West Victoria RFA Independent Panel
PO Box 502
East Melbourne Vic, 3002
Dear Independent Panel
I wish to make a personal submission that the Regional Forest
Agreement (RFA) Consultation Papers prepared by the Department
of Natural Resources and Environment NOT be used as a starting
point for your consideration of the Regional Forest Agreement
on the basis that the document itself is in breach of the
guidelines for the RFA because of reasons of bias and poor
representation of the issues. I will clarify these objections
This submission is based on reading written
information provided by the DNRE, listening to representatives
of DNRE espouse their position, personal attendance of Geelong
Community Forum meetings and discussion groups over the
last 6 months and the reading of information provided by
OREN (PRELIMINARY EVALUATION OF THE COMPREHENSIVE REGIONAL
ASSESSMENT FOR THE WESTERN REGION OF VICTORIA) In this submission
I will avoid the issue of subsidisation of an uneconomic
My context. I am a General Practitioner. I am very interested
in the links between health and the environment, and the
contributions made to our pharmaceuticals derived from the
natural world, which is dependent on maintained biodiversity
of plants and animals. I am a bushwalker. I live in a timber
house. I am a member of Geelong Community Forum. I am not
a member of OREN, but have been impressed by their attention
to the issues around forests as a resource.
The intentions of Regional
Forest Agreements (RFAs are to a balance of all forest values
including tourism, water, recreation, social and historical
interests, timber, mining, apiary and grazing. As it stands
such objectives cannot be balanced as some are clearly mutually
exclusive (eg grazing and timber industry). A clear statement
of hierarchy of values is essential here. If objectives
conflict, which values will be privileged and why? Despite
lack of stating these, it is obvious throughout the Regional
Forest Agreement (RFA) Consultation Papers that timber "harvesting"
(logging, usually clear-felling) has been privileged over
preservation of our forest heritage for recreation, water,
social or tourism uses. This represents a gross unstated
bias. The papers give little attention to tourism, water
quality, and ignore assessment of forests in terms of beauty,
grandeur, biodiversity. Consideration involving words such
as habitat, shelter, conservation, understorey, soil micro-ecology
are noticeably absent or underrepresented. If your panel
wishes to consider what we want to have available to our
descendants in 50 to 100 years, I believe this document
should be grouped with any submissions made by the timber
industry, and a better starting point would be the documents
prepared by OREN.
2. Poor representation of the issues.
The Federal Government on its RFA website has stated..
"All RFAs are based on scientific Comprehensive Regional
Assessments of the environment, heritage, social and economic
uses and values of the forests." To use of the words "scientific"
and "Comprehensive" to describe the Consultation Papers
I believe would be misleading. As an illustration of the
lack of comprehensive consideration of issues raised in
consultation, I would like to point out that in this document
the public's input into the process had been reduced to
a list of over 100 issues, without a single one of these
being addressed specifically. For example, lack of transparency
of the consultation process was listed as one point of concern.
No discussion.. it was just listed as an issue. This, I
believe, is negligence by omission.
The consultation papers misrepresent the
value of forests because they restrict "scientific" discussion
too much to the context of logging. By doing this they misrepresent
the intent of the RFA process, and by giving inadequate
attention to issues such as tourism and water quality, they
misrepresent issues of relevance to the general population
(to whom governments are accountable). Any "scientific"
analysis of the forest situation must include, for example,
due concern to issues of water quality, threats to any species
(eg: the Tiger Quoll) The consultation papers fail to consider
assumptions underlying the scientific discussion (ie; what
are the assumptions about the relative value of an untouched
unlogged forest compared with a clearfelled area?). Where
is the scientific debate about this? It is actually absent.
Science per se is not valueless. Making the triggers for
nuclear weapons may be a scientifically reproducible procedure,
but this does not validate its usefulness to humanity. So
please put aside the consultation papers, and consider the
issues de-novo, using the consultation papers as ONE RESOURCE
Introduce into your consideration information
dealing with issues as biodiversity, wilderness value, scenic
beauty, "forest heritage". You will be doing future Australians
a great favour by basing your considerations on a the human
and environmental value of forests rather than documents
which basically condone woodchipping by "scientific" discussion
in the context of a valueless void.