Misclassification of Native Forest as Plantation in the Strzeleckis - 2003
In no other Victorian State Forest has regrowth Mountain Ash and reforestation been re-classified as 'plantation'. 

 
Summary of Evidence Regarding Misclassification of Native forest as Plantation.
At present it is claimed that approximately 10,000hectares of hardwood plantation exist on public land in the Strzeleckis (6500 ha. on areas formerly vested in the VPC, and about 3500 ha. on areas formerly leased to APM).However, Mountain Ash reforestation carried out as part of the Strzelecki Reforestation Scheme, andareas regenerated after native forest logginghave wrongly been included in this tally. This is young, biodiverse regrowth Mountain Ash forest with a healthy native understorey, which in any other State Forest is defined as Native Forest. Classifying these areas as plantation contradicts what Government documents say were the intentions of both these activities.Some of these so-called plantations are in sites of botanical and zoological significance, adjacent to rainforest, in areas earmarked for reservation by the LCC.If all these areas continue to be treated as if plantation, there will be severe ecological repercussions in the Strzelecki Ranges, a bioregion already heavily depleted of native vegetation and used intensively for timber production.Please refer to Nature Conservation Review 2001 (Traill, Porter 2001)and The Strzelecki Ranges Biodiversity Study (Mueck S et al 2001) for scientific appraisal of the Strzeleckis reserve system, and recommendations for maintenance of biodiversity.


 
 

The Hardwood Reforestation Scheme

Hardwood reforestation first began on a small scale from the late 1940s in the Strzelecki State Forest, with larger scale activity beginning from the mid 60s.The aims of the hardwood reforestation scheme are summed up in the LCCís Final Recommendations South Gippsland Area District 2, 1982:"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". 

The need for reforestation in the Strzeleckis was recognized by the State Development Committee, which stated in the Royal Commission on the Outer Ports,1927that "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.)

The intentions then of the Mountain Ash reforestation were to restore forest to areas where forest had been lost, not to remove forest, not to have areas lose their native forest status, and not to replace native forest with non-indigenous species.


 
 

Logging of Mountain Ash forest and regeneration can not be claimed as part of the reforestation scheme as these areas were already natural forest.
 
 

The LCC Study demonstrates a degree of conflict when it describes the Eastern Strzeleckis.The LCC report praises the hardwood reforestation scheme for restoring forest to the Ranges, but elsewhere refers to the same areas as hardwood plantations. This perhaps reflects a disagreement about how to view the reforestation. This inconsistency in use of terminology was less important before the State Government decided to sell off its plantations. Once corporatised and then privatised, all except one of theìoptions for the future useî for this forest were removed.

Having to rely on Departmental data, the LCC itself was more than likely confused by how much of the area was reforested, how much was regenerated native forest after logging, how much was native forest all along andhow much was established solely as timber plantation, and this confusion was reflected in the report.

However, the LCC is very clear in its recommendation that all the forest (including Mountain Ash reforestation)ìbe maintained as reserved forest under the Forests Actî, and while the area would provide timber, due regard must be paid to  landscape values, recreation, conservation of flora and fauna and water values.This quote shows that ultimately, it was still legally regarded as native forest, and the LCC recommended it should continue to be regarded that way.


 
 

It is clear from the intentions and origins of the hardwood reforestation scheme, that it was established to restore Mountain Ash forestand was not a step towards the provision of short rotation timber plantations of non-indigenous species, that is being carried out at present.


 
 

Regenerated Nativeforest logging coupes misclassified as plantation.

From studying the Departmentís various publications, it becomes evident that the Mountain Ash in the Strzelecki State Forest was being logged at a rate of between 100 and 200 ha. per year since the 60s. References to this can be found in publications and records from the 60s through to the 90s. such as the LCC reports as well as timber industry publications such as ìStrzeleckis:a new look for the heartbreak hillsî

Most of these publications carry the assurance:"Forests are regenerated following harvesting".

Roughly then, between 100 and 200 hectares of native forest logging had been carried out in the Strzelecki State Forest per year. To date, this would tally up to many thousands of hectares.These areas are at present wrongly classified as plantation, as they are neither reforestation or plantation, but are in fact regenerated logging coupes.


 
 

The Timber Industry Strategy

In the mid 1980s, the TIS outlawed the practice of clearing native forest on public land in order to establish plantations. The ëTimber Industry Strategy GovernmentStatement, 1986í states ëNative forest values will be safeguarded as new pine and hardwood plantations are established on cleared landí.(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 forestimmediately prior to conversion This practice continued to recent times. These are serious acts of environmental mismanagement. By giving these areas official recognition as ìplantationî, the government is rewarding actions which rightly should be deserving of serious penalties.


 

Government Definitions of plantation and native forest:

All this Mountain Ash reforestation and regeneration (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 Regeneration, The State Government defines it as:"The renewal of forest by natural or artificial means" Clearly, the means by which regeneration is brought about about is irrelevant as to its status. It can be given any amount of human assistance, including hand planting of seedlings, and it still keeps its native forest status


 
 

Definition of native forestThe 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 in a State Forest.

The National Forest Policy Statementagreed 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. 

Areas sprinkle seeded, aerial seeded, seeded by hot burns or by seed trees, etc. also seem to be excluded by this definition. However, in the Strzelecki State Forest at present, every scrap of young Mountain Ash however it was regenerated, even logging coups which have regenerated without any human assistance at all, have all been labeled "plantation".


 
 

Intent:The definitions aboveprovide evidence to show that the regenerated logging coupes and reforestation in the Strzeleckis is not plantation.Intent also plays a part.The Departmentdescribesreforestation as ënative forest reforestationí.(see Mt. Fatigue Reforestation Plan, August 1989) ëReforestation 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 farmingí.(p.1)The Plan also states that it is ëDepartment policy to reforest areas only with trees that are native to the site.í


 
 

Flaws in Mapping Methodology

Maps of the hardwood ëplantationí areas in the Strzeleckis were not made available prior to the sale of the timber rights to Hancock Victorian Plantations.LEGL maps which had to be viewed on microfiche in Melbourne were the only available maps.It was impossible to know which areas on these maps would be included in the sale and which may be divested from the VPC.Many politicians argued for a delay in the privatisation until mapping was complete and could be scrutinized by the public.This did not happen.

After HVP bought the timber rights, they had to assess and map their hardwood plantations.They did this by comparing recent aerial photographs to logging history maps.The problem was that neither the maps nor the aerial photos provide any distinction between regenerated native forest logging coupes, reforestation or plantation establishment.

Young Ash forest shows up fairly distinctly in the aerial photos. Every bit of this was then incorrectly labelled as hardwood plantation. Logging history maps provided to HVP indicate where and when an area had been clearfelled and regenerated, and when and where pine plantations were established. HVP incorrectly assumed that all areas delineated by the dotted lines on these maps were plantation.

Other Evidence

The argument that many areas of Hardwood ìplantationî were once farmland is also flawed.

Of the 60,000 ha of public land in the Strzeleckis, only 28000 ha. was re-purchased ex- farm land. More than half of the public land, therefore has never been alienated, and never cleared for farming. Of the repurchased land, the areas which had been previously cleared, more often than not were converted to pine plantation. A proportion of this re-purchased land had always retained its original native vegetation, but much of this was also removed to make way for pines.

Patrick Morgan in ëThe Settling of Gippslandí explains that in the Eastern Strzeleckisearly ëfarmsí were not farms as we think of them today, but mere clearings in the forest. The forest closed over many of these small clearings without assistance.Some areas were only briefly leased to farmers, and not all areas were cleared.

On the whole, the repurchased ex-farm land was converted to pine plantations. Pine was the major plantation focus in the Strzeleckis. The mountain ash regenerationand reforestation is in the steep upper reaches of the Eastern Strzeleckis in areas which mostly were never alienated.

The Nature Conservation Review 2001 observed that,ëillegal 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.í p. 190

Botanists during the Regional Forest Agreement classified the reforestation and regenerated forestin the Strzelecki State Forest as Wet Forest.Final maps were altered , re-defining this ëWet Forestí as ìplantationî and lumping it in with Pine Plantation. This was a political decision and not a botanical one.This action seriously compromised the outcome of the Gippsland Regional Forest Agreement and augmented the serious skepticism about the Gippsland RFA process.This is anotherunresolved community issue.

Repercussions from Reclassifying Strzelecki Hardwood Reforestation and Regenerated coupes as plantation:

- reduces the amount of forest cover in the Strzeleckis rather than restoring forest, which was the stated aim of the reforestation scheme.

-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.

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

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

- sites of botanical and zoological signific ance, areas earmarked for reservation by LCC, areas of nationally significant reainforest are now leased to a plantation company.

- 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; Forest Management Plans; Sustainable Yield Review

- allowingtimber harvesting to operate under the less environmentally stringent private section of the Code of Forest Practices. This has taken away the right of nationally significant rainforest to have subcatchment protection and minimum buffers for other rainforest.

- allowingshorter rotation rates; and the planting of exotic species for the first time in parts of this forest.

Evidenceto show that not all the young Mountain Ash 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 by any of these parties to refute this.

Case Studies of Particular Forest Areas.

The following case studies show two forest areas in greater detail.Each areamay be seen as a microcosmof the Strzelecki situation.

1.Gunyah Forest

The forest area shown on parish maps as the Gunyah Timber Reserve 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, and contains nationally significant rainforest.A portion of this area is now contained within the Gunyah Rainforest Reserve. Clearfell logging in this area in the late 1970s received considerable public protest, media coverage and condemnation by the South Gippsland Council.The LCC recommended Section 50 reserves in theEast Morwell, Agnes, Franklin and Dingo Creekheadwaters.The Gunyah Rainforest reserve was created in 1986 after many years of negotiations.,but only protected a portion of the area.In 1997, the Victorian Plantations Corporation, loggedthe logging coupes from the 70s again,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 and areas of Cool Temperate Rainforest, and the remainder of the Gunyah Forest (not in the Gunyah Rainforest Reserve) is now managed by Hancock Victorian Plantations.

2.Woomera Creek Catchment

In December 1987, the Mt. Best Concerned Residents submitted areserve proposal to the Department, calledëOn the Future of the Regrowth Forest on the Southern Face of the Mount Fatigue-Woomerra Creek Ridgeí.The submission called for a flora and fauna reserve of approximately 750 hectares south of Devilís 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 areaówallabies, 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 naturallyoccurring regrowthon previously disturbed or abandoned areas.In 1989 the Department wrote the ëMt. Fatigue Reforestation Planí 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 furtherevidence 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 November1989, 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 heíd like meeting to avoid talking about logging and concentrate on reforestation, because any logging is ë80 years down the track if thatís a problem thení

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:ëIt (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 ëve all passed on, as to whether this will be part of the production forest or notí.ëDecisions for future generations....í

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

Mr. PridginëWhether that option is taken up or not is up to the future.And thatís been the same thing with every area in the Strzeleckis that we have bought back or resumed after people have walked off and reforestedí.

Tape 2 26/1/90Mt. 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. Thatís 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 islikely 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 weíve 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 youíll 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 wonít be just a complete sweep of Mountain Ash.Quite obviously, these northern aspectsnaturally 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 siteís southern aspectsthose willbe 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 Residentsreserve proposal was denied and the Department cleared and ëreforestedí 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 this forest is now leased to Grand Ridge Plantations.

All this evidence showing that not all the young Mountain Ash should be treated as plantation and the case studies demonstrate the complexities of generalizing about the Strzelecki hardwood ëplantationsí.Problems associated with the mapping, the definitions, the flouting of regulations, the intent of the reforestation scheme, the failure to factor in the regenerated native forest logging coupes, the fact that not all the area was cleared farmland, make it necessaryto be flexible and to rethink the attitude that these areas are solely for the timber industry.

It's best if we act on all these unresolved issues now, or they will continue to haunt us all.

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