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 below.

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 industry.

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.

1. Bias.
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 ONLY.

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.

Yours faithfully,

Michael Axtens