Kim Devenish and Julie Constable
Complaints Regarding
Smartwood’s Assessment of Hancock Victorian Plantations and Subsequent Certification.
Dear Smartwood and the Forestry Stewardship Council,
We were very disappointed and alarmed that you have given certification to Hancock Victorian Plantations given the serious unresolved community and ecological issues in the Strzelecki Ranges component of Hancocks estate. The conditions you have created also do not address the issues which we will describe below, and the report itself has seriously downplayed particular issues, casting doubts on the methodology of the assessment and its conclusions.
Complaint 1:
There has been a serious downplaying of
the community support for a 30,000 ha. National Park in the Strzelecki State
Forest. This demonstrates a grave misreading of the
community’s expectations and poor scholarship.
The Report has failed to acknowledge the support for the 30,000 ha. National Park Proposal, ‘A Proposal for a 30,000 ha. National Park in the Strzelecki State Forest’, by Kim Devenish, Julie Constable and Alan Standering, This should have been described in section P2 ‘Tenure & Use Rights & Responsibilities’ and described correctly in P9 Maintenance of High Conservation Value Forest.
In the Section P2, there is mention of a historic train station and camping area on HVP land which stakeholders would like to see transferred to Government ownership and control. The proposed 30,000 National Park in the Strzeleckis has the support of 7,000 signatories to a petition tabled in the Victorian Parliament, and letters from many peak and local conservation groups and community groups. The support has continued to grow by email and letter since the petition finished. The implementation of this national park, involves public land being transferred from HVP to Victorian Parks Management. This has been omitted from this section.
We are particularly distressed by the serious misrepresentation of the National Park Proposal under P9 on p.22. This says that only one stakeholder group is advocating transferring part of the HVP estate to establish a national park. This is just plain wrong. Which group are you referring to here?
In Submission 1(from Julie) you were given a list of groups supporting the National Park Proposal. Did Smartwood make any attempt to contact these groups and include them in the stakeholder process?
The fact that these groups are included in Submission 1 should have alerted Smartwood to the wide ranging support from conservation, community and tourist groups in the area. This proposal has already been tested in the public arena, via the media, the petition, through the Gippsland RFA process etc. It has already been publicly acknowledged as having widespread community support.
This misrepresentation is an insult to the community which supports the national park proposal. These groups are constantly asking us for updates regarding the park, lobbying for the park when given the oportunity , funding the ‘Up into the Hills’ Strzelecki Forest Drive to promote the area for tourism and attending the rally in Melbourne against the privatisation of the Strzelecki State Forest and for a large national park in April 1998, and again in August 2003 etc.
The misrepresentation also demonstrates a lack of care in assessing reports already available to the Smartwood team and in selecting a strong stakeholder base.
To argue that 150 stakeholders, many of which probably (there is not list available in this Public Summary) represent industry viewpoints and people concerned about Pine Plantation Management throughout Victoria, outweigh a very public campaign for a national park comprising 7,000 signatures and numerous community groups is absurd.
The Gippsland Regional Forest Agreement Social Assessment 2000 conducted social assessments as part of the process. On p110 is states for the Yarram community, that it had a ‘desire to see a major National Park in the Strzelecki Ranges’. The West Gippsland Catchment Management Authority has also stated in Board Minutes that there is community acceptance of the national park proposal.
Here again is the list of groups supporting the National Park Proposal: Society for Growing Australian Plants (Leongatha), 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; Friends of Tarra Bulga National Park, Friends of Morwell National Park, Greening Australia, 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.
We also have a volume of letters from groups and individuals supporting the National Park Proposal which has continued to grow. We have about 33 letters, one of which was signed by 150 students at South Gippsland Secondary College in support of the national park. These are of course, only a proportion of the letters which have been sent to the Government or HVP in support of the park, but of which we do not have a copy.
Please note, that the Gippsland Greens and the Friends of Tarra Bulga National Park have asked the Government to establish a park system in the Strzeleckis in line with the Nature Conservation Review 2001 recommendation for a major new park system in the Strzeleckis, which would increase the reserve system by 45,000 ha. The Gippsland Local Government Network supported an enlarged park or reserve system as a tourist asset. The GLGN is a body representing the Mayors of six Gippsland Shires, and as such is an indication of the community’s views on this matter.
We offered archival information on campaigns for parks in the Strzeleckis dating back some decades. So far, no one from Smartwood has expressed a desire to see these documents. We have said that it would be essential to look at maps with Smartwood to show how the leased public land in the Strzeleckis is essential to meet bioregional reserve targets set by the Commonwealth and State Governments. All archival material relating to any facts stated here is available for viewing.
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We are very angry over the downplaying of the national park issue. The downplaying of this issue means that Smartwood has avoided the serious issue of the existence of major unresolved, or poorly resolved, conflicts within the local community which under FSC guidelines is an impediment to certification. The issue has not been addressed under the guidelines of Principle 6 Environmental Impact or Principle 9 Maintenance of High Conservation Value Forests. We would like to see Smartwood address this issue in the Report correctly and consider the ramifications for the overall certification decision.
Complaint 2: As in Complaint 1, the Tenure & Use Rights & Responsibilities section on page 20 has also failed to acknowledge the community support for the 7,500 ha. Core and Link reserve. The recommendation to the Government which has the support of HVP and many groups asked for a permanent reserve, which would raise the formal reservation of land in the Strzeleckis Bioregion from less than 2% to just under 5%. Formal reservation on public land requires legislation by State or Commonwealth Governments.. Permanent, formal conservation reserves relevant to this public land in the Strzeleckis include: Reference Areas, National Park, State Park, Flora Reserve. (from Appendix 9.5 ‘What is a reserve?’ West Gippsland Native Vegetation Plan (Draft June 2003)
It is also relevant to look at the support base for the Core and Link reserve proposal. It includes, of course the member groups of the Strzelecki Working Group: Friends of Gippsland Bush, Trust for Nature, Hancocks Victorian Plantations, South Gippsland Conservation Society, West Gippsland Catchment Management Authority. Support is also offered by groups supporting the larger 30,000 ha. proposal, and additional support came from Friends of the Earth, Field Naturalist Club of Victoria, Wilderness Society, the Gippsland Local Government Network, and Prom Coast Tourism. Most of these groups acknowledged that they preferred a larger reserve system, but supported the ‘Cores and Links’ reserve as an urgent priority. (We can provide letters of support if necessary).
We would like to see this issue addressed in the relevant sections of Smartwood’s report, in relation to Principle 2 Tenure & Use Rights; Principle 6 Environmental Impact, Principle 9 High Conservation Value Forests.
Page 4, lines 19, 20 and Page 6, lines 15, 16; Page 9, line 7 all suggest that all 32,500 ha of “custodial land” is somehow available for logging and that HVP are restraining themselves voluntarily. This is a gross exaggeration of the case.
the Ex VPC land
In the
Ex VPC part of their Strzelecki leasehold there is around 20,000 ha. that
everyone recognises as
non-plantation land. In
1998, the State Government prepared a breakdown of this land and it indicated
that only 4000 ha. was “theoretically available” for logging or
conversion to plantations. The breakdown is set out in a letter from Mr Peter
Ryan MLA to us in 1998, before HVP were even on the scene. The 4000 ha. of land
was zoned in such a way that the VPC, or later HVP, could theoretically apply
for a permit to clear and convert the areas. Whether that application would
have been granted is unlikely, as Victoria’s laws and rules regarding
conversions and native veg clearing have moved on since the zoning was dreamt
up in the early 80s. In fact, it was the alarm felt by the South Gippsland
community over the wholesale conversion of bush to plantation that provided the
trigger which resulted in Victoria’s change of policy toward conversion
in the mid 80s. As a direct result, the land zoned for conversion was never
converted and remained native forest even though the out-moded zoning may still exist in some form.
When Amcor’s land assets were added to HVP’s, a further 14,000 ha. (approx) of native forest and other non-plantation land in the Strzeleckis came under HVP management. Around 4000 ha. of this was on land which Amcor leased from the State, and the rest was on freehold. For quite some time now it has been acknowledged that in the Amcor managed parts of the Strzeleckis, areas suitable for plantation have already been made plantation. In the 90s, Amcor applied to clear or convert a further 2000 ha. of their land. Many groups and individuals in the community objected to the conversion and the local Governments involved asked the Planning Minister to make a decision. The Minister appointed an independent panel to examine the proposal and objections. The Panel found that Amcor’s applications were at odds with Native Vegetation Retention Controls and recommended that the applications be refused.
In Victoria, no native forest on public land can be converted to plantation. On private land, the native vegetation retention rules and the directive that plantations can only be established on predominantly cleared land serve to protect native forest and vegetation from conversion.
The 32,500 ha. of “custodial land” has been wrongly portrayed to appear to be some sort of magnanimous act on the part of HVP. The fact of the matter is that very little is theoretically available, and of that, HVP should fail to obtain permission to clear on most of it anyway.
The reason that this plantation company has so much native forest is because HVP hold the leaseholds over virtually all of the Strzelecki State Forest.
Complaint 4: We are concerned that there is not more attention paid to the ‘Nature Conservation Review 2001’ , which recommends a major park system in the Strzelecki Ranges Bioregion. Of necessity their recommendation for an extra 45,000 ha. of reserves must include some of Hancock’s leasehold on public land. There should be a clear commitment to biodiversity protection under this framework of biogeographical reservation. The biogeographical framework has been adopted by the States and the Commonwealth as part of the Regional Forest Agreements and by Catchment Management Authorities. ‘The Nature Conservation Review, 2001’ used this framework to work out reserve targets in the Strzelecki Ranges Bioregion. The West Gippsland Catchment Authority’s ‘Native Vegetation Plan’ has adopted this framework, and targets set for the Strzeleckis Bioregion in this Plan amount to an extra 25,000 ha. Please see Submission One.
Complaint 5: Opposition to the privatisation of the Strzelecki State Forest.
There is no mention of the community opposition to the privatisation of the Strzelecki State Forest. Please see Submission One. Again archival information is available for viewing.
Complaint 6 : Smartwood has failed to understand the significance
of the disputed 7,000 ha. of claimed hardwood plantation on the leased public
land for its ecological values and its importance to the community.
The Strzelecki Ranges Biodiversity Study (Mueck et al) acknowledges that these areas are functional native forest and that their potential to continue to develop naturally as native forest is seriously compromised by further timber harvesting and the planting of non-local species.
We provided pages of evidence demonstrating that these areas should not be defined as hardwood timber plantation under current definitions in Australia, as adopted by the States and Commonwealth under the Regional Forest Agreements. FSC guidelines state that the body seeking certification must respect national, local and administrative requirement s of the country of operation. We would like to read the FSC deliberations on this matter in order to make further comment.
The Public Summary ‘s definition supplied on p. 6 that ‘natural and semi natural forest’ are areas ‘where many of the principal characteristics and key elements of native ecosystems such as complexity, structure and diversity are present’ applies to the disputed 7,000 ha. precisely because the aims and intentions of forest management of these areas was to restore native forest or regenerate native forest after logging. That is why Mueck et al in the Strzelecki Ranges Biodiversity Study also found that these areas are functionally native forest. We have provided pages of evidence regarding these areas. Please refer to these again, and note that the original intention of the Mountain Ash Reforestation Scheme was to restore forest. This aim was reiterated in 1990 and the Department documented that all areas logged and regenerated or planted with Mountain Ash after removing other forest, was native forest. We reiterate, that we have ample documentation to support these claims which Smartwood needs to examine.
Page 6, Line 22 suggests that there is historical information and aerial photographs that define plantations. Is this information available? We have already in Submission 1 explained the flaws in the methodology of using aerial photographs to identify plantations, as it may be confused with regrowth forest or areas planted as native forest restoration. Regardless of whether these areas are considered HCVF they are in fact native forest and under Victorian Law may not be converted to plantation . Human assistance in regeneration, for example, planting and sowing have been acceptable methods for regenerating native forest in Victoria’s state forests and these methods are enshrined in the Code of Forest Practices for native forest regeneration. These local rules take precedence over FSC definitions. The local community was told in 1990, that these areas if logged at all,) would be on 80-120 rotation rates and that reforestation was native forest restoration using species native to the site. (Mt. Fatigue Reforestation Plan 1989) We can supply these references. The Plan also refers to the growing of the seedlings from seed at or close to the sites to be reforested.
Page 7, line 18-21 says that HVP is logging 270,000 cm of hardwood annually and most of this is occurring in the Strzelecki Ranges. Page 11, line14 elaborates that 255,000 M3 of Hardwood is cut from the Strzeleckis More specifically, Hancocks have informed us that most of it is occurring on the leased public land, that is, in the controversial 7,000 hectares. We find this distressing and unacceptable that forest is being logged at this rate, and that after logging is being planted with plantation species. This is not the place for intensive plantation logging. It is a remnant public forest, it is extremely steep with unstable soils, and the controversial 7,000 ha. are scattered throughout the last large tract of Wet Forest in the Strzelecki Ranges bioregion. Please note, that fragmentation of habitat has been listed as a threatening process under the Flora and Fauna Guarantee Act. Allowing the misclassified native forest to be treated as plantation has caused and is causing fragmentation of critical and significant habitat.
On Page 15 the Summary states that there were two key issues which received FSC deliberation. One of these was the definition of plantations in the HVP context. Why weren’t we asked to provide our evidence, our mapping archives and other documentation for this deliberation? We have important maps showing that areas now claimed as plantation are within Sites of Botanical Significance, Sites of Zoological Significance, in areas earmarked as reserves by the LCC, and areas the Department had indicated were native forest regeneration.
Please note too, that the Land Conservation Council in 1982 recommended that the Strzelecki State Forest, including reforested areas remain subject to the Forests Act and under public tenure. The summary acknowledges that across Victoria, logging of native forest on public land was reduced by one third to meet sustainable yield criteria. This figure in fact only applied to sawlogs. In Gippsland the reduction was 50%. The Strzelecki hardwood areas should have been subject to this review and undoubtedly would have had its yield reduced to a degree similar to the rest of Gippsland. Unfortunately , it was exempted from the review because of the leasehold arrangements.
On Page 17 of the Summary, the concern about using the Interim Standard for native forest certification in Australia is stated. Please note, that while the 7,000 ha. fits the definitions of native forest that it should be treated as such for the purposes of certification
This issue must be examined again.
This misclassification of native forest as plantation causes conflicts with FSC Principle 6.3 which says that ‘Ecological functions and values shall be maintained intact, enhanced, or restored, including a. Forest regeneration and succession, b. Genetic, species and ecosystem diversity and c. Natural cycles that affect the productivity of the forest ecosystem.’
There should be established conditions to protect the integrity of these areas or a moratorium placed on harvesting in these areas until a public investigation (as promised by the Victorian Government) occurs?. (The Victorian Government promised to examine all community issues raised during the Gippsland RFA. The misclassification of native forest was one of these issues).
We need to show Smartwood and the FSC the maps and historical documentation pertaining to these areas as requested in Submission One.
Complaint 7: Conversions since mid 80s
As Victoria had restrictions in place preventing further conversion of Native Forest to plantation since the Mid-80s, then, any conversions carried out since that are in contravention of these regulations.
As FSC standards choose 1994 as their cut-off date for conversion, any conversion carried out since then is in contravention of both State regulations and FSC guidelines.
As Page 17, lines 11 – 20 state, The FSC system requires that state laws and regulations must be complied with.
As such, conversions carried out since the mid 80s on land now managed by HVP must not be endorsed by the FSC.
We have clear evidence that at least 1000 ha. of land was converted into “Hardwood plantations” in the Strzeleckis since the mid 80s, as well as a good deal of additional land was converted to pine plantations post-mid 80s, and that this land was under native forest immediately prior to the logging and conversion operation.. (We are still waiting for a meeting with Smartwood in order to produce this evidence)
In the case of the Mountain Ash hardwood, as Reforestation the practice was allowable, but conversion was not allowed. In the case of pine, it wasn’t allowable at all, as radiata pine is unambiguously a plantation species.
There are 2 problems here:
- Some conversions were clearly in breach of regulations
- The rest was only allowable if these areas were reforested with local provenances (Mountain ash) and retained their native forest status. As all these areas have been re-labelled as plantation, and the native forest status has been revoked, then the decision to re-label these areas is in breach of regulations. The re-labelling of all the young stands of mountain ash reforestation and regrowth as plantation is proving to be the most unworkable aspect of the Strzelecki predicament.
For these areas, the FSC cannot endorse any land use other than managing it as native forest, or for the restoration of native forest.
The mountain ash reforestation and regrowth already is native forest, and no restoration is necessary.
The areas in question converted to pine, or to plantation eucalypt will need to be restored.
In addition to the areas described above, which are all whole coupes, there is the further problem caused by the VPC’s regular practice of expanding their plantations during their harvesting operations. This occurred across the State Forest and is well documented. (T Ealley, ‘Plantation Logging in the Strzeleckis’)
Each day that HVP log mountain ash and replace it with Bluegum and Shining Gum, they are further complicating the matter, and increasing their potential liabilities.
In the case of the areas of State Forest vested in the VPC and leased to HVP (which are the areas best understood by us) there are more than 1000 ha. of Hardwood land with one of the aove 2 problems, and a sizeable (ut unknown) amount of pine also.
In the case of the ex-Amcor leased state forest, and HVP’s freehold land, we do not know.
Supporting evidence. Here are a few of the forest blocks described below where these problems exist. the text is from a document we produced called “Area Survey” 1999, with data and input from Ian Hemphill from VPC and HVP. The Land Conservation Council (1982) and/or the later EVC (circa late 90s) classifications for these areas showed that there was native forest in areas now labelled as plantation. The text contains a lot of shorthand. For further clarification, access the whole document at http://members.dcsi.net.au/kimjulie
10
LOWER CARRAJUNG (Bodman
block)
200 or so hectares of the upper reaches
of Bodmans creek bordered by Bordens rd to the south and Carrajung road to the
north.
Amount of reafforestation: Areas accessible by Bordens and
Carrajung road have been bulldozed and now carry planted eucalyptless than 3
years old. The policy of not clearing native forest for plantations has been
ignored here. Nevertheless, the majority is undisturbed.
LEGL 1993 maps do not confirm some of
these claimed planted areas. (due to the newness)
LCC classified area as a mosaic of : 1a,
2a,3a, .
EVC classified area as: 17, 49
Gross area: 192.1 ha.
Nett area of reafforestation: 71.6 ha.
Hemphill Environmental Value
rating: M Dominant trees: MA / MG / YSB / MM
11. BORDENS ROAD
(Bodman block)
Moving South East from 10, South of
Bordens rd, 300 or so hectares of forest containing 30 or so hectares of pine
planted in 1985, a year after it became the rule not to replace native forest
with plantation.
Pines established within designated
hardwood zones.
LCC recommended that this area remain a
Hardwood zone. This inappropriately placed pine plantation now must be included
in the area to be considered for reserve status in order to link this area with
Grieg creek area (area 5)
LCC classified this area as 2b and 3b.
Gross area: 303.8 ha.
Nett area of reafforestation: 30 ha. of pine
Hemphill Environmental Value
rating: M/L Dominant trees: MG / YSB / MM
23a, b, and c AGNES
(Woorarra Block)
Around 3000 or so hectares of the Agnes
headwaters, taking in Woomera Creek and Dingo creek. The area is bounded by
(clockwise from north) Grand Ridge
road, pine plantation perimeter, private land perimeter, Woorarra road, pine
plantation perimeter, state forest southern perimeter, Toora - Gunyah rd.,
Gunyah reserve perimeter. Mount Fatigue stands in the south west corner.
VPC maps show around 20% of the area to
be planted Ash, often planted in long fingers. According to LEGL maps, much of
this was carried out in 1982, 1984, 1985, 1986, 1987, 1988, and 1990, and was
carried out on land that had previously contained native forest. This means
that the majority of these planted areas are by definition regrowth or
reforestation, as is the case in many other areas also. This area contains
extensive cool temperate rainforest , and is ranked among the most significant
sites in Victoria The area ia also notable for its mature blackwood forests,
mature and "over-mature" ash. The hilltop clearings of 100 years ago
are no longer apparrent. The activities of forestry during the 80s is far more
obvious.
The LCC over generalised by classifying
such large swathes of this block as 9b (previously cleared but grown
back) These hills were inhabited
once apon a time, but far from cleared. The terrain, weather and lack of
financial reward meant that large areas were left in peace.
The Agnes supplies the towns of Toora,
Welshpool and Port Welshpool with water.
LEGL 1993 maps indicate plantings between 1982-1990, making the majority of reafforestation between 9 and 16 years old.
Further information regarding this block and the true nature of the forest is available via taped meetings between the then forest commission and the community in 1990.
We have provided HVP with a great deal of this sort of evidence and spent a great deal of time explaining things to HVP representatives. Has HVP volunteered any of this information in the certification process?
We can see nothing in this report that discusses what to do with the areas converted since the mid 80s. This needs to be addressed, and once again we remind you that we have offered to show maps and discuss this very issue. We stress again, that name changing as a way of obtaining plantation resources should be viewed as immoral and illegal.
Complaint 8: High Biodiversity Core and Link Areas
We have already praised HVP for its support of the reservation of the high biodiversity ‘Core and Link’ areas and appreciate the temporary moratorium. However, until these areas become part of the formal reserve system, they will be at risk. Companies come and go and change their minds and the protection of the Core and Link areas must be made legally binding to safeguard the ecology of the area and satisfy community expectations.
There should be a clear condition in the certification document that these areas are exempt from timber harvesting for all time.
Complaint 9: Inadequate consultation with Kim Devenish and Julie Constable, authors of Strzelecki Blues: Mucking around with a State Forest 1997 and A Proposal for a 30,000 ha. National Park in the Strzelecki State Forest 1998 and problems with the certification process:
In our original registration as stakeholders, I made it clear that we felt it essential to speak face to face with Smartwood personnel to discuss our main concerns, and look at the large amount of historical documentation and maps showing anomalies between HVP’s claimed hardwood plantation areas and other maps and documentation.
We also offered the Smartwood team, access to a newspaper archive which demonstrates the community’s attitude to the privatisation of the Strzelecki State Forest, the National Park proposal and the inadequate consultation over what was to be called plantation and the way the forest was privatised without maps showing which areas were to be defined as plantation. We also offered other scientific reports, archival material on the history of forest campaigns in the Strzeleckis, volumes of correspondence, etc.
Smartwood did not avail themselves of this important information, nor meet with us to discuss these issues.
It wasn’t until late 2003 that Julie received a phone interview with Richard Donovan. We have pages of emails asking for meetings and complaining about the process. We were concerned about the lack of feedback on initial submissions and the problems and difficulties of communicating with Smartwood personnel. There is a lack of openess and transparency in the submission process. My submission was placed on Mr. Cadman’s website concerning certification, and yet no other group or Hancocks has taken the opportunity to share information and concerns. This makes it difficult to answer any points made in other people’s submission, check the authenticity of statements or raise issues concerning conflicting information.
Complaint 10: On page five, the report states that initial plantation establishment was focused on purchased and/or abandoned farmland. This suggests that areas used for plantation establishment only occurred on cleared land. It must be stated that much of the repurchased land was used to convert to pine plantations. Very importantly, not all the land that the Forests Commission managed (and logged) was repurchased or abandoned farmland. Approximately half of the Strzelecki State Forest was previously Crown Land.
A more precise and correct term for the purchased and/or abandoned land would be ex-leased and ex-freehold land in the Strzeleckis. History books and various reports say that farm land is misleading because much of this land was not cleared, many farms were small clearings in the forest and that after farmers walked off their land in the early years the forest regrew. We can supply these references.
Complaint 11: FSC Principle 6.10 states that ‘Forest conversion to plantations shall not occur in any area which has been recommended for protection’ . Please note that many of the areas which Hancocks claims are plantation and which we have disputed are areas recommended for Section 50 Reserves in the Land Conservation Council South Gippsland Area Final Recommendations, some are classified as sites of biological or botanical significance and should not be available for plantation purposes . ‘The Nature Conservation Review 2001’, has recommended that a major new park system be established in the Strzeleckis. While not specific in the areas to be included, of necessity HVP’s leasehold is necessary to meet the 49,300 ha. of reserves recommended for the Strzelecki Bioregion. We would like to see this addressed in the certification documents.
Complaint 12: FSC Principle 9 deals with the maintenance of high conservation value forests. The Strzelecki forests must be considered high conservation by this definition because of the nationally significant rainforest and endangered and/or rare species of flora and fauna. This forest acts as a refugia in a largely agricultural area. It also contains viable populations of most naturally occurring species in natural patterns of distribution and abundance. The forest contains many gullies of the threatened Ecological Vegetation Class Cool Temperate Rainforest and contains the headwaters of most of South and Central Gippsland’s rivers and streams.
Maintenance, presumably means not using these areas for logging, but also managing logged areas to the best standards for the maintenance of surrounding values, even if that means excluding logging in some cases.
‘The Strzelecki Ranges Biodiversity Study’ proposed a suite of recommendations for the maintenance of biodiversity, including the protection of Cool Temperate Rainforest and other endangered species. It is difficult from the Public Summary to know if these are going to be implemented by Hancocks. Condition 6.2.1 says ‘The Threatened Species BMP is to be finalized and put into practice’. We would like to have more input into this BMP and check its progress against other recommendations, and the Flora and Fauna Guarantee Act Action Statements. It would be hoped that to claim BMP HVP would need to adopt recommendations for threatened species on public land or better them on a local level.
Complaint 13: There should be additional Conditions regarding Forest Management.
At an Operations Meeting Hancocks
informed the SWG that they did not wish to adopt
the following recommended management prescriptions in The Strzelecki Ranges Biodiversity Study
- 250 metre buffer ‘no go zones’ around all Cool
Temperate Rainforest Isolates
- 100 metre
buffer ‘no go zones’ around all Strzeleckis Warm Temperate
Rainforest Isolates
- Minimum
buffers of 30 m. from centre of waterways, including the incorporation of a
strip of the closest trees, which may widen some buffer zones beyond the 30 m.
minimum level.
- Drainage
lines to have 20 m. buffer strips,
retaining trees.
- A minimum
buffer of 2000 m. around the
Spot-tailed Quoll record
- No harvesting
on slopes over 25 degrees
- The extension
of gully strips to ridge lines and widening them to retain eucalypts
- The planting of a mix of indigenous tree species,
especially for koalas in large areas that have recently been harvested.
- The planting of Mountain ash should be encouraged for any
replanting. Hardwood areas should
not be replaced by pine trees or any other non-indigenous species.
The Smartwood Public Summary has given HVP conditions to do with use of chemicals. However, we cannot see any mention of slope limitations, the planting of indigeneous species, ‘no go zones’ around Rainforest, buffers around threatened species. There is mention of improvements to filter and buffers around waterways, but not specific measurements. We would like to see the management prescriptions from the Strzelecki Ranges Biodiversity Study made a condition of certification. This study was funded by local Shires, WGCMA and is the major management practice study of recent times, dealing with particular local conditions in the Strzelecki Ranges.
However, as stated previously, a moratorium on Mountain Ash logging on leased public land should be implemented until the issue of native forest having been misclassified as plantation is resolved.
Complaint. 14: There is an error on Page 20. P2: Tenure & Use Rights & Responsibilities. The report says that ‘Prior public ownership of HVP lands complicates control of this, because users still think the land is public...’ Two thirds of HVP’s Victorian estate is leased public land. The public land is still public land. HVP do not have freehold ownership of the public land. They are leasing it.
Complaint 15 : We object to P10 p.26 which says that HVP has ‘a clear policy that it will not convert native vegetation to plantations’. As stated in Complaint , we have provided information in Submission 1 that shows that HVP is converting Mountain Ash forest into plantation, or has decided to call areas of native forest, plantation, and will convert these in the future. HVP has heard our arguments and cannot claim to be acting innocently in this matter.
Complaint 16: ‘Increased Demand’
p.10 line 20-22 states that the reduced sawlog harvest rates in the state resulting from the Sustainable Yield Review has placed upward pressure on expectations of volumes from plantation forestry in the region. HVP have expressed this idea to us on several occasions, presenting this as some sort of added obligation imposed on them to supply more in order to compensate for the reduction in wood available from other State Forests in Gippsland. However, there is no such obligation. The State Forest sawlog volume reduction was just that – a reduction. Compensation was to come in the form of Government restructuring funds, etc, not from increased and intensified logging from the Strzeleckis.
Complaint 17: ‘Infrastructure Land’
P. 6 Table states that there is 21, 639 ha. of ‘infrastructure’ land on their State-wide holdings. In the case of the Strzeleckis, we believe that HVP have over-estimated the proportion of “infrastructure” land in their forests and plantations, while under-estimating the proportion of Native Forest. In aerial photos, it is very hard to find any land that is not treed, save for areas recently logged. Tracks and roads are narrow and barely break the canopy. We are not equipped to come up with a more accurate estimate, but strongly feel that the current estimate is way too high.
Complaint 18: The Poor situation the Strzeleckis is in
p.14 lines 12-21 Outlines challenges and risks soil, slope, coupe size, koalas, catchment protection, etc. While recognizing these challenges and risks, the certification document is not setting conditions that directly address them. Size, timing and configuration of coupes is being left up to HVP to develop (P23).
there are no formal “protected forests or SMZs” (P7 lines 7-9 ) This is due to the leased SSF being exempted from the reserve process under the RFA. As stated on P9, line 14, there is no AAC, that is, no annual volume or hectare limits to what HVP can cut. As mentioned, the Strzeleckis was exempted from the 2002 Sustainability Review for Native Forest logging in Victorian State Forests. The proportion of the Strzeleckis protected in formal reserves is pitifully below Federal and State agreed targets and has failed and weakened the Regional Forest Agreement. The situation is grim. Every bit of progress Victoria has made toward wise use of forest has applied to all State Forests except the Strzeleckis, which languishes in a lasse-faire purgatory. We can see no conditions in the certification that directly help this situation.
Complaint 19: Illegal Logging
Page 20. The document is incorrect in its statement that illegal logging does not appear to be a major or systemic issue. HVP are aware of this problem, did they not inform Smartwood. For more information on this issue it would be best to contact the Morwell Police
Complaint 20:
Page 19, lines 33, 34 states that HVP is funding the FSC process in Australia. Does this compromise the FSC process?
Please could you give us the information about HVP’s donating of land to conservation groups. (page 26.)
If HVP is referring
to the Den of Nargun, Morwell, Birds Gully, Tyers, Bulga and Tarra Valley,
Mount Worth, Trraralgon South and Moe Lookout in its list of generous acts,
then it has an awful cheek because HVP had nothing to do with these land
donations and swaps, some of which date back 40 years when AMCOR was called
APM. Parks Victoria’s website explains the history of some of these areas
as follows:
Den of
Nargun (Mitchell River National Park):
Australian Paper
Manufacturers Ltd donated 143 ha to the State in 1963 to preserve the
environment. Glenaladale National Park was formed, and in 1986, additions were
made to create Mitchell River National Park.
Proclaimed in
1967, Morwell National Park is an area of natural beauty that is also suitable
for passive recreational activities. The park has regional significance as one
of the few remaining areas of remnant vegetation in the Strzelecki Ranges. The Billys Creek area was added to Morwell
National Park between 1989 and 1991 to provide a wider range of recreational
opportunities and a greater sample of the State’s natural environments
than were previously available in the Fosters Gully area.
Tarra-Bulga
...1,625 ha of some of the best examples
of original cool temperate rainforests of the Stzelecki Ranges. ...
The quality of the fern gullies led Alberton Shire
Council, in 1903, to reserve small areas of forest near Balook, and in the
Tarra Valley in 1909. Following recommendations by the Land Conservation
Council, the two separate national parks were joined through a land exchange
with APM Forests Pty Ltd. The enlarged and re-named Tarra Bulga National Park
of 1,522 ha was declared in June 1986.
Mt Worth
From 1970, the
Warragul Field Naturalists Club and the Shire of Warragul worked towards
reserving this area to protect some of the remaining indigenous vegetation of
the western Strzeleckis. In 1975 the State Government began purchasing land for
the park. (The park was gazetted in 1978)
Tyers Park is an area of 1810 hectares of forest in
the foothills to the north of the Latrobe Valley.
The park, which
was proclaimed in January 1986, encompasses the fine scenery of the Tyers Gorge
where the Tyers River winds between steep forested slopes. Outcrops of
limestone and conglomerate are of considerable geological interest. The limestone
contains both plant and animal fossils.
This
certification document appears to rely on too much self-regulation.
Complaint
23:
Most
conditions are somewhat broad and vague.
The rest are specific, but only pertain to a small number of single
issues. The document appears to
avoid specifically addressing a lot of important issues.
Complaint
24
There
does not appear to be any conditions pertaining to the treatment of native
fauna. HVP employ shooters to kill
the indigeneous Black Wallaby in the Strzeleckis. As far as we can gather, they are the only organisation shooting wallabies in any
State Forest in Victoria. They are
the only organisation in Gippsland with a permit to shoot wallabies and
according to DSE officer in charge of such things, they are the only
organization to have ever applied for such a permit.
Complaint
25:
Condition
6.2.1 pertains to endangered species and appears to be the only condition
dealing with native fauna.
Apart from requiring that HVP indicate the presence of endangered species on coupe maps, does certification provide for the protection of these species and their habitats in any way?
Complaint
26:
We understand that FSC is not anti native forest logging, but in the case of HVP who describe themselves as a plantation corporation and seek kudos on the strength of this, then FSC must seek clarification regarding the plantation corporation’s relationship with native forest. They are theoretically allowed to harvest native forest , but as HVP portray themselves as a plantation company, perhaps the corporation should be required to formally relinquish that theoretical right. Identifying areas of custodial land only goes part way towards this.
Additional Observations and Questions.
* Is it possible to view the names and interest of the 150 ‘stakeholders’?
* On page 15-16, the Summary says that in early January 2003, a decision was issued to certify the company. Should this read January 2004? If you meant to say January 2003, we wish to lodge another complaint.
Yours sincerely
Julie Constable and Kim Devenish, February 23 2004