Comments on the Gippsland CRA As requested by the RFA team, we dutifully read the Gippsland CRA report and presented feedback....
This only makes sense if read in conjunction with the Gippsland CRA report.
Even though the Strzelecki State Forest was exempted from being included in proposed reserves for the RFA, a photograph of the Strzelecki State Forest was used for the cover of the CRA report.
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HVP plantations tally - corrections necessary
Page 36 states that in 1993, Victorian Plantations Corporation inherited 10,700 ha. of plantations including 7416 ha. in the Strzeleckis. This is incorrect. Virtually all of the State's HW "plantations" are in and around the Strzeleckis. There is not 3000 ha of former State owned HW plantations elsewhere. Page 71 states that HVP control 8000 ha. of HW plantations. This concurs with the VPC's 1997 annual report., but this is also incorrect.
The State Plantations Impact Study of 1993 states that the total extent of State HW plantations still in existence throughout Victoria totalled 7151 ha., virtually all of which was in the Strzeleckis. Not all of this was inherited by the VPC. Some are now within reserves and some remain within state forest controlled by DNRE. The total inherited by VPC is more likely to be 6500 ha.
HVP's own HW "plantation" tally in 1999 came to 7023 ha plus 250 ha awaiting restocking. Reports, personal experience and local news all show that many hundreds of hectares of this HW plantation tally were areas converted to plantation since 1993 on land that was native forest immediately prior, or not plantation at all but natural regrowth, and in some cases old growth.
Page 71 states that HVP plantations within the Gippsland RFA total 26000 ha. This is probably an overestimate to the tune of about 1000 ha. or so. HVP net pine plantations within Gippsland RFA would be around 18000 ha., with 6500 ha. of HW reforestation, totalling 24500 ha.
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Hardwood sawlog output Discrepancy:
Page 49 states that 142,616 M3 of sawlogs is sourced from state forest within Gippsland RFA region. The Fact Sheet "jobs and forest based industries" states that the figure is 126,575 m3
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Underestimate of sawlog output in region:
Page 49 states that along with the 142,616 M3 of sawlogs sourced from Gippsland RFA state forests, 5904 m3 is sourced from private forests within Gippsland RFA and 186,014 m3 is sourced from private and public land outside of the region.
This does not seem to take into account the 100,000 M3 of Strzelecki Mountain Ash sawlogs harvested annually by HVP for Planthard. Has this been overlooked, or has it accidentally been classed as being from outside the region, or has it fallen into an invisible category?
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Overestimate of sawn timber output and recovery rate
Page 51 indicates that 142,812 m3 is the total sawn timber output for the region. This is an overestimate to the tune of around 20,000 m3. At least, 19,932 m3 is counted twice due to it being included in both the unseasoned and the seasoned category. The illustration on Page 45 shows this to be the case. This oversight, coupled with the underestimate of sawlogs sourced from within the region, produces the unrealistic result that the Gippsland region's hardwood sawmills are achieving a miraculous sawn timber recovery rate of 42.6%. (p.50)
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Overestimate of proportion of sawmill offcuts re-used for export woodchips and pulp
Page 50 states that the sale of sawmill residues from the region earned $1.9 million. Page 45 states that the volume of sawmill residues sold was 197,696 m3. This works out to $9.60 per m3
Page 45, however, suggests that that the entire 58% of total residues from HW sawmilling operations are put back into pulp and paper and woodchip export market. It fails to take into account that there is a sizable proportion of unusable waste (such as sawdust) created in the process that there is no market for.
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Pulplog discrepancy
Page 62 states that Amcor used 70,000 m3 of pulplogs sourced from within the region, while page 53 suggests that around 24,000 tonnes of pulplogs from the region were bought by Midway.
This suggests a total pulplog output of 95,000 m3 or so. However, p. 41 states that the pulplog output for the region is 73511 m3, while p.43 says 73,000 m3 and p. 45 says 68,280 m3.
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Lack of logic
Page 43 states that 451,000 m3 of pulplogs "become available" in the region each year as a byproduct of normal sawlog harvesting, but are "underutilised". It goes on to say that 73,000 m3 of pulplogs was harvested in 97-98. It follows that in 97-98 "normal" sawlog harvesting resulted in a residual log byproduct of 73000 m3. How can the same paragraph imply that normal sawlog harvesting can result in a 451,000 m3 residual log by-product -more than six times higher than in reality.
On the same subject, the very notion of a pulplog "becoming available" is quite a bizarre notion. Worryingly, it implies that the State would like to see an additional 380,000 m3 cut from state forests within the region annually. It also implies that not cutting this amount is in some way a waste of a resource. This shows a failure to recognise that State Forests have values other than the pulplog price of the target species.
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Extremely messy choice of boundaries for the Gippsland RFA region:
The region takes in all of the Tambo FMA, but only 76% of the Central Gippsland FMA and 14% of the Wodonga FMA. This makes sustainable yield estimates and DNRE data (which are worked out on an FMA basis) extremely difficult to re-interpret.
The information showing that the vast majority of the sawlogs processed in this region are sourced from other RFA regions also indicates that the boundaries chosen for the Gippsland RFA are very unrepresentative.
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Page 71, paragraph 3 makes several mistakes.
Amcor total gross freehold and leasehold estate comes to 85,000 ha., 15,000 of which is native forest.Amcor's net plantation estate is around 55,000 ha.Far more than 60% of Amcor's net plantation estate is within the Gippsland RFA
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Population and Workforce discrepancies:
Page 8 states that the region has a population of 174000 and a workforce of 99,199. Gippsland Regional Information Service put the Gippsland population at 234,449 and workforce at 104,200 (this includes East Gippsland which they say has a pop. of 37893 and workforce of 13419). Mark Birrell, former State Industry minister, issued a press release in March this year quoting ABS statistics showing that Gippsland had a workforce of 78,100.
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Plantation Ownership misinformation
Page 69 states that half of Victorias plantations are publicly owned, yet the RFA is treating the 168000 ha. of State Forest land leased to HVP as de-facto private land. In reality the reverse is true. The land is still public land but the plantations have been privatised. It could be said that nearly all of Victorias plantations are privately owned.
This is a clear indicator that Victoria will not be developing long rotation or slow growing plantations for sawlogs, as only state governments are capable of waiting long enough for a financial return.
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Some minor errors
Page 70: Planthard is in Morwell, not Moe
Page 143 lists HUNTING as one of the primary recreation activities in National parks
Page 76 suggests that the Gippsland RFA region is within 100 km of Melbourne and Geelong. Page 53 has the HW and SW plantation tallies mixed up.
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Map 2:
Pine plantation and eucalypt reforestation has been lumped together in the EVC maps into category 149 : softwood and hardwood plantation. Previously, the hardwood reforestation was all classified as wet forest (No. 30). This was confirmed by DNRE botanist, John Davies; DNRE's Peter McHugh and DNRE's Brian Ward. This classification has been altered on the grounds of intended use rather than any botanical reason. Also, no hardwood reforestation is mapped within the Gunyah reserve. Approximately one quarter of this reserve is supposed to be hardwood reforestation and by this flawed system should be coloured grey.
Map 5
Non - forest, Private land and state forest leased for plantation purposes (all of the Strz SF) is all shown as the same colour. There surely must be some extra colours available in order to differentiate these three very different categories and important categories.
Map 5.1:
No hardwood mill is marked in for Yarram. This is a mistake as RADCON operates from Yarram, the manager of which participated in the RFA process.
No hardwood mill is marked in for Morwell, even though Planthard is the biggest HW sawmill in Australia. Page 49 states that 20 sawmills use sawlogs sourced from the Gippsland region, but map 5.1 only mark 18.
Serious confusion regarding HW sawmills
Map 5.1 also shows 11 of the 20 sawmills which use sawlogs sourced from the Gippsland sawmills are located outside the Gippsland RFA region. Page 50 states that 149,595 m3 of logs sourced from within the region were processed in sawmills within the Gippsland RFA . This begs the question: what volume of sawlogs sourced from within the region went to the 11 other mills located in different RFA regions? The report states the volume of sawlogs brought in from other regions (presumably to feed the 9 sawmills located within the region), but there is no mention of any volumes going out to feed the 11 mills outside of the region
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Map showing land tenure:
All Strzelecki State Forest is marked purple for plantations. This incorrect and overly simplistic classification was roundly criticised by the community at the initial RFA meeting in Yarram and should have been changed following that meeting. However, it has remained identical.
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Map showing old growth
The title of this map is totally misleading. This map should have been clearly labelled "old growth on public land" with a qualifier stating that it did not include leased public land. That information is buried deep within the text of the report on page 205. Information regarding old growth on land leased by HVP and Amcor is available. It is very naughty to have not mapped the old growth in the Strzeleckis. Page 205, paragraph carelessly implies that the level of vegetation disturbance on leased state forest is as great as it is on a freehold dairy farm. This is extremely un-professional.
The 8617 ha of State forest leased to Amcor is a result of a deal struck in the 60s and the 39000 ha. of State Forest leased to HVP was corporatised in 1993 and leased off in 1998. The leased public land in the Strzeleckis was ignored by the old growth survey for political reasons, not botanical reasons.
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Underestimate of tourist spending patterns - Gippsland on $29 a day!
The CRA has chosen to use the silliest tourism survey figures on offer, which puts forward the hypothesis that the average visitor to the "Gippsland Natural Discovery" region spends a grand total of $29 per day. To maintain this average, for every "big spender" visitor who spends $200 per day, there would need to be 19 visitors eking out a holiday on $19 per day! A $29 budget would mean no: drinking, smoking, gambling, golf, dining out, staying in motels, cabins, rental caravans or B&B's, driving too far, car repairs, going anywhere where there is a "high" entrance fee, shopping for anything other than food, etc.
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Sustainable yield figures are too selective
Sustainable yield rates are all based on D+ log grades sourced from State Forest (unless it has been leased) Until ALL logs are included - sawlogs, residual logs, logs from SW and HW plantations, logs from leased public land and logs from private land - sustainable yield figures will never be a valid indicator
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Page 36
"The Strzelecki hardwood plantations accounted for approximately 10% of the sustainable yield in Central Gippsland FMA, and, prior to this decision, were to be available for sawlog harvesting, and contribute to the sustainable yield from about 2020."
This passage:
1. Rashly uses the word "plantation" to describe hardwood reforestation in the Strzelecki Ranges
2. Suggests that there was a plan to leave harvesting in the reforestation until 2020
3. Rightly suggests that HW reforestation was not intended for short rotation pulplogs.
This is contradicted on page 64, which says "To date, hardwood plantations have been managed mainly on short rotations to produce pulpwood for paper manufacturing"
4. Suggests that Strz state HW plantations provided 18,300 m3 per year to Central Gippsland FMA sustainable yield figure (10% of the 183,000 m3). They are currently being logged at a rate of 100,000 m3 of sawlogs per year, which is six times their calculated sustainable yield rate.
5. The removal of the Strzelecki State reforestation from the sustainable yield equation suggests that "plantations" are not intended to reduce native forest logging, but to supplement it.
6. Suggests that the current rate of logging in the HVP HW lease is far in excess of projected sustainable yield and worsened by having commenced harvest 23 years too soon
"Given that the forecast sustainable yield in the Central Gippsland FMA was estimated to increase by approximately 14%, it was considered that the estimated 10% loss could be offset and therefore a change to the legislated sustainable yield rate was not warranted."
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STATE FOREST
p.16-17 The report refers to State Forest and how they are managed, for water, catchments, hardwood timber production, conservation of natural and cultural values, recreation and tourism etc. However, the issue of the effects of having these management regimes removed from the Strzelecki State Forest by treating as if it were private land have not been addressed.
Related issues:
- The Strzelecki State Forest has been made exempt from employing Special Protection Zones (no timber harvesting permitted) - designed to link and complement established conservation reserves; and Special Management Zones used to conserve specific features, where timber harvesting is permitted under certain conditions.
- p.18 The Strzelecki State Forest has been removed from the Forests Act.
- p.18 The directive that public participation play a part in planning forest management no longer applies to the Strzeleckis
- On public state forest the NRE has the ability to decrease the area harvested or volume taken to protect arboreal mammal habitats, rainforest, sites of high recreation and landscape value. The Ferguson Inquiry promoted this. (p.34) Similarly NRE can use volume, distribution and temporal harvesting controls to protect water yield and prevent soil erosion and stream sedimentation (p.114)
NRE has lost this flexibility of management in the Strzelecki State Forest .
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Page 53:
The passages describing the region's relationship with Midway in Geelong is too cryptic and vague. Why did it not just say: "Midway employs 20 full time staff handling around 500,000 tonnes of hardwood per year. In 1997-98, 24000 tonnes of their hardwood log intake was residual logs from the Gippsland RFA, and 6,000 tonnes were sourced from sawmill residues in the Gippsland region." It is also inconvenient in the way it talks in tonnes, while the rest of the document talks in cubic metres.
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We have prepared this analysis
We would appreciate it if RFA staff checked its accuracy and made any necessary corrections...
This region:
-Carries one third of all Victorias plantations (p.70: 85,700 ha)
-Carries one quarter of all Victorias State Forests (806000 ha. out of 3.3 million ha.)
-Provides almost half (more than 1 million M3) of Victorias plantation log harvest per year, (p.70)
-Provides 14% of the state forest sawlog supply and 6.6% of the state forest pulplog supply (RFA fact sheet)
-Processes 38% of all Victorias HW sawlogs, around two thirds of which are sourced from other regions (p. 45)
-Processes at least 50% of Victorias State Forest sourced pulplogs (Amcor holds rights for 500000 M3 of State forest pulplogs per year. (p. 63) and at least 80% of Victorias total HW pulplog output at Maryvale (820,000 m3 - p.63)
-Processes around 1 million M3 of plantation logs per year (p. 63: Amcor use 630000 M3 of softwood. and an unknown amount of plantation HW.... p.53: Brown and Dureau in Morwell is able to process up to 300,000 m3 of softwood...McDonnell & Sons in Yarram is able to process up 100,000 m3... Planthard in Morwell processes an unknown amount of "plantation" HW)
-Produces the bulk of all of Victorias paper products at Maryvale (p. 53: 400,000 tonnes)
-Produces 142,812 M3 of HW sawn timber (p. 50) which is more than one third of Victorias total output
-Produces an equally significant share of Victorias softwood sawn timber
-Provides and processes an ADDITIONAL 11% or so (100,000 m3) of Victorias HW sawlogs as well as an unknown amount of pulplogs from the Strzelecki State Forest (omitted from the CRA tally)
- Provides an ADDITIONAL 300,000 m3 of pine logs from HVP leasehold which are exported via Geelong (omitted from the CRA tally)
...yet only 11.4% of Victorias timber industry jobs are in this region. (p. 9)
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Key Legislation
p. 265 Appendix 1 Key Legislation:
The CRA report says that previous recommendations by the LCC continue to have
effect under the new Act - the ECC Act 1997. In the case of the SSF this
isn't correct. The LCC recommended that the SSF remain public tenure reserved
forest and subject to the Forests Act. Under the VPC Act, this forest
is now leasehold, and not subject to the Forests Act. In the Final
Recommendations South Gippsland Area District 2, the LCC recommended that areas
within the SSF be made Section 50 Reserves - not all these areas have been made
reserves.