Dailan Pugh, North East Forest Alliance, March 2011
This is a summary of our recommendations only. For full text of NEFA’s submission please go to http://nefa.org.au/wp-content/uploads/2011/03/NEFA_Submission_Australian_Forestry.pdf
1) The Inquiry needs to reassert that the establishment of comprehensive, adequate and representative reserve systems that satisfy the national criteria (JANIS 1997) is the primary requirement for Ecologically Sustainable Forest Management. The inquiry needs to recognise that the forest reserve system in north east NSW does not satisfy the national criteria. To improve compliance with the national reserve criteria and the North East Regional Forest Agreement it is requested that the Inquiry:
i) Report on the current shortfalls in attainment of the JANIS reserve criteria in north-east NSW and identify means of redressing gross deficiencies;
ii) Investigate the failure of the Commonwealth to ensure accurate and timely reporting on sustainability criteria and indicators; and
iii) Review compliance with all clauses of the RFA and identify actions to remedy failures.
2) The Inquiry needs to reassert that that the management of native forests on a sustainable yield basis, and within ecological constraints, is a fundamental requirement for Ecologically Sustainable Forest Management. The inquiry needs to recognise that public native forests in north east NSW are not being managed on a sustainable yield basis. In order to satisfy the RFA’s requirement to review sustainable yields in 2006, reduce commitments in line with timber reviews and cease unsustainable logging of native forests as soon as possible, it is requested that the Inquiry:
i) Investigate the failure of the Commonwealth to document, consider and account for identified criticisms of FRAMES wood assessments;
ii) Investigate and remedy the failure by NSW to annually report on actual versus predicted yields as required by the RFA;
iii) Investigate the expenditure of Commonwealth funds provided for the enhancement of FRAMES and long-term timber supplies;
iv) Investigate the decision to entrench and extend unsustainable logging for a further 5 years in contravention of the RFA, and for 3 years beyond the expiry of the RFA;
v) Investigate the failure of Forests NSW to satisfy current Wood Supply Agreements;
vi) Require an immediate independent review of the new FRAMES wood assessments that accounts for previous criticisms and specifically identifies the sustainable yield from native forests; and,
vii) Identify means of reducing the logging of native forests to a sustainable level as soon as possible.
3) It is suggest that the Inquiry consider the issue of public forest management arrangements and consider recommending separating policy and regulation from operations. Any such system would be enhanced by allowing members of the public third party appeal rights.
4) The inquiry needs to recognise that forestry operations can and do have significant impacts on inadequately reserved, rare and endangered ecosystems. In order to appropriately protect inadequately reserved, rare and endangered ecosystems, it is requested that the Inquiry:
i) Require the identification of the reservation status of all forest ecosystems in accordance with the RFA;
ii) Review the management arrangements for values protected in informal reserves and by prescription;
iii) Review the poor management of forest ecosystems intended to be excluded from logging; and,
iv) Identify appropriate management arrangements for each inadequately reserved, rare and/or endangered ecosystem.
5) The inquiry needs to recognise that forestry operations can and do have significant impacts on a range of native plants and animals and that many current prescriptions are inadequate and inadequately applied. In order to appropriately protect nationally rare and endangered plant and animal species, it is requested that the Inquiry:
i) Identify the reservation status of all nationally threatened species;
ii) Engage appropriate experts to review the adequacy of prescriptions applied to safeguard threatened species in logging operations; and,
iii) Review the application of prescriptions in logging operations and identify means to improve their implementation.
6) The Inquiry needs to recognise that forestry operations do cause soil erosion and do have a significant impact on streams, and that Forests NSW go out of their way to avoid external regulation and the application of Best Management Practices to protect stream quality. To ensure the application of best management practices to minimise the impacts of forestry operations on soil erosion and streams it is requested that the Inquiry;
i) Engage appropriate experts to identify performance standards and review the adequacy of prescriptions applied to safeguard streams and water quality in logging operations;
ii) Ensure independent regulation by requiring application of Environmental Protection Licences to all logging operations;
iii) Ensure that Forests NSW comply with the requirement to assign FMZ8 areas to the appropriate protection zone; and,
iv) Identify measures needed to improve compliance with requirements.
7) The Inquiry needs to recognise that logging has significant impacts on water yields from native forests, such that:
i) Reduction of mature and oldgrowth forest to younger growth stages will cause a significant reduction in water yields;
ii) Water yields will increase with increasing forest maturity; and,
iii) Logging should be excluded from significant water catchments.
8) The Inquiry needs to recognise that Bell Miner Associated Dieback is a significant threat to native forests and that appropriate management involves:
i) Identifying and mapping all affected and susceptible areas;
ii) Placing all affected and susceptible areas under a logging moratorium until such time as appropriate management responses that maintain ecosystem functioning are identified; and,
iii) Undertaking rehabilitation works (i.e. weed control) in affected stands.
9) The Inquiry needs to recognise that logging has significant impacts on carbon storage in native forests, such that:
i) Reduction of mature and oldgrowth forest to younger growth stages will cause a significant reduction in carbon storage in forest;
ii) Carbon storage will increase with increasing forest maturity;
iii) Large trees are particularly important for carbon storage; and,
iv) Forests should be managed so that they are carbon sinks.
10) The Inquiry needs to recognise that NSW’s Wood Supply Agreements distort the hardwood sawlog market and are for excessively long periods. The Inquiry needs to recommend that every opportunity should be taken to reduce the volumes committed and reduce the length of the agreements.
11) It is requested that the Inquiry recognise the market distortions and lack of transparency caused by NSW’s amalgamation of plantations and native forests for resource allocation and reporting and recommend separate reporting of native forests.
12) The Inquiry should recognise that the accreditation of timber being obtained from north-east NSW’s forests as coming from ecologically sustainably managed forests and legal sources risks Australia’s international reputation and credibility of its accreditation programs.
13) The Inquiry needs to recognise that forests have both use and non-use values that need to be taken into account when identifying the costs and benefits to the community from use of public forests. Use values include timber, water supply, carbon storage, recreation and tourism, all of which are usually compatible except logging. Non-use values include aesthetics, wildlife, ecological function value, option value, existence value and bequest value.
14) The Inquiry needs to acknowledge that logging of public native forests in NSW does not pay a resource rent to the community and is operating at a considerable financial loss. It also needs to be recognised that costs are rapidly escalating and timber volumes declining. The Inquiry needs to identify means of removing public subsidies to the timber industry and returning a resource rent to the community from the commercial use of public resources.
