Julie Constable

To Smartwood Program

65 Millet Street

Richmond,

Vermont USA 05477

jhayward@smartwood.org

re: FSC Certification for Hancock Victorian Plantations and the Interim Standard

Dear Smartwood,

Thank you for the inclusion of Kim Devenish and myself, Julie Constable as stakeholders in the certification assessment of Hancock Victorian Plantations. Thank you for the posting of the Smartwood Certification Interim Standard for Assessing Forest Management in Australia and your letter requesting a copy of ‘A Proposal for a 30,000 hectare National park in the Strzelecki State Forest’.

After a preliminary reading of the interim standard , I can see many positive aspects of the general principles and areas where consultation and discussion may lead to satisfactory resolutions of forest management. However, there are three main issues which I believe are critical to the certification of Hancock ‘s forest management and they all relate to the Strzelecki State Forest. These are: the unresolved issue of community support for a 30,000 hectare national park in the Strzelecki State Forest; the unresolved issue of the community opposition to the vesting of this forest and subsequent privatization under Hancocks; the unresolved community dispute over the classification , labeling and mapping of hardwood plantation in the Strzelecki State Forest Community attitudes are supported by facts, reports and research and the issues relate to other Smartwood Interim Principles. These will be discussed under each issue.

These three issues are all related to land use decisions and would seem to need resolving before any field assessments take place in any hardwood areas in the Strzelecki State Forest. In particular, it is necessary for Smartwood to be certain that when it conducts field assessments in the Strzelecki State Forest, that it knows whether it is assessing native forest, reforestation or legitimate plantation.

These three issues are discussed in the following pages. There may be other issues which we will respond to at a later date. We also feel it will be essential to speak with Smartwood personnel and be able to discuss these issues with the aid of appropriate maps, historical data and reports. It is possible that we will be unavailable for an appointment between September 28 and October 23. However, until September 28 and after October 23 we will be happy to discuss these issues with you.

Thank you

Yours sincerely

Julie Constable

Submission No. 1 from Julie Constable to Smartwood on the Process of FSC Certification Assessment of Hancock Victorian Plantations Pty. Ltd.

Issue 1. ‘A Proposal for a 30,000 Hectare National Park in the Strzelecki State Forest’.

This proposal may be accessed from the website dedicated to the Strzelecki State Forest at

<http://members.dcsi.net.au/kimjulie/reserve.htm> The Park proposal seeks to redress the lack of reserves in the Strzelecki State Forest and ensure that a large area of the state forest is returned to public management. under the National Parks Act. Basically it sets out the key areas where an extra 25,000 ha. of public land could be selected to add to the existing 5,000 ha. of reserves.

The proposal was written in 1998 and therefore needs to be read in conjunction with the following update.

Support for the Proposal:

The office of Susan Davies, MP Gippsland West organized a petition in support of the proposal. In September 1998, 7,000 signatures were tabled in the Victorian Parliament.

Groups supporting the "Proposal" : 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 Australian Labor Party, 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 Gippsland Local Government Network has acknowledged the need for a greater reserve system in the Strzelecki forests. Included in their major objectives is the creation of a major tourism asset in the form of an enlarged park or reserve system in the Strzelecki Ranges and to seek funds for the buy back of Hancock timber rights on public land. (from GLGN 'Memorandum of Understanding, Action Plan 1999-2000)

The Social Assessment chapter of the Gippsland Regional Forest Agreement, acknowledged that the local community has a vision for a major National Park in the Strzeleckis.

The year 2000 saw the publication of Victoria's National Parks: A Centenary History by Esther Anderson and published by the State Library of Victoria and Parks Victoria. In chapter 6, the Proposal for a 30,000 ha. National Park in the Strzelecki State Forest' is acknowledged. "There has been a community-based move to have part of the Strzelecki State Forest on the Strzelecki Ranges declared a national park. A proposal has been put forward by residents of South Gippsland, supported by Greening Australia, the Latrobe Valley Field Naturalists, the Society for Growing Australian Plants and the Shire of South Gippsland, urging that an area of the Great Forest of Gippsland be reserved." p.212

Update on Reserve Criteria

Chapter Six of the “proposal” was concerned with Comprehensive, Adequate and Representative Reserve systems during the Regional Forest Agreement process. The State Government sold the timber rights to areas in the Strzelecki State Forest and allowed most of the native forest component of the forest to be managed by Hancock Victorian Plantations, during the public RFA Process. The consequence of this was that that the bulk of the forest was excluded from being considered for the CAR system.

However, the scientific guidelines for adequate reservation of Ecological Vegetation Classes on a bioregional basis has been accepted by the Victorian Government and outlined in ‘Victoria’s Biodiversity. Directions in Management’ (NRE,1997) and later developed in ‘Victoria’s Draft Native Vegetation Management Framework’(NRE, 2000).

The bioregional data which is available currently shows that the Strzelecki Ranges Bioregion has 19% of its original native vegetation cover remaining. This means that the bioregion is classified as fragmented. Despite being a heavily depleted Bioregion, the majority of the remaining native vegetation forms a continuous mass following the upper parts of the Eastern Strzelecki Ranges. The Eastern Strzelecki Ranges which represents around half of the Bioregion contains more than 90% of the remaining Wet Forest and Rainforest; more than 80% of the remaining Damp Forest and more than 50% of the areas covered by the other extant EVCs. In all, some 50,000 hectares of the bioregion’s 60,000 hectares of the remaining native vegetation cover occurs in the eastern half of the bioregion. Of this, around, 30,000 hectares is on public and leased public land. The majority of the remainder is now on Grand Ridge Plantations private land.

Reports and studies based on this bioregional approach to conservation that concern the Strzeleckis include ‘The Nature Conservation Review, 2001’ and the’ Draft West Gippsland Native Vegetation Plan’ . It is interesting to examine these two documents and the vindication they lend to the grassroots proposal for an extra 25,000 hectares of reservation in the Strzelecki State Forest.

"The Nature Conservation Review, 2001" by Barry Traill and Christine Porter.

is an independent review funded by the Victorian National Parks Association . It was launched on March 5th at the Royal Society.

There are four major recommendations for land based reserves for the state, one being that 'a major new park system be established to conserve the biodiversity of the Strzelecki Ranges'. The Review continues, " The Strzelecki Ranges Bioregion forms a distinct and isolated area of tall wet forests and associated foothill forests. Land clearing and intensive forestry has fragmented and degraded the forests of the ranges. A major park system in the Strzelecki Ranges is needed to ensure protection of the remaining biodiversity of the wet and damp eucalypt forests and cool temperate rainforests of the regions. The special circumstances of land tenure in the Strzelecki Ranges are discussed briefly in Appendix 3.5. " (p. 108)

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." p. 107

On examination of the data and the criteria and modeling used in this report, the Nature Conservation Review requires reserve targets of 49,300 ha. for the Strzelcki Ranges Bioregion, some 45,000 hectares more than is presently reserved, and 20,000 more than in our “proposal”.

The data in the draft Native Vegetation Plan suggests that only 4% of pre-1750 wet forest and 5% of pre 1750 cool temperate rainforest are formally protected in the Strzeleckis Bioregion. In the Strzelecki State Forest, all Cool temperate rainforest and damp forest must be reserved to meet minimum targets.

Minimum Regional Vegetation Plan targets of 35% of extant Wet Forest would require 14,350 ha. reserved. At present there is approximately 3000 ha. protected in reserves, thus requiring an additional 11,350 ha. of Wet Forest to be reserved. This Plan suggests that in all, reserves in the Strzelecki Ranges Bioregion need to cover 29,300 ha., some 25,000 ha. more than is presently reserved. These targets equal those in our “proposal”.

We have a paper called ‘Strzelecki Ranges Bioregion Overview’ which can give more detail on this data.

State Government Commitments Relevant to the Proposal:

Prior to the recent Victorian Government election (November 1999) in 'Our Natural Assets: Valuing Victoria's natural environment', the Labor Party stated that 'The Kennett Government has failed to protect remaining native vegetation in the Strzelecki Ranges. It privatized 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.'

Strzelecki Working Group Proposal

This SWG includes Kim Devenish, Julie Constable, representatives of Friends of Gippsland Bush, South Gippsland Conservation Society, Hancocks, Wellington, Latrobe and South Gippsland Shires and Trust for Nature. The group came into being when the timber rights in the Strzeleckis were sold to HVP on the initiation of the South Gippsland Shire. The Shire had recognized the community disquiet about what was happening to the forest and set up the group to examine ways in which to protect the Strzelecki forests. The group commissioned a biodiversity study. ‘The Strzelecki Ranges Biodiversity Study’, among other things, concluded that the maintenance of biodiversity in five core areas and habitat links which it had identified was incompatible with timber harvesting. The group has now asked the Government’s assistance in the creation of a reserve to protect the Cores and Links.

Many groups which support the 30,000 hectare national park proposal, are supporting this smaller addition of 8,700 hectares to the reserve system as an urgent priority. Groups who have written letters of support include:

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

Issue 1 in relation to Certification and the Interim Standard

The community ‘s support for a 30,000 hectare national park in the Strzelecki State Forest was submitted to the Government prior to Hancocks purchase of the assets of the Victorian Plantations Corporation . The company was aware of the community call for a reserve before the sale and the company has not opposed the idea of a national park. Negotiations over this issue began with the Company in early 1999. More recently, Hancocks has agreed, along with the rest of the Strzelecki Working Group to ask the Government to establish a reserve of the Core and Link areas identified in the ‘Strzelecki Ranges Biodiversity Study’. This would add about 8,700 hectares to the reserve system. This issue is unresolved, with Hancocks only verbally promising not to log the cores and links for 2 years. This issue is relevant to Principle 2, which states that ‘the existence of major unresolved, or poorly resolved, conflicts within the local community may be an impediment to certification’.

This issue is also relevant to Principle 1 which involves compliance with laws. In Victoria, all development must be ecologic ally sustainable. Scientifically based bioregional reserve targets are the basis for achieving ecological sustainability. The scientific criteria for working out bioregional reserve targets is described in the Draft West Gippsland Native Vegetation Plan, the Nature Conservation Review 2001 and the Regional Forest Agreements documents. Even if 8,700 hectares is added to the reserve system, the reserve system will still be below acceptable targets and satisfactory compliance with Principle 1 will not be achieved.

The issue is relevant to Principle 6 which says that ‘Forest management shall conserve biological diversity and its associated values, water resources, soils, and unique and fragile ecosystems and landscapes, and, by so doing maintain the ecological functions and the integrity of the forest’. There are many threatened and endangered species of flora and fauna in the Strzelecki forests which require special attention in the overall management of the forest. Biosis Research in the ‘Strzelecki Ranges Biodiversity Study’ have emphasized that the maintenance and enhancement of biodiversity on Hancocks holdings is incompatible with timber harvesting in the high biodiversity Core and Link areas identified in the study. Principle 6 also says demands that ‘reserve areas are monitored to ensure they are viable and management changes implemented if necessary to ensure viability’. (6.4)

Principle 9, the Maintenance of high conservation value forests is also relevant to this issue. The Strzelecki native forests are of high conservation value on several grounds. The current low level of reservation; the presence of threatened, endangered and depleted Ecological Vegetation Classes; the presence of regional and national significant sites (zoological and botanical); the presence of endangered species; of endemic species; of watershed values and the fact that management units are ‘ contained within a large landscape level forest where viable populations of most if all naturally occurring species exist in natural patterns of distribution and abundance’.

Issue 2: The vesting and privatization of the Strzelecki State Forest.

Many in the local communities were opposed to the sale of hardwood timber rights in the Strzelecki State Forest and the vesting of over 20,000 hectares of native forest in the VPC and consequently HVP. The issue of the hardwood timber rights is taken up in Issue 3.

The last major land use report relevant to the Strzeleckis, was the Land Conservation Council’s South Gippsland Area 2. This report recommended that the forest remain in public tenure and remain subject to the Forests Act.

The vesting and sale of timber rights in the Strzeleckis have removed the forest from the Forests Act and the lease arrangements mean that the forest is treated as if private under some legislation. These changes were made without public consultation or an Environmental Impact Study.

The support for the national park proposal reflects the view that the forest remain in public tenure and under greater protection. There was also a demonstration outside the Victorian Parliament to oppose the amendments to the VPC Act which allowed for the privatization of the assets of the corporation.

This issue is unresolved and is relevant to Principle 2, which states that ‘the existence of major unresolved, or poorly resolved, conflicts within the local community may be an impediment to certification’.

Issue 3: The unresolved issue regarding the incorrect labeling of native forest as plantation.

There has been a long history of opposition to the establishment of the pine plantations in the Strzelecki State Forest. In fact, it was a local conservation group, angry at the amount of bush converted to pine plantation, the Yarram & District Conservation Group which instigated the call for a Timber Industry Inquiry in Victoria in the early 1980s. One outcome of this Inquiry was that the conversion of bush into plantation be halted from 1986. This past history is interesting, when one considers that there has been an attempt to classify all young, biodiverse, native forest in the Strzelecki State Forest as hardwood plantation. Areas logged or reforested before 1986 have also been incorrectly designated as plantation on HVP’s maps. This undermines local concerns and actions from decades earlier and threatens the ecological integrity of the forest. It is also unlawful to convert forest to plantation in Victoria and name changing should be considered unlawful as well. Conversion of forest to plantation and name changing of areas from forest to plantation shouldn’t be touched with a ten foot pole.

SUMMARY OF EVIDENCE

The Hardwood Reforestation Scheme

Hardwood reforestation began from the late 1940s in the Strzelecki State Forest. The aims of the hardwood reforestation scheme are summed up in the Land Conservation Council’s report. ‘The hardwood planting program is resulting in the restoration of a forest that will eventually have a similar structure to the original, and options for the future use of the land are being restored’. - Quoted in LCC Final Recommendations South Gippsland Area District 2, 1982. The need for reforestation in the Strzeleckis was recognized by the State Development Committee, which stated in the Royal Commission on the Outer Ports, 1927 that "this area, which once carried some of the finest white mountain ash forest of the State, presents a challenge to man to restore its beauty and productivity, which he so eagerly destroyed" - Quoted in LCC Final Recommendations South Gippsland Area District 2, 1982.

This means that the scheme was to restore forest to land which had been cleared or degraded; not to remove forest from areas which had been left undisturbed or regenerated naturally. Unfortunately, on the ground, forest was removed for both the softwood and hardwood plantings. Some areas claimed as plantation now, are in areas which were never alienated from the Crown; some are areas which were freehold for a time but were either never cleared or only partially cleared for farming.

The directive to restore Mountain Ash was also misused on the ground by the Forests Commission. The removal of other natural forest types, such as acacia forests and rainforest to plant Mountain Ash being a common practice.

The LCC report praises the hardwood reforestation scheme, but in other places refers to the establishment of hardwood plantations. However, it refers to all the forest as being maintained as reserved forest under the Forests Act and while providing timber, had to pay due regard for landscape values, recreation, conservation of flora and fauna and water values.

There are a number of scenarios that could explain this changing between the term reforestation and plantation. The LCC did not define its terms. Plantation in a general sense, can just mean planted, and not necessarily mean narrowly a timber plantation. It may be that the LCC was using the word in this general sense.

Another possibility is that having to rely on Departmental data, the council itself was confused by how much of the area was reforested, how much was native forest logging regeneration and how much was established as timber plantation, and this confusion was reflected in the report.

Confusion may well be the problem here. Lack of data became an issue in the 1990s when the vesting process took place. In 1997 we began asking for evidence of plantation establishment and reforestation and logging. I was told by the DNRE that all the records of plantation establishment had been given to the VPC; VPC told me that DNRE had kept them all; on other occasions I was told that record keeping for hardwood had not been rigorous; on another occasion that records had been burned. During the RFA Kim Devenish asked for clarification on number of hectares reforested; number of hectares logged and regenerated; number of hectares established as plantation; the number of hectares in total of the Strzelecki State Forest and other relevant data. To this date, this information hasn’t surfaced and we have had to fit data fragments together like a jig-saw.

Despite all this confusion, the hardwood reforestation scheme was to restore Mountain Ash to areas where it had been removed, and was not a step towards the provision of exotic species short rotation timber plantations, that is being claimed at present.

Some of the claimed hardwood plantation is regenerated native forest logging coupes.

Native forest logging has been facilitated by the Forests Commission and the Department in the Strzelecki State Forest. From the figures of sawlog and pulplog taken from SG Area 2, provided in the LCC Report, we estimate that in the years prior to this report, approximately 200 hectares of Strzelecki State Forest was being clearfelled annually.

The DCE brochure "welcome to the Strzelecki Forest Drive" (undated, but circa 1990) states: "In any one year wood is harvested from about 100 ha (0.9%) of the native Strzelecki forests. This developing forest presently produces around 2100 M3 of sawlogs." The amount of pulplogs produced is not stated. This indicates that native forest logging in the Strzeleckis continued into the 1990s, perhaps at a reduced rate compared to the figures from a decade earlier, or perhaps on areas which yielded less sawlogs. It goes on to say "Forests are regenerated following harvesting".

The Timber Industry Strategy

The Timber Industry strategy in the mid 1980s stopped the practice of harvesting native forest and converting to plantation on public land. This is further reinforced in the ‘Timber Industry Strategy Government Statement, 1986’.

‘Native forest values will be safeguarded as new pine and hardwood plantations are established on cleared land’.(p.95)

Since that time, around 1500 hectares of hardwood plantation has been established in the Strzelecki State Forest, mostly on areas that supported native forest prior to conversion, including sites of botanical significance, sites of zoological significance, sites recommended for reserve status by the LCC and in RFA Deferred Forest Areas.

Since 1993, ‘plantation’ areas have also expanded by clearing surrounding native forest. See Dr. Tim Ealey’s report Plantation Logging in the Strzeleckis. Dr. Ealey’s report is pertinent to the expansion of so called plantation areas, but he doesn’t examine the issue of whether areas are plantations per se.

Definitions:

All this Mountain Ash reforestation (which is now claimed as plantation, and denied native forest status) fits the State Government's own definition of native forest or regeneration as used in the Forest Code of Practice, etc., better than it fits the definition of plantation:

Definition of Regrowth

The Victorian State Government uses the term "Regeneration", and defines it as:

"The renewal of forest by natural or artificial means"

Definition of native forest

The National Forest Policy Statement defines native forest as 'any local indigenous community...and containing throughout its growth the complement of native species and habitats...or having the potential to develop these characteristics. It includes forests with these characteristics that have been regenerated with human assistance following disturbance."

Definition of Plantations:

The Victorian State Government, in several of its publications, including the Forest Code of Practice, uses this sentence to define plantations:- "a forest stand established by the planting or sowing of trees of either native or exotic species selected for their wood-producing properties and managed intensively for timber production".

Until recently, the lack of intensive management in the Strzelecki hardwood reforestation is striking. The pruning, thinning, fertilizing and spraying that intensive management entails is not apparent and indeed, inappropriate on reserved forest.

The National Forest Policy Statement agreed to by the Commonwealth, State and Territory Governments, used by the Regional Forest Agreements, defines plantation as "intensively managed stands of trees of either native or exotic species, created by the regular placement of seeds or seedlings."

The definition suggests that plantations must form rows. This is not apparent in the Strzelecki State Forest Areas which have been reforested in a random fashion such as areas sprinkle seeded, aerial seeded, seeded by hot burns or by seed trees, etc. also seem to be excluded from the definition. At present, even logging coups which have regenerated without human assistance have been labeled "plantation".

Intent: The definitions above provide evidence to show that the regenerated logging coupes and reforestation in the Strzeleckis is not plantation. Intent also plays a part. The Department * describes reforestation as ‘native forest reforestation’. (see Mt. Fatigue Reforestation Plan, August 1989) In reference specifically to some sites in the Mt. Fatigue area, this plan states, ‘Reforestation particularly in the Mt. Fatigue area involves conversion of the present understorey scrub species to the natural eucalypt dominated forest which existed prior to the land first being cleared for farming’. (p.1) The Plan also states that it is ‘Department policy to reforest areas only with trees that are native to the site.’

* The Department started off as the Forests Commission and since that time has undergone many name changes. At present it is the Department of Natural Resources & Environment.

Other Evidence

The Nature Conservation Review 2001 observed that, ‘illegal clearing of vegetation may be currently occurring in the eastern Strzeleckis if areas of native forest, incorrectly designated as plantations, are clearfelled and replaced with non-indigenous species.’ p. 190

Botanists during the Regional Forest Agreement classified the reforestation and regenerated forest in the Strzelecki State Forest as Wet Forest. Final maps were altered , lumping this ‘Wet Forest’ in with Pine Plantation, a land use decision and not a botanical one. This action seriously compro mised the outcome of the Gippsland Regional Forest Agreement and augmented the serious skepticism about the Gippsland RFA process. This is another unresolved community issue.

See below for case studies of particular forest areas that provide evidence of incorrect classification.

Repercussions of Including Reforestation and Regenerated coupes as plantation

Reclassifying Strzelecki hardwood reforestation as plantation:

- reduces the amount of forest cover in the Strzeleckis rather than restoring forest.

-is totally at odds with Victorian forestry publications which state that logged native State forest is regenerated with native forest., not replaced with a tree-crop.

-contradicts the definition of plantation due to the lack of intensive management

- contradicts the original intention of the reafforestation scheme to restore the beauty and productivity and native forest of the area.

-blocks future options

- defeats Native Vegetation Retention goals by lowering the official tally of native forest in this state forest

- defies State Planning Scheme Guidelines that plantations should be established on predominantly cleared land.

and

- allowed the privatization of this significant native forest remnant to occur

This in turn affects the status and management of the bulk of the Strzelecki State Forest by

- removing the forest from jurisdiction of Forests Act; the RFA CAR reserve system; and Forest Management Plans

- allowing timber harvesting to operate under the less environmentally stringent private section of the Code of Forest Practices

How this issue has not been resolved

More detailed evidence to show that not all the 7,000 ha. should be considered plantation has been provided to the Department and two Victorian Governments, the former Coalition and the present Labor Government. It has also been provided to Hancock Victorian Plantations. No evidence has been proffered to refute our arguments from the Department, the Victorian Plantations Corporation, Hancock Victorian Plantations or the Government.

Case Studies of Particular Forest Areas.

The following case studies show two forest areas in greater detail. Each area may be seen as a microcosm of the mismanagement of the Strzelecki State Forest. There are many other areas throughout the hills, which carried natural forest prior to being logged and re- labeled as plantation. Some of these were established by the VPC in the mid 1990s. Some specific areas could be shown to you on maps.

1. Gunyah Forest

The forest area shown on parish maps as the Gunyah Timber Reserve. This area was set aside in the 1880s. It was never alienated from the Crown, never cleared for farming. It has been classified as a site of botanical significance; zoological significance, containing nationally significant rainforest. Part of it is in the Gunyah Gunyah Rainforest Reserve. Areas were logged in the late 70s with protest from the public; the Rainforest reserve was created in the mid 1980s after logging plans revealed logging was imminent and a campaign was launched. The logging coupes from the 70s were logged again in 1997 as well as the surrounding Mixed Age forest which included 1914 Ash regrowth, old Ash that had survived fire(s), upwards of 300 years; a regenerating Cool Temperate Rainforest layer including Myrtle Beech; Cool Temperate rainforest gullies. These logged areas are now labeled as hardwood plantation.

2. Woomera Creek Catchment

In December 1987, the Mt. Best Concerned Residents submitted a reserve proposal to the Department, called ‘On the Future of the Regrowth Forest on the Southern Face of the Mount Fatigue-Woomerra Creek Ridge’. The submission called for a flora and fauna reserve of approximately 750 hectares south of Devil’s Pinch Road at Mt. Fatigue, the banning of aerial 1080 baiting throughout the region and the cessation of strip-clearing for regeneration;

The submission emphasized the value of the regrowth forest of the Woomerra Creek area with its potential for succession, the presence of rainforest plants in the gullies, the diversity of understorey flora and its value to the fauna of the area—wallabies, wombats, echidnas, lyrebirds and platypuses. The submission was critical of the removal of understorey and mature trees by Departmental reafforestation activities and subsequent reduction in habitat in the region, as well as effects of these activities on soil erosion and siltation of creeks, rivers, and ultimately Corner Inlet, where seagrass beds would be threatened.

A long campaign to have this area designated a reserve was initiated by the Mt. Best Concerned Residents. They were opposed to any reforestation in the catchment, arguing that the area supported mature forest, rainforest gullies, and naturally occurring regrowth on previously disturbed or abandoned areas. In 1989 the Department wrote the ‘Mt. Fatigue Reforestation Plan’ in which it put forth the proposal to reforest 210 hectares by clearing and replanting. This was called native forest restoration.

At two public meetings, the Department outlined this plan and the tapes from these meetings provide further evidence that reforestation is native forest restoration and that any future wood harvesting is to be at least 80 years away and subject to public opinion at that time. (And presumably taking into account scientific and conservation principles.)

Tape 1: 28 November 1989, Foster

Department Staff Present Ian Hemphill, Bob McKinnon and Ross Pridgin

They refer to a map of the 750 hectares which shows 4 native forest logging coupes, 2 from 1954 and 2 from 1986. It also shows a 15 ha. patch of reforestation.

Mr. Hemphill says he’d like meeting to avoid talking about logging and concentrate on reforestation, because any logging is ‘80 years down the track if that’s a problem then’

He says that concern has been expressed as to whether they are putting in plantation species. He says they are matching species that naturally occur there.

Mr. Pridgin: ‘It (the landscape perception study) also caused us to stop logging for the time being and as Ian said, that will now be a decision to be made quite a time down the track when further reviews are made, probably once we ‘ve all passed on, as to whether this will be part of the production forest or not’. ‘Decisions for future generations....’

The Department stresses that to reforest this particular bit is just to have the option open of harvesting in the future.

Mr. Pridgin ‘Whether that option is taken up or not is up to the future. And that’s been the same thing with every area in the Strzeleckis that we have bought back or resumed after people have walked off and reforested’.

Someone asks if the reforested areas throughout the Strzeleckis are logged in 80 years time will they be replanted again with Eucalyptus Regnans.

Mr. Pridgin ‘That would be the intention.”

Tape 2 26/1/90 Mt. Best

Departmental staff present: Ken King(Regional Officer Yarram, now Head of Forest Service, Melbourne) and his staff, Ian Hemphill (Forest Production Planner; became Zone Manager VPC and HVP), Les Leunig (Land Protection Officer, Foster), Tony Willott,(Bio protection planner and filling in for Ian Leversha)& Regional Fire Protection Officer.

Chair Alan from Alberton Shire

Ian Hemphill speaking. “I stress from the outset that its the Mt. Fatigue Reforestation Plan. That’s not a sleight of hand or a card trick sort of thing, it definitely means that. We are separating the issues into um... the first steps in any management of this area is to restore it to its original condition, then the debate about whether its logged or not can be taken up at a future date”.

‘If we reforest these areas it could be something like 40 -80 years before any action is likely to be taken on those areas in terms of decisions on logging. I say 40 because there are some older growth forests in here , but we’ve found with the 1939 ash regrowth that its got to be at least 40 years old before its really runs into its prime suitability for utilization. If you cut it much earlier than that then you are not doing the timber justice... ....Current department policy is to run these forests on a 100 year plus rotations....

The issue of whether we’re talking about plantation species. In the plan you’ll read that the seed for these plants, the plants have already been produced at the Department’s nursery at Won Wron. The seed was collected last year in these areas just to the north. So seed collection’s not really an issue in this area, except to say that we’ve collected seed from the trees that are native to the area. The mixtures of planting won’t be just a complete sweep of Mountain Ash. Quite obviously, these northern aspects naturally grow messmate and blue gum and ridge tops of blue gum, those who know the drive up to the scenic reserve, notice there’s messmate on the right hand side up there. Those sites will be planted to Mess mate. The site’s southern aspects those will be the only ones planted to Mountain Ash. In other words, the actual mixture is close as we can get it to what was originally there will be replanted.”

End of transcripts.

----------------------

The Mt. Best Concerned Residents reserve proposal was denied and the Department cleared and ‘reforested’ areas within this catchment in 1990. At present, the 4 regenerated native logging coupes from 1954 and 1986 are now classified as plantation, as well as the earlier reforestation and the 1990 reforestation. All the forest is now leased to Grand Ridge Plantations.

How Issue 3 is relevant to the Certification of HVP

During the public opposition to sale of the timber rights in the Strzelecki State Forest, mapping of the ‘plantation’ areas was not available. Logging history maps showing areas which had been logged were available in Melbourne, but in the Victorian Plantations Corporation Office, the main map showed softwood plantation and the rest of the forest as forest. Many politicians argued in Parliament that a delay in legislation paving the way for privatization was necessary until mapping was complete and could be subject to public scrutiny. They were ignored.

Hancocks were aware of this problem when they took over the management of the area. Mr. Whittemore of HVP, said that he aware of the arguments between the VPC and conservationists as to the definition and location of plantation, old and regrowth trees, in the area now managed by HVP. (Foster Mirror, 17-2-1999) He continued, ‘the mapping is not going to be resolved immediately....’

Hancocks had to assess their hardwood plantations after the sale was finalized, and did this by comparing aerial photographs of young forest to logging history maps. This methodology does not distinguish between young regrowth ash, regenerated native forest logging coupes, reforestation or plantation establishment. By basing their hardwood plantation survey on treetop shape, all young ash seems to have been classed as plantation.

Given that botanical description of reforestation and regenerated forest as Wet Forest by RFA botanists, the logging and converting to plantation species is in breach of Victorian regulations including the Native Vegetation Controls under the Planning and Environment Act which specifies that plantations only be established on cleared land; and the Code of Forest Practices which prohibits the conversion of forest into plantation. This is relevant to Interim Standard Principle 6, Environmental Impact. Under 6.3 the Interim Standard says that ‘ecological functions and values shall be maintained intact, enhanced, or restored, including forest regeneration and succession, genetic, species and ecosystem diversity....’ In 6.10 the Interim Standard says that ‘Forest conversion to plantations or non-forest land uses shall not occur on high conservation value forest areas.....’ In the Strzeleckis , all native vegetation is of high conservation value because it is a bioregion with only 19% native vegetation extant. There are also areas within HVP holdings that are in areas recommended for protection, and provide habitat for vulnerable, rare, threatened or endangered species or ecosystems, (6.10).

The issue is also relevant to Principle 10, Plantations in the interim standard. This principle states that ‘plantations should not displace natural forests or other biologically important ecosystems’. 10.2 continues ‘the design and layout of plantations should promote the protection, restoration and conservation of natural forests, and not increase pressures on natural forests’. Given that, native forest restoration in the Strzeleckis is now being logged and converted to plantation, restoration measures of the past are being undermined and the native forest is being fragmented and degraded by current management applications.

10.9 says that ‘plantations established in areas converted from natural forests after November 1994 normally shall not qualify for certification.’ Many natural forest areas in the Strzeleckis were logged since this time and are now called plantation. In Victoria’s case, 10.9 should be brought back to 1986 when the Timber Industry Inquiry directives prohibited this activity.

10.9 also says, ‘Certification may be allowed in circumstances where sufficient evidence is submitted to the certification body that the manager/owner is not responsible directly or indirectly of such conversion’. This point needs further clarification in the Strzeleckis. While Hancocks may not be responsible for logging in the Strzeleckis between the late 1940s and 1999, they have played a role in the mapping and designation of the plantation status to areas for which we have provided evidence to show should be regarded as native forest.

This is another major unresolved issue as outlined in Principle 2 which says that ‘the existence of major unresolved, or poorly resolved, conflicts within the local community may be an impediment to certification’.

It is imperative that Smartwood address these issues of land use, classification of plantation, the viability of the reserve system and community plans for the forest before any forest management assessment takes place.

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Preliminary Notes on the Standard:

It is important that the Standard codifies the need for Bioregional conservation reserve targets being met. Without this it will be impossible to ensure beneficial ecological outcomes; ensure compatibility with scientific reports; meet the demands of the local community and assist HVP in meeting ecological sustainability goals.

10.9 must be modified to be consistent with Victoria’s laws prohibiting the conversion of public native forest to plantation since 1986. This applies to the establishment of softwood areas after this date as well.

It is important to include the Planning and Environment Act in the list of laws, rules and regulations in Principle 1. This Act contains the retention of native vegetation controls guidelines.

Preliminary Notes on Certification:

Hancock Victorian Plantations must be commended for the steps they have undertaken in relation to their involvement in the Strzelecki Working Group and ‘Strzelecki Ranges Biodiversity Study’ and their support for the reservation of the Core and Link areas identified by Biosis. However, the gravity of the three issues raised in this submission and the lack of resolution of these issues provides a huge impediment for certification.

Other Issues

There are also many other issues in which we are interested which are relevant to the Interim Standard and the Certification process. We have not touched on the heartaches we have in regard to what we see as an unprecedented acceleration of logging and planting activity throughout the Eastern Strzelecki Ranges.

‘The Strzelecki Ranges Biodiversity Study’ (Biosis Research, November 2001) raises the problems associated with the repeated use of designated plantation areas as intensive production areas and the subsequent loss of biodiversity. ‘The initial clearing of the Strzelecki Ranges had a significant impact on the structure and habitat characteristics of the Wet Forest environment, largely impacting on sensitive/hollow dependent fauna and reducing the extent of Cool Temperate Rainforest. Most Wet Forest plants, however, probably re-established after this disturbance. ‘ In regard to reforested areas, the report says, ‘the overstorey may have been planted and its species composition modified or simplified, but it is still functionally native vegetation capable of regenerating many of its depleted characteristics in the longer term.’(p.60) The report goes on to say that if the areas are logged again and again, many native species are unable to regenerate. ‘This simplification of the biodiversity needs to be managed if the significant ecological values of this bioregion are to be retained in perpetuity’. (p.60)

The report outlines strategies to maintain biodiversity including:

Management strategies for the Core Areas and Habitat Links, which ‘should be put in place as soon as possible, for the long term protection of biodiversity within the HVP estate’. (p.63). The report concludes, that ‘from an environmental perspective, the Core Areas are particularly sensitive to disturbance and the high biodiversity values of the Core Areas would be substantially enhanced if these areas (and also habitat links) were excluded from timber production’. (p.74)

In regard to areas of native vegetation outside the Core and Link areas, the report says that all native vegetation is ‘important for biodiversity and should be clearly delineated on the ground to minimize disturbance from harvesting activities’. (p.67)

The placement of buffer zones around known locations of threatened flora, fauna and vegetation communities. They recommend for Cool Temperate Rainforest isolates, 250 metre ‘no go zones’ and 100 metres for Warm Temperate Rainforest isolates. (p.68)

Minimum buffers of 30 metres on waterways. (p.68)

Treating minor drainage lines as buffer strips and retaining the native vegetation to a minimum of 20 metres , i.e. 10 metres on each side of the drainage line. (p.68)

Minimum buffer of 2000 metres around Spot-tailed Quoll records. (p.69)

Improvements to the minimum standards of the Code of Forest Practices to protect rainforest, biodiversity, soil and water values. For example, harvesting should be excluded on slopes over 25 degrees (p.69); extending retained gully vegetation across ridges and widening strips to retain more eucalypts; marking coupe boundaries. (p.69-70)

The report recommends ‘the planting of Mountain Ash be encouraged for any replanting, and areas of harvestable hardwood should not be replaced by pine trees or any other non-indigenous species, e.g. Shining Gum’. (p. 70)

Planting suitable areas with a mix of locally indigenous tree species and maintaining/restoring 10-30 metre wide strips of koala feed trees.

Avoiding native vegetation for roads, tracks etc.

Retiring narrow and isolated areas mapped as harvestable within the linkages.

Planning harvesting to produce a dispersed array of regenerating coupes that contribute to habitat continuity. (p.70)

Avoiding herbicides. (P.71)

Addressing the Victorian Biodiversity Strategy; the Draft West Gippsland Native Vegetation Plan and the Nature Conservation Review. (p.71-2), which are all concerned with native vegetation protection and reserve targets. p.72-3 outlines the target levels for protection of Ecological Vegetation Classes in the Strzelecki Ranges Bioregion. We have given more detail on this in our discussion of Issue 1, the National Park Proposal, ‘Update on Reserve Criteria’.

I include this list of recommendations from Biosis for your information and for consideration in the detail of assessing forest managment in the Strzelecki forests.

Supporting Papers we can make available:

Newspaper Archive

We have an enormous archive of newspaper clipping which relate to the privatization issue, the National Park Proposal and the controversy over the misclassification of native forest as plantation in the Strzeleckis. These articles reflect the community attitudes to all these issues.

Notes on the history of forest campaigns in the Strzeleckis.

Strzelecki Ranges Bioregion Overview

Area Survey

Strzelecki State Planted Hardwood Tally

The Strzelecki Hardwood Reforestation Scheme

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