From Julie Constable To Mr. John Thwaites,Member for Albert Park and Minister for Sustainability and the Environment 281 Coventry Street, South Melbourne 3205 re: Strzelecki Forests and Labor Government Commitments sent Jan. 10 2003

Dear John Thwaites,

Congratulations on your new position as Minister for Sustainability and the Environment.

It is likely, that by now that you have been briefed by the Department on the Strzelecki forest issues. I hope you will find the following summary useful and look forward to some constructive discussions and ultimate satisfactory resolution to the conservation crisis in the Strzelecki Ranges.

Kim Devenish and myself have been involved in a campaign which opposed the privatisation of the Strzelecki State Forest and has asked for a large reserve to be established in the Strzelecki Ranges. Along with Alan Standering, we wrote A Proposal for a 30,000 hectare National Park in the Strzelecki State Forest , which is supported by a petition of 7,000 signatures tabled in the Victorian Parliament in late 1998 by Ms. Susan Davies. We are both currently on the Strzelecki Working Group initiated by the South Gippsland Shire in response to community concerns in the Strzeleckis. The group also includes representatives from South Gippsland Conservation Society, Friends of Gippsland Bush, Wellington, Latrobe and South Gippsland Shires, West Gippsland Catchment Management Authority, Department of Natural Resources and Environment, Hancocks Victorian Plantions (now Grand Ridge Plantations) and Trust for Nature. Kim Devenish is also currently serving as a board member on the West Gippsland Catchment Management Authority.

From the middle of 1997, the communities in and around the Strzeleckisstarted to become aware that the Strzelecki State Forest had been placed under the managment of the Victorian Plantations Corporation . This change had occurred without environmental impact studies or public consultation. Opposition to this change of management and an impending privatisation began. A demonstration took place at Spring Street on April 28 1998, which opposed the privatisation of the Strzelecki State Forest, called for a large national park to be established and an investigation into areas which were being misclassified as hardwood plantation. Minister Garbutt and Susan Davies addressed the people of South Gippsland who attended that day, (and thank you for visiting and talking to the people gathered on the steps of Parliament). Thank you as well for opposing the amendment to the Victorian Plantations Corporation Act, the following night, which as you are aware was passed by the Kennett Government and paved the way for the sale. In November 1998, the Kennett Government sold the timber rights in the Strzelecki State Forest to Hancock Victorian Plantations, despite considerable public opposition and Labor party criticism.

In the Strzeleckis and across Victoria, the stateıs pine assets were privatised by this move, however, in the Strzeleckis, 7,000 hectares of hardwood was sold as plantation. This 7,000 hectares included areas of regenerated native forest logging coupes and native forest restoration carried out under the Strzelecki Hardwood Reforestation Scheme . See the attached paper entitled Summary of Evidence Regarding Misclassification of Native forest as Plantation, for a detailed analysis of this issue. Classifying these areas as plantations and removing them from the Forests Act, has sacrificed these areas to be logged every 28 years and to be regenerated with non-indigeneous species for the first time in history.

Furthermore, some 20,000 hectares of native forest in the Strzeleckis was included in the package. This outraged the local communities who rightly felt that they were being dispossessed of their forest and that the conservation significance of the Strzelecki State Forest was being undermined. The strong support for the national park proposal reflects this public concern. Groups supporting the proposal include Society for Growing Australian Plants, the South Gippsland Conservation Society, the Mt. Best Concerned Residents Association, the Latrobe Valley Field Naturalists, Environment Victoria, the Strzelecki Hills Branch ALP, Wonthaggi/Bass Branch ALP, Friends of the Gippsland Bush; Greens Party and the Victorian National Parks Association. Senator Bob Brown has written a letter of support. Professor David Bellamy lent his support to the proposal on his visit to the Strzeleckis, December 1999.

The sense of public alienation was further compounded by the Kennett Government forging ahead with the privatisation in the middle of the Gippsland Regional Forest process. This was despite the Strzelecki State Forest being a Deferred Forest Area at the beginning of the process, and therefore should have remained exempt from timber harvesting pending the outcomes of the RFA. This meant that the Strzelecki State Forest areas leased to Amcor and Hanocks were not available for the Comprehensive, Adequate and Reprsentative reserve systems.

The Labor Party acknowledged these injustices in their pre 1999 election policy document, OurNatural Asset: Valuing Victoriaıs Natural Environment, which stated: 'The Kennett Government has failed to protect remaining native vegetation in the Strzelecki Ranges. It privatised over 20,000 ha. of native vegetation when it sold the Victorian Plantations Corporation to private interests, and failed to enforce the Code of Forest Practice to protect rainforests, streamside vegetation and other native vegetation from logging. 'Labor will: Ensure full protection of all conservation areas in the Strzelecki Ranges Negotiate with private landowners to ensure protection of all significant areas of native forest and strictly enforce the Code of Forest Practice. Refer the Strzelecki Ranges to the Victorian Environmental Assessment Council to examine future opportunities for protection of native forests in the region.'

While the Gippsland RFA seemed unable to change the circumstances forced on the Strzelecki State Forest by the Kennett Government, the Social Assessment report acknowledged that the local community has a vision for a major National Park in the Strzeleckis. Furthermore, after the 1999 election and the formation of Bracks government, Laborıs commitments to the Strzeleckis were confirmed in the Gippsland Regional Forest Agreement Consultation Paper, which stated that, Œa range of concerns have been raised by communities in South Gippsland about the management of native forest and plantations in the Strzeleckis. These relate to the manner of sale of the plantations, the appropriateness of transfer of public native forest management to private companies and the delineation of the extent of plantations in maps published in the Comprehensive Regional Assessment (CRA) for the Gippsland RFA.ı The paper continued, ŒThe Victorian Government has indicated its intention to ensure full protection of all conservation areas in the Strzelecki Ranges and to refer the issues raised about the Strzelecki Ranges to the proposed Environmental Assessment Council to examine future opportunities for protection of native forests in the region. These processes will follow completion of the Gippsland RFAı. (p.28-9) In other words, the Strzeleckis was to have its own mini-RFA type process.

Unfortunately, these issues are not yet resolved. Papers lodged with the Department regarding the misclassification of native forest as plantation have not been addressed; neither has the national park issue progressed. I hope this may be lack of communication rather than lack of planning and action at governmental and departmental level.

A setback occurred under Minister Garbutt, when the Upper House ammended the Victorian Environment Assessment Council legislation so that private land was excluded. Given that the leased areas in the Strzeleckis were being treated as if private, this interfered with the referral process. However, Minister Garbutt instructed the Department to Œprovide advice on alternative approachesı in July 2001. (Letter from Gerard OıNeill, Executive Director, Forests Service, 13 July 2001). Kim Devenish and myself have not received any further notification of these alternative approaches for resolving the Strzelecki issues .

In December 1999, the Strzelecki Working Group commissioned Biosis Research to undertake an independent biological study of the Hancock leasehold and make recommendations to assist the conservation of biodiversity. The Strzelecki Ranges Biodiversity Study was funded by the Shires of South Gippsland and Latrobe City, the West Gippsland Catchment Management Authority and Hancocks. The report identified five Core Areas of high conservation value and two habitat links, recommending that Core and Link areas be excluded from timber harvesting. From east to west, the areas identified are Gunyah, Jack River, College Creek, Upper Merrimans Creek and Tarra-Bulga. Part of the Gunyah core area is a rainforest reserve containing nationally significant Cool Temperate Rainforest; the Tarra Bulga area is a small national park. The report found 15 fauna species and 12 flora species of national or state significance. In the absence of any released environmental assessments by the department , this largely community funded study is the most current and pertinent reference document. Flora and Fauna have found that the report is a Œfair and reasonable assessment of the available information on biodiversity assets in the area and makes valid recommendations for retention and management of areas of high biodiversity value in the HVP estateı.(Letter from Ken King, Executive Director, Forests Service, to Strzelecki Working Group, 3/12/02).

Based on this study, the Strzelecki Working Group, in full agreement, wrote to the Minister, January 31, 2002 saying, Œthe Working Group sees the establishment of the Core and Link areas as a permanent reserve as an urgent priority and requests the assistance of the State Government in the speedy implementation of this reserve, in line with the Stateıs Governmentıs commitment to full protection of all conservation areas in the Strzelecki Rangesı. The proposal recommends approximately 8,700 hectares be added to the reserve system. . The proposal links the Gunyah forest with the Tarra Bulga National Park providing a linked reserve through the Eastern Strzeleckis. It provides for the formal reservation of further Cool Temperate Rainforest, including a nationally significant site at College Creek and sites of botanical significance at Gunyah and Rytons. Protection of the cores and links will also serve to protect the headwaters of catchments , including the Franklin River, Agnes River, Dingo Creek, Albert River, College Creek and Middle Creek.

Government intervention is crucial to the resolution of these issues. Hancocks, as part of the Strzelecki Working Group have agreed that the area be made a reserve, but this is contingent on the timber licences in these areas being bought back by the Government.

Minister Garbutt commended the Working Groupıs proposals in a letter, dated April 17, 2002 and stated, ŒI note your reference to the State Governmentıs commitment to protect conservation areas in the Strzelecki Ranges and I am considering how this might now best be done in light of completion of the Study and other related developmentsı.

There is no doubt that Government intervention is necessary to protect biodiversity in the Strzelecki Ranges. Less than 2% of the Strzelecki Ranges Bioregion is protected in reserves. This problem in confirmed in the Draft West Gippsland Native Vegetation Plan and the Nature Conservation Review 2001. The Nature Conservation Review (Porter/Traill), funded by the Victorian National Parks Association identified gaps in Victoriaıs reserve system. The Review acknowledges the lack of reserves in the Strzeleckis: "...the wetter forests of the Strzelecki Ranges Bioregion stand out as a forested bioregion requiring special attention due to the high level of threatened Ecological Vegetation Classes and very poor reservation.² (p.107) The report recommends 'a major new park system be established to conserve the biodiversity of the Strzelecki Ranges'. The reserve targets recommended in this report total 16% of the bioregion, 45,000 hectares more than is presently reserved. Please see the attached document Strzelecki Ranges Bioregion, for an overview of the region.

Prior to the recent state election, November 2002, a coalition of Victoriaıs peak environment groups released an environmental policy for Victoria. In regard to biodiversity, the implementation of the proposal for a major reserve system, as recommended in the Nature Conservation Review, in the Strzelecki Ranges and the South west forests was made a priority.

The Strzelecki Working Group reserve proposal is supported by many community and environmental groups, including: Mount Best Concerned Residents, South Gippsland Conservation Society, Friends of the Gippsland Bush, Victorian National Parks Association, Friends of the Earth, Wilderness Society, Prom Coast Tourism, Field Naturalist Club of Victoria, Environment Victoria, Gippsland Local Government Network, Strzelecki Hills Branch ALP and Hancock Victorian Plantations, Australian Greens (Victoria); Brendan Jenkins, Member for Morwell. Mr. Jenkins in the lead up to the November 2002 election promised to Œhelp Hancockıs and working group work with a future Labor Government to protect those areas identified in the groupıs proposalı. (Latrobe Valley Express, 25/11/02).

Governmental assistance in the establishment of this reserve will lay a foundation for the maintenance and enhancement of biodiversity in the Strzelecki Ranges bioregion; protect the headwaters of major rivers and streams in the Eastern Strzeleckis, and alleviate the grief suffered by the Strzelecki communities and wider Victorian public when this beautiful state forest was quasi-privatised. The proposal has scientific, industry and community backing. The permanent reservation of these high biodiversity areas will then allow for a process to be implemented to examine further conservation measures in the Strzelecki forests in a calm and open manner. Further delays will have serious consequences for the Strzeleckis , with so much young biodiverse forest designated for intensive plantation use in a forest which is depleted and under reserved .

Kim Devenish and myself met with Minister Garbutt and her advisers on February 9, 2000 followed by a further meeting with Mr. OıNeill, Executive Director of Forests on September 11, 2000. Kim Devenish, myself and Councillor David Lewis, Chair of the Strzelecki Working Group would appreciate a further meeting, to discuss with you, developments in the progress of these Strzelecki forest issues andoptions which may be available for a speedy and satisfactory resolution. We also invite you to visit the forest with us in order to see some of the areas in need of protection and to confirm the Governmentıs continued commitment to the Strzelecki forest.

Yours sincerely Julie Constable

c.c. Mr. Steve Bracks, Mr. John Brumby, Mr. Brendan Jenkins, Environment Victoria,


The following 3 letters we have sent to various politicians and public servants some time ago.


September 6, 1997
re:  The Strzelecki State Forest and the Victorian Plantations Corporation

Dear ....,

I am a resident of South Gippsland and am very concerned about about the future of the Strzelecki State Forest.
This 50,000 hectare State Forest is already over-utilized and has been for 100 years.  Amcor lease about 16% of the Strzelecki State Forest for timber production and DNRE has converted a further 26% to softwood plantations and at least 10% to hardwood plantations. Timber from the native forest is also used as a timber resource.  This means that the utilisation of the Strzelecki State Forest for timber production has been way above the State average of 14%.  Now it seems the State Government has changed the management of  40,000 hectares of the Strzelecki State Forest, by vesting it in the Victorian Plantations Corporation.  By an alteration to the Forest Code of Practice in 1996, this land is to be treated under the private section of the code.  This means that about two thirds of the Strzelecki State Forest is available for timber production, compromising its 'multiple use' status for habitat, recreation and water catchment values, and at the same time virtually removing this land from the public realm.  Furthermore, significant areas of native forest, including mountain ash and cool temperate rainforest have been vested in this plantation corporation.  During this year,  the Victorian Plantations Corporation have committed widespread breaches of the Forest Code of Practice by removing non-plantation timber, such as 80 year old mountain ash, blackwood and myrtle beech and encroaching on the rainforest.

Therefore I would like to ask you, as Minister for Natural Resources & the Environment of the Victorian State Government the following questions.

1.  Why, in the light of the community and governmental concerns about environmental damage and reduction of habitat has the Victorian State Government changed the status of 40,000 hectares of public State Forest in the Strzelecki Ranges, so that it may be treated as 'private' land, thus relaxing the protective guidelines that were in place for the safeguarding of its native flora and fauna?

2.  Why has the Victorian State Government passed legislation to vest approximately 40,000 hectares of the Strzelecki State Forest in the Victorian Plantations Corporation before the region has undergone a Comprehensive Regional Assessment in preparation for a Regional Forest Agreement?  This process would involve Commonwealth and State levels of government and public consultation.

3.  Does the State Government realise that not all the land vested in the Victorian Plantations Corporation is plantation?  Much of the area is wet sclerophyll forest connecting cool temperate rainforest gullies. In the Gunyah and Ryton region, to give you one example, a 2250 hectares in the vicinity of the Gunyah Gunyah Rainforest Reserve (which contains cool, temperate rainforest of national significance - Flora and Fauna Survey and Management Group Rainforest Project Team, March 1990) were described as sites of botanical state significance by CF&L in 1984, and contain old growth remnants, mountain ash regrowth from 1914 and cool temperate rainforest of regional significance.  How can the State Government justify vesting areas like this in the Victorian Plantations Corporation?

4.  On account of the widespread breaches of the Forest Code of Practice by the Victorian Plantations Corporation and public disquiet about the removal of the Strzelecki State Forest from the public realm, do you agree that all Victorian Plantations Corporation activities in the Strzelecki State Forest be frozen until a review committee can identify environmentally significant and sensitive areas and areas which are not plantation and excise them from the Victorian Plantations Corporation's land package and ascertain whether the Victorian Plantations Corporation are suitable managers of this valuable forest resource?

If you require more information about the Strzelecki State Forest, its history, land use and tenure, vegetation, DNRE management and the transition of management to the Victorian Plantations Corporation, I have compiled a 30 page report which you are welcome to read.

 Yours sincerely
.....
 

c.c.Marie Tehan; Senator Robert Hill; John Anderson; Pat McNamara; Office of Surveyor-General; DNRE; West Gippsland Water Catchment Authority; Sherryl Garbutt; Conservation Council of Victoria; South Gippsland Regional Water Authority; Susan Davies; Peter Western (President of South Gippsland Shire Council); Peter Ryan (MLA); Philip Davis (MLC).
 
 

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April 15 1998
 

re:  Timber harvesting within a Deferred Forest Area in the Strzelecki State Forest

Dear ....,

We are writing to inform you that all the following logging  coupes lie within the deferred forest area in the Strzelecki State Forest.  All coupes have been harvested since the DFA's were created and some coupes are continuing to be harvested by the Victorian Plantations Corporation.

1.  Redhill Track (off the Toora-Gunyah Road) 2.  Stronichs Road (off the Toora-Gunyah Road)
3.  Evans Track (off the Toora-Gunyah Road)  4.  No name track (off the Toora-Gunyah Road)
5.  No name track (off the Toora-Gunyah Road) 6.  Lewis Track (off the Grand Ridge Road)
7.  Contorta Track  (off the Grand Ridge Road) 8.  Hatchery Road (off the Grand Ridge Road)
9.  Jacksons Track (off the Grand Ridge Road) 10.  Johnsons Hill vicinity (off Midland Highway)
11.  English's Corner (off the Midland Highway)
All these locations are within a 10 km radius of 38¡ 31' South, 146¡ 20'East.

A Federal Government media release from 1995 clearly states that the Deferred Forest Areas "will ensure that these forest areas are not logged while complete assessments are undertaken to finally determine the reserve system' (Senator John Faulkner & David Beddall, 1 December 1995).  The Regional Forest Agreement process for the Gippsland region has barely begun.

Not only is this logging activity pre-empting the outcomes of the Regional Forest Agreement process for Gippsland, which is supposed to provide certainty for both conservation and industry interests, but the Victorian Plantations Corporation have also clearfelled part of the Gunyah Gunyah Rainforest Reserve and they operate under the least stringent environmental guidelines in the State - the private section of the Forest Code of Practice  - even though they are operating on public land.  The VPC are also exempt for the usual requirement of lodging Wood Utilisation Plans and have not applied for permits to clear native vegetation from local planning authorities.

The strategic value of the Strzelecki State Forest to the South and Central Gippsland region in relation to water production, biodiversity, tourism and recreation is being compromised by current management practices.  The area given interim protection in the DFA is surrounded either by land given over to the timber industry's needs or agricultural land.  Only 8% of the Strzelecki State Forest is protected in reserves. The need for this deferred area to be reserved for habitat, water production, and biodiversity is paramount.  Amcor,  lease 8% of the Strzelecki State Forest for timber production and the VPC have 13,000 hectares of pine to play with without annoying the public by harvesting in the deferred forest area.

As Victoria's first "State owned Enterprise", the VPC is something of a test case, yet the behaviour of the VPC in Gippsland is shattering hopes for good public relations.  Local newspapers not known for their strong political stances have been running headlines such as "Logging action unpopular", "Look what's happening to our Forest" and "Fear or favour in VPC sell off?"

The State Government's announcement that the VPC and its vested land is to be privatised this year also pre-empts and runs contrary to the public spirited Regional Forest Agreement process.  We would welcome assurances that this matter will be dealt with urgently.

Yours sincerely

..............

c.c. Marie Tehan; Robert Hill; John Anderson; Pat McNamara; Office of Surveyor-General; ; West Gippsland Water Catchment Authority; Sherryl Garbutt; Environment Victoria; South Gippsland Regional Water Authority; Susan Davies; Shire of South Gippsland; Wellington Shire; LaTrobe Shire; Peter Hall;  Peter Ryan (MLA); Philip Davis (MLC); Richard Rawson; Rob Maclellan; Alan Stockdale; Paul Marsh; Ian Myles; Peter McGauran; ACF; Jeff Kennett; Kevin White; Ian Hemphill; Gary Squires; John Faulkner; David Bedall; John Howard; Tim Fisher; Environment Defenders Office; South Gippsland Conservation Society; Friends of the Gippsland Bush; VNPA; Wilderness Society; Friends of the Earth; The Age; The Australian; Bob Brown;
 

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May 26 1998

To the Honourable Marie Tehan
Minister for Conservation and Land Management
8 Nicholson Street
East Melbourne 3002

Dear Mrs Tehan,

We refer to your letter of April 24 1998 regarding the Strzelecki Ranges, the Deferred Forest Areas and the Regional Forest Agreements.

In 1995, approximately 25,000 ha. of forest in the Eastern Strzelecki Ranges was included in the Deferred Forest Area for Gippsland.  This map, still the current one in circulation excludes the softwood plantation areas established mainly on the lower slopes of the area, which also contain native forest within and between pine plantations.  Possibly about two thirds of the softwood zone is plantation area.  The area which was included in the DFA for Gippsland in the Strzeleckis is very similar to the area indicated by the LCC as being a hardwood production zone, in general terms.  This area of approximately 24,000 ha. contains around 6,000 ha. of land which has received some form of reforestation, natural and assisted.  Reforestation as the LCC reiterates was implemented to restore the original structure of the forest and in no way were reforested areas exempted from the 'multiple use' guidelines or to be treated as a crop.  It is important to remember that only half of this State Forest was repurchased farmland and that natural regeneration began before reforestation and half a century before plantations were established in the area.

 In 1996 when Jeff Kennett and Paul Keating changed the terms of the Interim Forest Agreement as stated in your letter, the mapping and surveying of vegetation classes in the Gippsland Region was far from complete.  During 1997, the Warragul NRE were still completing maps of vegetation types, and Philip Davis informs me that that the VPC are conducting plantation boundary surveys.  At the Foster Agricultural Show in March, the VPC presented a map to the public which coloured in their land holdings as either softwood or hardwood plantation, a patently false and simplistic view of this State Forest.  Philip Davis refers to the 'fragmented nature of the native vegetation within the VPC  vested land'. While this may be true of the softwood zone around the fringes of the State Forest, it is a complete misrepresentation of what is to be found in the hardwood zone, where 'planted trees' are native species and scattered in amongst continuous native bush.

 In your letter you say that Deferred Forest areas 'exclude areas identified as plantations, including those areas vested in the VPC in the Strzelecki Ranges'.  As only a small proportion of this area is plantation,  it is vitally important that the area be reinstated as part of the DFA.  To exclude this area before mapping and surveying is a terrible injustice to this significant forest.  Perhaps the problem lies in the initial vesting process which was performed too hastily and with little regard to terrain, public rights, habitat and vegetation classes.  The Government has abrogated its responsibility for the Strzelecki State Forest by vesting it in the VPC, allowing it to be treated as 'private' land, and removing it from the DFA's interim protection.

The Strzelecki State Forest, in South Gippsland, is an extremely steep, wet, misty and lush place, where the giant mountain ash forest casts a perpetual dappled shadow over the deep rainforest gullies shimmering with ferns and moss.  As a forest community it has much in common with the cool, mountainous forests of Tasmania - a great rarity here on the mainland. Great stands of blackwood, wattle and messmate add to the rich mosaic.  This forest forms the last public tract of the Great Gippsland Forest, which once stretched almost to Westernport Bay.

It is home to mammals such as echidnas, platypus, koalas, wombats, two species of antechinis, the black wallaby, two species of bandicoot, gliders, possums, native rats and bats, potoroos, as well as the the rare tiger quoll,. The giant earthworm, confined to this region alone, is also on the threatened list; 80 species of bird including the threatened barking owl, the powerful owl, sooty owl, and the grey goshawk; and native fish such as the spotted galaxis, striped gudgeon and the threatened grayling. Over one thousand vascular plants have been identified in the Strzeleckis, including no fewer than 10 varieties listed as rare and threatened. The entire cool temperate rainforest community such as can be found in the Strzeleckis (rated among the 4 top rainforest sites in the state), is on the threatened list of the State's Flora and Fauna Guarantee. In the Strzeleckis this community includes myrtle beech, sassafras, the rough, the smooth and the slender tree fern, hazel pomaderris, mountain correa, musk daisy bush, blanket leaf, a host of epiphytes and small ferns, including the rare forked fern.   South Gippsland was once called 'The Land of the Lyrebird' due to the sheer abundance of these wonderful songbirds. The Eastern Strzelecki bush has become its refuge.  (underlined = listed as threatened)

Why is the Government even considering giving this land away?   To privatise the State owned section of the last of the Great Gippsland Forest on account of a mere 4,600 -7,400 ha. of hardwood plantation is an absurd notion .  This action forecloses public options to expand reserves, make viable ecological areas, preserve heritage values etc. now and in the future.  The South Gippsland Council in its Planning Scheme, states that, 'public land provides for a wide variety of activities and land uses including outdoor recreation and areas of natural ecosystems hosting wildlife habitat and remnant vegetation.  Mismanagement of public land can affect a broad range of qualities from tourism to the health of the natural ecosystems. (15.1).  It also says, 'smaller reserves are at risk from deterioration, some of which are the only known sites of original remnant vegetation,' and that 'the isolation of these large blocks of vegetation from one another is an issue.'  If the Government wishes to exclude VPC land from the DFA and RFA, then it must be certain about which land is vested.

Looking at the DFA map, 24 November 1995, it is easy to see the special significance of the Strzelecki State Forest in a local context.  The Central Highlands is a separate geographical entity and cannot be tied to the Strzeleckis in terms of geographic representation of vegetation types.    The Western Strzeleckis are privately owned and  contain little public forest.  The Eastern Strzelecki bush is of importance for habitat, heritage, water quality and production.  This area is vital to the spirit of the CAR process, which suggests that at a minimum, 15% of pre 1750 forest cover should be reserved across the forest's geographic range.

Some politicians and Forestry spokespeople have argued that the native forest is contained within gullies and will not be logged.  However, the Strzelecki forest also covers ridges and slopes and this argument does not address the issues of public access, extension of reserves etc.  Furthermore, no one has addressed the problems associated with treating the Strzelecki State Forest as 'private' land.  This means that licensees are able to manage the forest under the private section of the Forest Code of Practice, which has far less stringent environmental safeguards.

 We refer again to the native forest west of the Toora Gunyah Road between Franklin Road and Stronachs Road and north of the Gunyah Gunyah Rainforest Reserve in the Hatchery Road, Morwell West Branch vicinity.  This vast tract of public native forest, 1914 mountain ash regrowth and  remnant old growth has been logged heavily in the past 18 months. Hundreds of hectares have been clearfelled, removing mature and oldgrowth and young mountain ash (from previous NRE native forest logging coupes, which under the public section of the Forest Code would not be available for harvesting for at least 80 years).  This area of the Strzelecki State Forest was described in a C,F&L document, 'Sites of Botanical Significance in Central Gippsland' as being of State significance because of its undisturbed wet sclerophyll forest.   South of the reserve, the rainforest understorey was dominated by myrtle beech.  This section was clearfelled and transformed into 'plantation' by the planting of non-endemic shining gum only last year.    This is an action clearly prohibited under the public section of the Forest Code of Practice, which states that no native forest may be removed and replaced with plantation.  Under rules applying to 'private' land, the owner would have to acquire a planning permit to remove this vegetation.  The VPC did not do that either.  In Parliament there has been a reference to only 4 hectares of native forest being felled.  This is an understatement.  These actions have not inspired public confidence in VPC management, the vesting process or the legislation.  Plantations were only established in the Strzeleckis from the late 1940s.  Why were these areas vested at all?  When will these shining gum be removed and native bush regenerated?  Is this area now considered part of the VPC's plantation estate?

The vesting of this land has already worried the community.  The land vested is now treated as private, which has seen actions like that described above occur.  Did the Government really desire outcomes like this as a result of the legislation?  By calling an area 'private' or a 'plantation', the removal of native bush and the establishment of plantation is permissible.  It also means that instead of the average 100 year rotation rate for areas where timber harvesting is permitted, land may be cleared numerous times per century. There is no need for public participation in allocation of public land for various uses. Under the public section of the Forest Code of Practice, there are guidelines about wildlife corridors, retention of habitat trees, the regeneration of bush with local species, provision for protection of flora and fauna listed as threatened under the Flora and Fauna Guarantee, and meet sustainable yield requirements.  Under the private section, there are no guidelines, only 'encouragements' for these practices.  It seems that the VPC did not feel any qualms about transforming the site of botanical significance west of the Toora-Gunyah Road into plantation.  This is a threatening action for flora and fauna.  The age structure of the forest has been changed and the species changed.  The integrity of the Gunyah Gunyah Rainforest Reserve is compromised.  The Government has withdrawn the protection of the public section of the Forest Code of Practice from the native forest areas it has vested in the Victorian Plantations Corporation.

You mention that the Gunyah Gunyah Rainforest Reserve remains intact.  According to a map available from NRE, Traralgon, the border is clearly Stronachs Road, and harvesting has occurred north of this road into the reserve.

The LCC did not recommend that this area be used as plantation.  The report  on South Gippsland Area 2, says that the area is very good for hardwood production, but it was always seen as a public, multiple use area.  The LCC recommended a balance in the use of this public land seeing a return of a similar structure to the original forest as desirable for restoration of  options in land use.   The report recommended that the present legal status and land tenure continue.  It recognised the significance of the remnant vegetation in the headwaters of Dingo Creek, the Franklin and the Agnes Rivers, and the importance of water quality and production in these watersheds.  The Government's actions in vesting this land in the Victorian Plantations Corporation and its move to privatise run contrary to these LCC recommendations.  The timber industry will not allow the forest to grow old and fulfil all its functions.  The forest will be kept young by high rotation harvest rates, which is devastating for the wildlife, which nest in hollows, feed  on nectar and seeds from mature trees or rely on a deep forest litter in which to find food.  Young trees are also thirstier and high rotations will have a serious effect on water flow in this steep mountain range.

The LCC Report also stated that their 'knowledge of the distribution and ecology of plants was very imperfect' and that areas where special values  may be unrecognised. Indeed, since 1982 other areas of botanical significance have been documented.  In 1984, a C,F& L report, 'Sites of botanical Significance in Central Gippsland', identified 400 ha. at Rytons and  2500 hectares in the Gunyah region as being of State significance for its undisturbed wet sclerophyll forest and cool temperate rainforest.  In 1990 after further study of the area, the Gunyah region, along with Paradise Valley at Wilsons Promontory was recognised as of national significance.    Despite all this, the amount reserved is a mere 650 hectares and the surrounding area has been vested in the Victorian Plantations Corporation.  Many other areas of the Strzeleckis are awaiting full botanical study and identification.  Only two weeks ago the rare forked fern, tmesipteris elongata was identified in the Agnes Catchment, in an extensive cool temperate rainforest area. Some areas in the Agnes Catchment headwaters are rainforest areas  dominated by blackwood.  There is concern that areas such as these are being classed as 'pure scrub'  or 'understorey species which could be reforested' , rather than as native forest.

It is imperative that more of the Eastern Strzeleckis are protected in a reserve system. Despite any possible outcomes of the RFA process it is evident that the Strzelecki State Forest needs a better reserve system.  Only 8% is protected is reserves, and about one third, mostly around the fringes,  has been converted to plantation.  The LCC's 'Hardwood Zone', now either vested in the VPC or leased to Amcor, is the key to the areas most in need of protection.  The Zone identifies the most intact, largest and most magnificent single remnant of the Great Forest of Gippsland.  The extensive agriculture of the region and the later establishment of plantation forestry has left this remnant isolated.  Locals are aware of the history of the region and there is a strong community feeling that we cleared the forest too much.

  Intensive plantation forestry is not compatible with other forest uses, especially when the majority of it is pine.  Even eucalypt plantations on high rotations are not suitable for most species to live in.   It would be possible to fulfil other land use objectives by reserving these watersheds to act as a viable ecological parcel, which would link the isolated reserves of Turtons Creek, Gunyah and Tarra Bulga.  This would allow the forest to grow older and fulfil commitments by the Government and Shires and Catchment Authorities to regional biodiversity, by providing habitat for the wildlife.  At the same time this would provide scenery for tourism and recreation potential  and the health of the catchments would be secure.  The older Mountain Ash gather the rain and  the undisturbed, forest is the cheapest way to ensure water quality and regulation of stream flow.  The same LCC report says, 'It must be recognised that the higher the original quality of the water, the cheaper and more efficient is the treatment.  In many catchments it is already difficult to maintain existing water quality.  Catchments must be protected from loss of infiltration capacity, damage to other hydrologic properties, soil erosion, and contamination from chemical or biological sources.  Values such as water yield, quality and flow regime must be of major concern when implementing recommendations for public land within catchments.' (p.24) Intensive plantation forestry, with its disturbance of the soil at frequent intervals will pose a threat to the integrity of these headwaters and will compromise habitat in an area, which is already heavily biased towards the timber industry.

Alan Stockdale has indicated that he wasn't aware that large areas of native forest were included in the Victorian Plantations Corporation's land holdings and acknowledged that more areas could be removed.  A small group of locals have been preparing a design for a larger reserve in the Strzelecki State Forest.  Perhaps you as Minister for Conservation could arrange a meeting with us as soon as possible to discuss the idea and facilitate the creation of this reserve.

Thank you

Yours sincerely

..............

c.c.  South Gippsland Shire Council; Alan Stockdale, Treasurer.
 
 

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The first two letters have generated dozens of single paragraph responses and about five or so slightly more in-depth answers.  The third letter has had no reply as of June 10 1998.  Some of these responses will be added to this site in the near future.
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