Tasmanian Special Timbers Alliance P.O.

Box 105 Kettering Tasmania 7155

Members of Tasmanias Legislative Council

Re-Durability Report and Special Timbers

Dear Legislative Councillors, Nothing would please me more to be able to support this durability report, the Governments response to its deficiencies and subsequently the continuation of the legislation. I would also like to be able say that since the passing of the TFA legislation earlier this year that there has been good progress made in resolving the issues I have highlighted to you all regarding Special Timbers (ST). I would also like to be able to report I have found a new way to make pigs fly. Unfortunately this is not the case. Before you all put this aside and groan thinking "not bloody special timbers again", I would urge you to continue reading - I will try and make it interesting. What has happened and continues to happen with the issue of ST and the forest agreement can only be described as a calculated, intentional strangling of a strong and vibrant industry sector with the direct intent to shut it down. I will not mince words here because this is exactly what is occurring.

The Durability report and special timbers The Tasmanian Forests Agreement 2012 clause 41 states;
41. The Signatory Council will provide a durability report to governments, to demonstrate that implementation of the commitments in this agreement, both by Signatories and governments are progressing well, prior to the tabling of the initial Protection Order, and again before any subsequent permanent legislative reserve orders.

According to clause 42 of the Tasmanian Forests Agreement the durability report must take into account a range of issues including the ability to achieve wood supply commitments agreed to by the signatories and government. Clause 42 specifically states;

42. All elements of this agreement should be reviewed as part of each durability report, with key elements to be considered including progress with recognition of the agreed vision in legislation, implementing the reserve gazettals; achievement of wood supply commitments including specialty timbers

If the durability report is not accepted by either house legislation is repealed. In accordance with the legislation, a ministerial appointed special council was convened to come up with a special timbers plan for the future and the Federal Government has allocated $2 million to achieve this goal. Signatories have advised this process will take 2-3 years to finalise. In the interim, the TFA prescribes in clause 4 that until the Clause 9 process is completed, the annual supply of special timbers are to be in accordance with the FT 2010 Special Timbers Strategy. The FT 2010 Special Timbers Strategy set a supply target of a minimum of 12,500 cubic metres of category 4 and utility grade logs with the following breakdown by species; Species Blackwood Silver Wattle Myrtle Sassafras Celery top pine Huon pine King Billy Volume (cubic metres) 10,000 500 500 500 500 500 Arisings only

Table 2. Annual supply targets for special timbers millable logs (Cat 4 and utility) for the tenyear period to 2019. FT Special Timbers Strategy 2010 Over the past 6 months we have consistently heard from industry experts, the forest manager in Legislative Council committee hearings and most recently the resources Minister in an estimates hearing (June 5th) that the supply target of 12,500 cubic metres cannot be met given that the areas set aside for special timber production under the agreement cannot provide this volume. In fact FTs own analysis in February this year showed that only 600 cubic metres combined for celery, myrtle and sassafras could be achieved with the reserves as they stood. The Specialty Craft and Timber Zone Although this area was mentioned several times during the agreement, it did not make it into the legislation. The SCTZ was a very specific size of 37,954 hectares and was to be an area available purely for special timber selective harvesting. You would think that it would be easy to get a map for this important area but it is not available - even under RTI. Also not available under RTI are answers to the following questions regarding this area;

1. What are the predominant species in the areas chosen 2. What is the forecast sustainable harvest of special timbers by category, species and estimated volume for each area 3. Have any of the areas been ground proofed and if so by whom and when? 4. Who conducted the modelling to chose the SCTZ 5. Have any of the SCTZ areas been previously harvested? Pretty simple queries I thought. As it turns out and according to FT, the SCTZ was chosen without any FT input by the TFA Signatories. Conveniently, the modelling used by the signatories to choose these areas is not subject to RTI. The modelling used to choose these and the Schedule C coupes was also meant to be tabled in the legislative Council with the Durability Report but has not been seen. From Hansard 16th April 2013;
Mr FARRELL - The House will get the information on this matter in the first durability report to be provided by the special council and tabled with the first proposed reserve order. Members can then judge the issue at that time together with all other durability issues

The Schedule C Contingency areas Now the plot thickens. In an effort to appease upper house MPs concerns on special timber supply and to allay the fears of the special timbers sector, the Government introduced 24 Special Timbers Contingency areas totalling just over 10,000 hectares the so called Schedule C coupes. When speaking of these areas in parliament earlier this year the Resources Minister, Mr Green called the Schedule C areas an insurance policy and they were similarly referred to as such in the upper house. Although FT acted in a consultancy capacity with regards to these areas, the final boundaries for these areas were chosen by the ENGO signatories. After a number of drawn out RTI applications, the truth about the Schedule C coupes has come out. The size of the coupes had been inflated with FT advising that of the 10,000 odd hectares in these areas, only approx 4700 hectares were actually possible special timber areas. On ground investigation has shown that some of these coupes have been harvested as recently as 2010 and have been re-sown as monoculture eucalypt. Other coupes contain large areas of button grass plains with no trees at all and whilst some of the coupes do contain special timbers, it is certainly not anywhere near the quantity or quality required to supply the industry and be our insurance policy. A further RTI has been submitted requesting clarification on what is in these areas, how much has been harvested etc. I would like to discuss a few of the contingency areas in particular to highlight what I would consider to be a major problem. Well briefly have a look at WE25S, WE26S and BF19S.

Here is a satellite picture of a part of WE25S contingency coupe. The white outlined area is as per official maps of the coupe shown below this photo.

In the map above the area outlined around WE25S is part of the special species contingency area.

Below is a picture taken a few weeks ago in this coupe.

WE25S contingency coupe. The re-growth is eucalypt 1-2m tall. The coupe boundary is the taller trees in the background This is not just a one off. Just to the north of this coupe is another portion of WE25S and guess what yep thats right, harvested again in 2010 and re-sown with eucalypt. The white boundary in the satellite picture below was obtained through image overlay of the official FT maps.

WE25S northern smaller coupe area map

Picture taken of WE25S northern section from the top of the landing. Again like the lower coupe, this only contained re-growth eucalypt. Wheres the special timbers?

I personally visited these coupes after receiving official maps under RTI in August 2013. A video of showing the quality of special timbers in the WE25S coupe as well as the nearby WE26S coupe can be viewed at http://youtu.be/lRKbOSlT24E

Interestingly the government was advised by FT in February this year in an email discussing the Schedule C coupes that these; Derwent Coupes (WE25S and WE26S) will add little or nothing to the supply of Special Timbers Below is a satellite picture from BF19S, the largest Schedule C coupe at approx 3,800 hectares. Note the large un-forested areas and the harvested/regrowth areas. Independent analysis of this coupe corroborated FTs own advice that only approx 30% of this coupe may contain special timbers. Why was it inflated to such a large size? Other coupes contain similar issues.

Northern half of BF19S

I find it somewhat interesting that the Upper House MLCs were denied a briefing by FT on these areas during the debate on the bill on the 16th April 2013. Despite asking the government more than 10 times for a briefing to ensure that what they were debating and about to pass into law was accurate, the Government denied the request in an unprecedented move I wonder why. I would like to offer an open invitation for all members of the upper house to come with me to these coupes and see first hand the level of deception that has occurred here. If these coupes have been placed before the parliament with full knowledge that they did not contain special timbers then we have a serious problem.

The Taylor amendment This amendment to the TFA bill was proposed by MLC Adriana Taylor as an insurance policy (on top of the Schedule C insurance policy) for the special timbers sector. It was quite evident to upper house members from evidence supplied during the committee process by FT and other experts that the areas initially set aside under the bill for Special Timbers production (both the original areas and the 24 Schedule C Contingency coupes) could not provide enough timber for the industry or meet the Clause 4 agreed supply commitments. The Taylor amendment allowed for the harvesting of special timbers from basically anywhere in the state on a tread widely tread lightly policy including harvesting in reserves. There is a fairly length process to get to utilise this amendment but it is there nonetheless. The amendment was passed unanimously and the leader of the Government in the upper house, Craig Farrell stated on Hansard (16th April 2013);
In relation to the government's position, the government is prepared to support this amendment and I am advised that the signatories also support this amendment. Unknown to Upper House members at the time (and it would appear Mr Farrell included), the government and the signatories had no intention of supporting this amendment at all and it could be argued that the house may have voted differently or introduced further amendments if this deception was made apparent at the time.

In the lead up to the final lower house debate, the signatories sought and were given assurances in writing (the infamous 21 point Implementation Assistance Document) that the Federal and State government had no intention of allowing logging under the Taylor amendment to ever occur. We have also seen FT, the normal manager and harvester of ST advise publicly that they will not harvest in the future reserve lands (where the Schedule C coupes are) and that basically they are not interested in harvesting special timbers as it could impact on the achievement of FSC if they log in controversial forests. This is despite one of the current signatories to the TFA (and ex FT manager) Hans Drielsma stating in 2010; Myth: FSC does not certify native forests. FACT: Quite the contrary, FSC was originally set up to promote sustainable forest management of natural tropical forests, and certifies natural forests around the world. FSC also certifies old growth harvest and clear felling operations in many parts of the world. The Canadian boreal forests are a good example, where it is reported that one of the largest clearcuts in the world is found in an FSC certified forest and where harvesting of old growth, including variable retention, is also FSC certified. Source FT Branchline June 2010. The Governments response to the durability report goes so far as to place geographical limits on this amendment by limiting it only to the future reserve land. Are there any special timbers there? Who knows.

Special Timbers and the FT 3 year wood production plan On the surface and if you believe the governments response this week to the durability report, FT will be able to provide nearly all of the required quantity of special timbers this year 10,600 cubic metres of the required 12,500 cubic metres. Pretty close you may say but lets delve a little deeper here. The 3 year wood production plan contains approx 1000 coupes. Of these coupes, 141 will be targeted for specialty timbers. Of these 141, only 3 will be selectively logged and a further 12 will be harvested by group selection targeting specialty timbers the remaining coupes will be clear felled or similar. The special timbers target of 12,500 cubic metres is the volume for Category 4 sawlog and utility sawlog it is not for out of spec logs (Source FT Special Timbers Strategy 2010). The figure of 10,600 cubic metres is not broken down any further and when I asked FT to provide advice on this last month I was advised; it is not possible to predict the proportion of Cat 4 because of the low volumes cut for most species and the very high variability in quality of the timber that is accessed in a particular year. For example, in 2012/13 158 cubic metres of celery-top pine was sold, of which 29% was Cat 4, 5% was utility log and 66% was outspec. In 2013/14 these percentages are likely to vary markedly, depending on the quality of the trees that are harvested. Whilst being overly simplistic, if we applied these rates to the current harvest forecast of 10,600 cubic metres it paints a pretty bleak picture. Many coupes in the 3 year wood production plan that have special timbers in them are not old growth coupes that would contain age appropriate special timbers yet they will be harvested anyway and wasted. So I would strongly suggest that the volumes of millable special timbers will actually be well below the 10,600 cubic metre figure. FTs own schedule for special timbers earlier this year only had an estimated celery top pine harvest of 130 cubic metres this year and 115 the following year. Sassafras was similarly constrained.

The Dilemma The government and the signatories now find themselves in a dilemma of their own making; Both parties allowed special timber production areas to be chosen that contained no appreciable quantity of special timbers; The signatories did commit under the TFA to supply special timbers at a figure that is completely unachievable from the reserves they chose for this exact purpose.

Both parties publically supported legislation to allow harvesting under the Taylor amendment but privately have assured each other they will not allow this to occur.

So now there is a serious question surrounding durability with respect to wood supply commitments. The areas that the signatories chose for special timbers production cannot sustainably supply enough timber for the industry so durability cannot be achieved and the bill should be repealed. Was this intentional? Hard to say but heres a quote from a joint submission by ACF, ET and TWS from 2011; "Appropriate mechanisms would need to be put in place to ensure limited extraction of native forest specialty timber species to supply this industry (ST industry). At the same time it is imperative that in the long term ways are found to develop plantation derived specialty timbers. As subsidised native forest timbers cease to become available, the farm forestry sector will have greater incentive to innovate and commit to long term small scale investment in specialty timbers. It is also important to support the positive branding of plantation timbers as specialty timber products that can be used in high value applications." Plantation Celery top anyone? I would consider that those responsible for choosing the special timber production areas under this agreement have either done so for a reason or a completely incompetent in this area. Conclusion I would ask a simple question at this stage. What would FIAT or TA Ann say if their agreed wood supply was reduced by 20% or 30%? Would the agreement be durable? Of course it wouldnt be. They would not accept it and would likely call on the parliament to rightly do something to remedy the breach of durability. The agreed supply of some of the non-blackwood special timbers have been over 70% below the agreed volumes and are forecast to be into the future. The $2 million study into special timbers will not magically find additional areas of special timbers as they have all been reserved. This once iconic industry is now struggling with negligible supply, skyrocketing raw material costs and we are being left to scrounge dubious quality wood from dams to survive all because of politics and ideology. The agreement clearly fails to meet the agreed wood supply commitments for special timbers thus durability is not met. Why should a breach of durability in the ST arena be treated any differently than a breach of durability for sawlog or peeler billets? Are not all durability failures equal? Whilst you all may have different views on the TFA you all share a common thread of honesty and what is right and wrong. What has happened to the specialty timber sector is just wrong, dishonest, sneaky, uncaring and selfish.

To re-quote the ENGO signatories from earlier; "Appropriate mechanisms would need to be put in place to ensure limited extraction of native forest specialty timber species to supply this industry (ST industry). I would suggest the mechanisms are firmly in place wouldnt you?

Yours sincerely

Andrew Denman President Tasmanian Special Timbers Alliance 28th August 2013

PS If anyone would like a copy of the Google Earth .kmz file on the special timber coupes which show FT map overlays and coupe boundaries please email me at andrew@denmanmarine.com.au. It will allow you to view satellite imagery of all Schedule C coupes.