27/10/99

This submission has been written on behalf of the Geelong Community Forum by Serena O’Meley (Section One) and Cameron Steele (Section Two)

SECTION ONE - Serena O’Meley

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 outset.

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 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.

"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 table 2.1.

"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 timber sources.

"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.

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’ to manage.

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).

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 role.

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 profitability.

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.

"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 hardwood figures.

Why is there no mention of the Structural Adjustment money which can be used to find timber workers alternative employment?

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 document.

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.

SECTION TWO - Cameron Steele