community consultation.
In response to public demand the Geelong Community Forum
held a public briefing (1/6/99) which was attended by
over two hundred people, with six speakers representing
industry, government and conservation interests. One positive
outcome from this meeting was Geelong’s inclusion in the
West RFA briefing circuit.
However, a follow-up ‘workshop’ (16/8/99)
held in Geelong by the responsible departments just one
week after the release of CRA(1) was farcical. It included
a cursory presentation upon the contents of CRA(1) followed
by questions from the audience. The legitimate concerns
of the audience, particularly concerning the impact of
clearfell logging upon water catchments in the Otways,
were dismissed out of hand by the DNRE representative.
Concerns about the timing of public consultations were
also not addressed. Participants in a meeting at Enfield
later in the week were even more disadvantaged as officers
from DNRE did not turn up due to the announcement of the
State Government Election.
A second round of funding for community
consultations was announced at the CRA workshop and application
forms have been made available just one week before the
deadline is due for submissions on the first volume of
the CRA. In the meantime the Geelong Community Forum has
run its own low-budget workshop on the contents of the
CRA(1). We did so because we are committed to increasing
community participation in the consultations and believe
that the CRA is a critical stage within the RFA process.
As it states within CRA(1) this is supposed to be the
time when, "Any deficiencies in the data or methods
identified at that stage can be taken into account in
the development of the Directions Report."
Given that the RFA will hold for 20 years
we urge that community consultations be undertaken with
all regard and care for due process. The iterative approach
to consultations and document development appears at first
glance to be quite sound, but will only work if enough
time is allowed between stages. We don’t believe that
this time is being allowed. It is generally understood
that the West RFA is being rushed because of restrictions
upon the export of wood chips should the signing of the
agreement be delayed beyond the end of the year.
It is the view of the Geelong Community
Forum that public submissions be accepted upon the first
volume of the CRA up until the closing date of submissions
for the second volume. We also ask that the second volume
be released well in advance of work commencing upon the
Directions Report. We believe that unless the CRA is treated
as a whole and integrated meaningfully with comments from
the community before further drafting of documents, then
based upon its own terms of reference, the Directions
Report will be seriously flawed.
Chapter Two - West Region
It is of concern within the construction
of the CRA that certain data of interest to the public
has been aggregated. Within the fields of social and environmental
impact analysis data aggregation is known to favour economic
analyses while disaggregated data is more likely to reflect
the complexities of competing values within a community.
It also raises the question of transparency and accountability
as aggregated data allows important data to be hidden
from view. This is a issue which we will return to several
times in our comments.
Data Aggregation- example one
"Although the formerly government-owned
plantations are now privately managed, these areas are
also included as public land as the land is leased from
the Crown" (p.8).
The privatisation of our plantations
is a contentious political issue, and this data should
be made available to the public as a separate item within
Data Aggregation - example two
"It is estimated that the Victorian
timber industry (defined as the forestry and logging sector
and the wood and paper products manufacturing sector)
directly employed around 29 865 people. Within the West
region, the timber industry directly employed 3718 people
in 1996..." (p.10).
The operational definition of ‘timber
industry’ would be fine if separate figures were provided
for each sector of that industry, including breakdowns
which differentiate between plantation and native forest
Data Aggregation - example three
"Between 1991-96, employment in
the Victorian forestry and logging sector increased by
30 per cent, while in the wood and paper products sector,
employment increased by 9 per cent. In the West region,
employment in these sectors over the same period reflected
these movements, with employment increasing by 42 per
cent and 22 per cent respectively. The increases largely
reflect the increased establishment, harvest and utilisation
of the plantation resource in the West region."
Once again, for a fair assessment of
employment patterns, there should be differentiation between
plantation and native forest components.
Chapter 3 - Forest Management and Resource
Community Consultation is mentioned
under the headings ‘Forest Management Plans’ (18) and
Wood Utilisation and Coupe Planning (19). We believe that
community consultation is a critical component of the
RFA process, and request that more detail be made available
about ongoing consultation procedures, including the periods
after the RFA is released. A section of the report should
have been expressly dedicated to consultation methodology.
We believe that a compendium of the concerns expressed
by the individual and organisational submitters should
be made available to the public at all DNRE offices.
The recommended silvicultural practices
described within the remainder of this chapter paints
a very disturbing picture of the future of our forests.
We believe that an inappropriate emphasis has been placed
upon commercial concerns which has skewed the report to
favour inappropriate methods of regeneration and ‘harvesting’.
Thinning is undertaken so that
the growth rates of remaining trees is increased (e.g.
p.26), in fact, it is even stated that "As overwood
has an inhibiting influence on regeneration, the removal
of large trees not required for habitat or cultural purposes
provides gaps of about two hectares, which are necessary
for the establishment of regeneration" (p.23, my
italics). The ‘necessity’ to thin overwood is a priority
relating to wood harvesting, not to the natural regrowth
of forested areas. We are also concerned that thinning
practices may be used on old growth forest areas.
It is claimed that ‘mechanical disturbance
of the soil is required for adequate regeneration [of
Mountain Ash]’ (21, my emphasis) while later in the report
mention is made of studies into ways of reducing
soil disturbance (p.26). Why is it that problems such
as weed infestation are not even considered in this section?
Why is it that the release of carbon into the atmosphere
is not mentioned in relation to soil disturbance?
Clearfell logging is regarded
as the method of choice for improved regeneration: "..the
clearfelling regeneration system has proved to be an efficient
method that satisfies the requirements for successful
regeneration of Mountain Ash forests..." (20) and
"Shelterwood, group selection, seed-tree and clearfelling
systems are commonly used in the messmate-dominated mixed
species forests of the west region as they provide sufficient
disturbance for consistent and adequate regeneration and
growth" (21). Once again these claims appear to be
thinly veiled attempts to justify commercial goals.
As the report itself states, "...clearfelling
and seedtree systems will continue to be used to harvest
and regenerate Mountain Ash (Campbell 1997a, 1997b), particularly
where timber production is a high priority" (p.25,
my italics). Clearfell logging and seedtree systems are
even regarded as the method of choice for minimising the
impact of Honey Fungus. In sum, clearfell logging is apparently
regarded as a panacea for all ills.
It is obvious from statements such as
these that regeneration projects are not going
to return the forest to anything approaching its original
state. The picture which emerges is of an open stand of
widely spaced trees, of even height awaiting ‘harvesting’
on a rotational basis. Chances are these trees will be
a monoculture because they will be simpler and more ‘productive’
The methods of silviculture outlined
in this report do not reproduce a forest, but creates
an artificial crop which will have negative impacts upon
the natural aesthetic, biodiversity and carbon values
of the forest.
At the same time there is an admission
that "Whilst clearfelling is an operationally efficient
silvicultural system, and was seen to meet the biological
requirements for successful regeneration, the appropriateness
of the system in terms of its ability to meet other criteria
has been questioned" (p.25).
Why haven’t these ‘other’ criteria been
listed in this report? Why have no viable alternatives
to clearfelling been flagged? Where is the local and international
data of the impacts of clearfell logging upon biodiversity,
soil erosion and water values?
Monitoring and Review
Our members have participated in a number
of consultations so far, and we would like to express
our concern on their behalf about the possibility of DNRE
staff overseeing the monitoring and review of procedures.
While staff from the Department of Prime Minister and
Cabinet and other departments have been helpful and professional
throughout the consultations we have attended so far,
we have found that a number of DNRE staff have been antagonistic
with regard to community input. We question the ability
of DNRE staff to undertake an auditing role when they
are so closely aligned with the Forest Industry. Our concerns
are borne out by data on p.50, Table 5.5. which indicates
that 33 people in DNRE are considered to be integral to
‘Total forestry and wood-based industry employment’. This
amounts to 33 people who are reliant upon the commercial
exploitation of the forests for their own livelihoods.
How can they possibly maintain their independence? We
strenuously object to DNRE staff undertaking this auditing
Forest Extent and Merchantability
We note the statement that, "Victorian
Government policy for native forest timber production
is geared towards sawlog production and value adding"
(34). If this is the case then the industry is already
contravening government policy in the Otways, given that
sawlog production is running at a loss and only the continuation
of woodchipping and subsidies allows the industry to maintain
Legislative, Policy and Planning Framework
for Sustainable Yield
Of great concern is the production driven
definition of sustainable yield expressed in the CRA(1).
"Sustainable yield, as the term applies in Victoria,
is the annual rate of hardwood sawlog production that
can be achieved from the forest, taking into account the
structure and condition of the forest, without impairing
the long-term productivity of the land" (35). This
is further clarified with a note to the effect that one
of the objectives is to "provide the highest yield
available (on a sustainable basis)", and once again,
to achieve "a balanced age class distribution throughout
the forest". These are definitions of sustainability
which would cause shock and dismay to members of the public
who care about the biodiversity values of the forests.
This definition is a licence to decimate the natural values
of the forest. It is not until later on the same page
that there is even an attempt to round out the definition
with reference to calculating sustainable yield "using
an integrated process that considers wood production in
the context of other forest values" (35). There is
no attempt, whatsoever, to integrate this definition with
any of the concepts raised in Chapter 16 "Ecologically
Sustainable Forest Management". We object to the
shift from conservative management practices to those
which attempt to maximise production over a given area
(see p.36). We note that Principle 9 of the ESFM practice
argues that we "Utilise the precautionary principle
for prevention of environmental degradation" (p.215).
Note that more tabular data would be
appreciated for this section to facilitate comparison.
Regarding the document, in general, it would be good to
have a glossary of terms and acronyms.
Strategic Forecast of Sustainable Sawlog
"The SFRI will map around 3.5 million
ha of State forest, with sampling of productive regrowth,
mature and over-mature forests to determine the standing
volume of sawlogs" (39). Will other forest values
be included in this inventory? Will this be undertaken
by DNRE staff or consultants?
"These plans provide for sustainable
timber production, plus the protection of environmental
values in State forests, and incorporate input from the
community" (42) (my emphasis). Once again, it cannot
be restated often enough that the language of this CRA
is biased against values other than timber production.
Sustainability and environmental values - let alone other
forest values -are added in as afterthoughts in many places
throughout the document.
The employment figures and monetary values
stated in tables 5.5 and 5.6 are expressed in a misleading
way, and should be tabularised with the following sections:
A breakdown for the three discrete forested
areas represented in the West RFA.
Differentiation between softwood and
Why is there no mention of the Structural
Adjustment money which can be used to find timber workers
Note contradiction between the following
two claims: 1) "For the region as a whole, the total
sustainable yield (see Chapter 4) has in effect been fully
allocated, with regional licensed allocations (Table 5.2)
closely matching the sustainable yield estimates. Therefore,
there is little scope for expansion..." (46,
my emphasis). 2) "...the Asia-Pacific region is likely
to be the main market focus for any expansion of
Australia’s forest product industries" (57, my emphasis).
It is ironic that the first five chapters
of the CRA are dedicated to treating our forests as a
marketable commodity, and then suddenly the tone shifts
in chapter five where there is evidence presented that
planting of timber is important to "...rehabilitate
agricultural land, to improve water quality, and
to meet other environmental, economic and aesthetic objectives"
(68). Further, it is stated that the Replanting Victoria
2020 ‘Carbon Cropping’ project will contribute to "...improved
catchments through supporting strategic revegetation"
(73, my emphasis). In Chapter 16, under Ecologically Sustainable
Forest Management Assessment Criteria, it is stated that
"Forests contribute significantly to the maintenance
and conservation of the soil resource; they afford water
catchment protection, and maintain the quality and quantity
of water" (214, my emphasis).
The importance of water values to the
Geelong community cannot be overstated, and some of the
scientific data which supports an end to clearfell logging
in our water catchments will be presented later in this
Alternative Pulp Production
We urge the committee to include information
about alternative forms of pulp production and their economic
and environmental viability, such as hemp plantations.
We urge the committee to include more
information about the value of carbon credits in the RFA
process. Please note the following newspaper articles,
which we are attaching:
The Australian Financial Review,
August 27 1999. A Japanese company pays $3million to NSW
to plant 1,000 hectares of trees.
The Australian Financial Review,
August 31, 1999. Carbon trading market expected to reach
$7.9 billion dollars in the next few years.
TWO - Cameron
It is our submission that the body of
evidence illustrating a direct link between the practice
of clearfelled logging in Mountain Ash forests in water
catchments and the resulting diminution of water yield
is so overwhelming that it should be halted immediately.
The Geelong region obtains most of its
water from the Otway ranges but has been subjected to
ongoing water restrictions, catchment levies, and blue/green
algae blooms in the last few years. Whilst acknowledging
the current climatic conditions we at the Forum find it
incomprehensible that clearfelled logging is permitted
in our watercatchments and contributing to the serious
water problems we as a community are facing. The issue
of water sustainability for the growth of our region can
not be underestimated.
The ‘Kuczera Curve’ (Kuczera 1985)
explains the relationship between mean annual stream flow
and forest age. The implication presented by this model
is that every mountain ash coupe logged in a catchment
for the last 150 years continues to contribute to water
yield loss or, if an area previously logged was then protected,
water yield would continue to increase for 150 years.
It is also indicted that an eighty year rotation would
result in approximately a 35% reduction in yield from
In the same year the Kuczera study was
produced (1985) a report was prepared for Gutteridge Haskins
and Davey Pty Ltd by P.F.Clinnick through the Department
of Conservation Forests and Lands. Titled "Determinants
of Water Quality and Aspects of Water Production in the
Upper Barwon Catchment System" the report looked
at the comparative economic, social and environmental
costs of timber and water production. Using the studies
detailing the effects of forest operations done by the
Melbourne and Metropolitan Board of Works (MMBW) (Langford
and O’Shaughnessy 1980) Clinnick found that from the
site profiled "the value of water is almost twice
the value of timber". Clinnick also found "an
increase in rotation age to 150 years would result in
a 25% reduction in the potential stream flow compared
with a 35% reduction for an 80 year rotation.". At
the top of a list of options resulting from these findings
Clinnick placed "cease timber production" stating
"water yield will be maximised as the forest continues
to mature". The last option presented was to "continue
at proposed cutting levels" which "may mean
that opportunities for increasing water yield and net
revenue may be foregone."
A Water Victoria study on "The effect
of timber harvesting operations on Streamflows in the
Otway Ranges" by Rae Moran (1988) did far more extensive
modeling of the implications of the Kuczera Curve in the
Otway region. Moran noted that "forest management
activities affecting the age composition and/or density
of the forest stand can produce impacts on streamflow
yields that are of significance for a water supply point
of view". Explaining that 57% of the catchment area
is used for hardwood production Moran states the bulk
of the sawlog allocation for the Otways "is drawn
from high site quality mountain ash forests". These
areas are of "particular importance from a water
supply point of view as they will generate a large proportion
of total streamflow" and "it is estimated that
the 53% of the catchment area that is under mountain ash
forest generates 70 - 80% of Melbourne’s water supply".
Moran established that while the MMBW
(where the Kuczera study was done) and Otway sites were
comparable for climatic conditions, the "major difference
between the two environments that is likely to be of significance
for model application is that of soil depth". The
MMBW catchments have 10 - 15 metre soil depth while the
Otway depths were in the order of 3 metres. This has implications
for the base flow component of total streamflows. It was
this and other issues that lead to Moran concluding
"direct transposition of the MMBW
model to the Otway environment would result in ‘upper
limit’ estimates of the changes in yield...i.e... smaller
than those predicted using the MMBW model". She further
concludes that in the two Otway catchments examined "the
maximum likely impact of timber harvesting activities
on catchment streamflows is a reduction of around 20%".
There are some cautionary aspects to
note regarding Moran’s study. Soil compaction from clearfelled
logging operations retards soil absorption regardless
of soil depth. Also later studies have highlighted the
importance of soil/litter evaporation estimating that
it "accounts for 10-11% of annual evapotranspiration
in mountain ash forests" (Industry Report from the
Cooperative Research Centre for Catchment hydrology).
This is also independent of soil depth.
Because of the differences in the results
of the two Otway catchments studied Moran states, "It
is therefore important that different catchments be treated
on their individual merits in planning timber harvesting
treatments, if management of flows for water supply (or
environmental) purposes is important.". If indeed!
For the Geelong community water management is of extreme
importance. It appears a common thread runs through the
literature and regulation regarding timber harvesting
and water, the overwhelming focus on quality rather than
quantity. The Comprehensive Regional Assessment document
is a case in point.
We feel the RFA process should be able
to produce an economic evaluation of water versus timber
production. If this could be done in 1985 then the availability
of far more extensive data and modeling should present
an accurate cost/benefit analysis of both forest uses.
We feel that the general public are not
prepared to tolerate even a 5% reduction in water yield
through clearfelled logging. Calling for further studies
to be carried out before action is initiated is unacceptable,
primarily since the evidence already so damning. Any delay
in ceasing this practice in our catchment areas will only
intensify public discontent. The Geelong Community Forum
is committed to continue raising this issue in public
meetings and through the media.