I have read the Draft Position Document (Policy Revision Process for the Certification of Large Tree Monoculture Plantations FSC Responsibilities. Forest Program of FoEI).

I support the Position Document, as does our Forest Collective in Melbourne, however FoE Australia does not have a position on the document as yet.

FoE Australia is a member of FSC and sees FSC as a means to improve forest standards in Australia. Australian forestry is amongst the worst in the world, with export woodchipping of old growth forests continuing unabated. The ENGO sector in Australia is however split on the issue of certification with the most influential forestry groups in the country opposed to FSC occurring in native forests due to their campaign goal of shutting down all native forest logging. FSC has therefore been relegated to occur only in plantations on interim standards. The entire FSC process in Australia is in danger of collapsing, with plantation companies currently banding together to fight against moves by FSC to increase the number of chemicals currently listed as prohibited under FSC criteria. FSC certified plantation companies are attempting to create their own plantation standard and will ditch FSC on mass if the prohibited chemical list is increased to add amitrole, alpha-cypermethrin, dicamba, haloxyfop and hexazinone (amongst others). Australian plantation companies are still fuming that Simazine is not allowed to be used under FSC guidelines and attempts at a derogation for its use have been thwarted.

Australian FSC Plantation Issues

Currently 5 plantation companies operating in Australia are certified by FSC. Albany Tree Plantations (bluegum plantations - Western Australia), ITC (bluegum plantations - Western Australia and Victoria), Timbercorp (80,000 hectares - bluegum plantations in Western Australia and Victoria), Hancock Victorian Plantations (primarily radiata pine (160,000 hectares) and eucalypt reforestation (15,000 hectares) in Victoria) and 58 hectares of reforestation has also been certified by FSC in Briar Hill Tasmania. Most plantations in Australia remain uncertified by FSC, with some being certified under the weaker Australian Forestry Standard which effectively has been boycotted by all ENGO's in Australia due to its poor ecological and social criteria. Almost all of the FSC certified bluegum plantations have been established on already cleared pasture/farmland, with most of the plantations being established since1996.

Ecologically speaking, the main issues concerning certification of the newly planted bluegum plantations in Australia; are water usage by plantations and aerial spraying regimes of pesticides. (Tree plantations in areas of 800mm rainfall, will generally use about 2 million litres (ML) of water per hectare per year more than pasture, meaning that a 20,000 hectare plantation will consume about 40,000 million litres more water per year than pasture. Therefore locations for plantations are of utmost importance. Plantations located in areas of high salinisation can effectively lower water tables if grown in recharge areas, meaning that positive environmental outcomes can occur if strategic planting occurs. 100,000 hectares of land each year in Western Australia is impacted by salinisation. In Victoria salinisation costs the Victorian Government $500 million per year. However strategic planting has not always occurred due to bluegum companies wanting to buy whatever land they can get their hands on, regardless of whether it occurs in a recharge area or not. Bluegum plantations grown in the wrong location can actually worsen salinity in some instances by decreasing stream flows).

Social implications with new plantations have included dislocation of some small farming communities and problems with aerial spraying. The West Australian government placed a moratorium of the aerial spraying of the insecticide dimethoate in tree plantations in 2000 due to concerns by local residents and business owners. Concerns are still occuring with eucalypt plantations in Western Australia and recent discoveries in Tasmania highlighting concerns, particularly with the insecticide Alpha-Cypermethin which is toxic to freshwater species at four parts per trillion, have made national news.

Spraying of plantations and subsequent pollution of drinking water with the herbicide Atrazine has been an issue in Tasmania since 1994. One of the worst examples being pesticide tainted runoff wiping out oyster farms in eastern Tasmania in 2004. Tasmanian's have also been concerned about rural dislocation and contamination of drinking water supplies by plantation companies. No large plantations have been certified by FSC in Tasmania. The plantation backlash has also started in Victoria, but the worst offenders appear to be companies not certified by FSC. Sporadic plantation concerns have occurred in Victoria since the 1970's with the aerial spraying of 2,4,5-T. Hancock have received a fair bit of criticism due to their logging of high conservation value areas in the Strzelecki Ranges in south east Victoria. The only positive result we have seen in Australia in regards to FSC is an end to the use of Simazine by plantation companies (http:www.hancock.forests.org.au).

AUSTRALIAN ENGO CONTEXT

Some Australian ENGO's with influence and funding come from the perspective that they oppose all forms of native forest logging. This no native forest logging ideology was first esposed by The Wilderness Society (TWS) in 1990. Australian Conservation Foundation followed this position in 1996 after TWS members were voted onto the ACF board. FoE and WWF* and smaller regional groups, do not necessarily support the No Native Forest Logging (NNFL) position and there is a fair amount of 'bad blood' between ENGO's who support limited amounts of native forest logging and those who advocate NNFL. NNFL is entrenched in groups like The Wilderness Society and Australian Conservation Foundation due primarily to the uncontrolled logging of old growth forests by State Government's and companies associated with the export woodchipping industry. NNFL's believe that only plantations can supply the export woodchip industry with the fibre it currently sources from old growth and regrowth native forests. The Australian Greens are also vocal on the NNFL issue, with most support for NNFL coming from the Victorian Greens and Tasmanian Senators Bob Brown and Christine Milne. Therefore with these groups opposing any form of logging in native forests, the only available option for the forest industry is plantations. Such is the situation of bad blood between the conservation sector over this matter, that Greenpeace has refused to get involved with forestry issues in Australia, except for a tree sit that they helped set up in Tasmania with The Wilderness Society in 2004.

(*WWF generally have a bad reputation amongst ENGO's in Australia that work on forest issues. WWF are seen to be aligned with government and business. This poor reputation has 'weakened' support for FSC by ENGO's, some of whom see FSC as just another WWF front).

Therefore, most ENGO's in Australia have actively been promoting plantations as a means to stop native forest logging. In my view this stance is fundamentally flawed. Groups supporting the plantation industry refuse to get into dialogue about chemicals used in plantations and social issues concerning plantations. They remain fixed on their ideological goal of stopping all logging in native forests. What occurs in plantations is pretty much a non-event for these groups. Groups such as FoE that are trying to promote a more holistic ecological view, a given short shrift by groups supporting No Native Forest Logging. It also appears that Australian ENGO's have been influenced by events in New Zealand, where the government in New Zealand stopped logging in native forests in the late 1990's. Almost the entire New Zealand forest industry is now based in plantations and argueably the influence of the New Zealand plantation industry has had global ramifications in influencing policies within FSC. A large percentage of plantations in New Zealand are FSC certified.Some ENGO's in Australia, use the New Zealand model as one that they would like to see emulated in Australia.

There is also emerging in Australia a small but vocal debate voicing concerns about plantations. Some see no place for plantations in the Australian landscape and are 100% opposed to any form of plantation certification due to plantations not being managed under ecological and social criteria. Some of these people have personally been effected by pesticides contamination and others impacted by the social dislocation that occurs when plantation companies move into rural communities and displace 'traditional' farming communities. There is some networking occurring on an informal basis with groups opposing plantations and this movement will grow as more communities have plantation companies move into their areas. There appears to be support for these campaigns by ENGO's such as the National Toxics Network and FoE, however these social and health arguments have not found fertile grounds in groups that support NNFL.

FSC in Australia

I regards to ENGO's, FSC currently has about 4 member groups; WWF, FoE Australia, Rainforest Information Centre and Friends of Gippsland Bush.

There is no national initiative for FSC. Groups met in Canberra in 2002 to try and reach agreement for a national standard. An economic, social and environmental chamber were tentatively formed. Both the economic and social chambers said that FSC would not work in Australia unless it also included native forest logging. The environmental chamber could not reach consensus over the native forest logging issue. The FSC meeting gave the environmental chamber 6 months to work out where it stood on the native forest logging issue. The environmental groups met again in September 2002 to work on this issue. The Wilderness Society, led by Alec Marr, and Tasmanian Greens, led by Christine Milne, actively stated at that meeting that they would not support any form of certification in native forests. Consensus could not be reached. Therefore in Australia there is no national initiative and the ENGO's have effectively opened the door for FSC only to occur by interim standards in plantations. In terms of ENGO's actively working on FSC issues, only WWF, Friends of the Earth Melbourne and Friends of Gippsland Bush have been involved in the process. Noone is funded to work on FSC issues in Australia from an ENGO perspective. Groups like the Wilderness Society and the Greens who have pushed for FSC only to occur in plantations have not in any way worked at getting solutions to plantation management problems in Australia via the FSC. They basically have swept the entire issue under the carpet.

Plantation companies working against the interest of FSC

Much of my work has been looking at the logging activities of Hancock Victorian Plantations. Latest information can be found at;

http://www.forest-network.org/Docs/amis_fsc_05-04.htm

It appears that Hancock is currently trying to water down FSC standards. There have been a myriad of problems associated with Hancock's FSC operation in the Strzelecki Ranges. Many conditions have been added to the certification and it could be argued that Hancock continue to snub their nose at the process. This can be explained by the fact that moves towards FSC in Hancock were adopted by their US based owners, due to pension holders in the US demanding FSC certification. Hancock's operations are 60% owned by Teachers pension funds in the US. It was their influence to only invest in an FSC certified company that was the main pressure of Hancock to adopt FSC in Australia. The Australian managers certainly did not want FSC and have reluctantly been made to adopt the process. I believe that key forest managers in Australia are deliberately attempting to lose the certification as a means of “getting the monkey off their back”.

In recant weeks there has been much concern about the banding together of Australian and New Zealand FSC certified plantation companies to counter the recent Pesticide Action Network's UK review of the FSC's plantations policy. It would be fair to say that these companies have been more than horrified to learn that many of the pesticides that they currently use are now possibly going to be added to the FSC's prohibited chemicals list. Of particular concern are the possible prohibition of; amitrole, alpha-cypermethrin, dicamba, haloxyfop and hexazinone. The plantation lobby in Australia has also been non-pleased with their failure to get a derogation through FSC for the use of simazine. Arguments from the plantation sector are now saying that if FSC prohibits the use of these chemicals there is no possible way that their industry would survive and that as a 'block', they will all leave FSC and work on a new certification standard based on New Zealand and Australian conditions.

FSC Hancock certification update 16/4/05

http://www.certifiedforests.org.au/documents/asp/asp1.html

http://www.hancock.forests.org.au/docs/05april.htm

The following document is an updated version of the above document which was written by Friends of the Earth on 6/4/04. Quotes taken from the 2004 document are presented here in italics.

"If Hancock failed to attain certification, the same old problems of environmental degradation would remain - potentially forever. With the FSC carrot however, there is now constant pressure on the company to improve its operations. If the company doesn't comply then it can lose its certification - which in turn would be a major embarrassment to the company and perhaps more importantly its investors." 6/4/04.

Friends of the Earth is yet to see improvements on the ground with Hancock's operations. Most of our attention for the past year has been in the Strzeleckis and it could be argued that the company has moved backwards in regards to the quality of their logging operations, particularly in their eucalypts. Of particular concern has been Hancock's lack of concern regarding cool temperate rainforest, their apparent lack of commitment to support the Cores and Links* proposal and a declining standard of consulation with local stakeholders, including Friends of Gippsland Bush who have done more to understand and document Strzelecki logging issues that any other group.

It could now be stated that Hancock appear to be deliberately undermining efforts by the local community, the Strzelecki Working Group (SWG), Friends of Gippsland Bush and Friends of the Earth regarding the Cores and Links proposal. Hancock have created a new working group to address the Cores and Links issue, now with representatives including; PaperlinX (the multinational paper company), VAFI (Victorian Association of Forest Industries, Trust for Nature and WWF. Details of the Cores and Links Reserve now appear to be cloaked in secrecy. A Memorandum of Understanding has been drafted but the public has not been privy to any of its details.

The Strzelecki Working Group is represented on the advisory group. It is the community which has been the driving force for this entire process and any attempt to undermine the work of local community will be strongly opposed. The basis for the MOU is the Cores and Links. This was the agreed goal of the Strzelecki Working Group (SWG) which has always included Hancock representation. The SWG has already done all the work required for the smooth transition, it does not need to be revisited by any advisory/ or other group.

Stakeholders outside of negotiations have not as yet even been granted a copy of the Memorandum of Understanding (MoU) for the Cores and Links Reserve, even though the Trust for Nature promised that it would be on their website. It seems very odd that an FSC certified company and a conservation trust would not want to further publicise the details of an historic MoU.

A map of the Cores and Links can be found at;

http://www.hancock.forests.org.au/docs/strzmap.htm

The new parties, now brought into the process, were not involved with the original creation of the Cores and Links. The credit for the Cores and Links must go to the Strzelecki Working Group who has been working on the issue since 2001. (*The Cores and Links Reserve was publicly announced by Hancock on October 29, 2004.

http://www.hancock.forests.org.au/docs/04oct.htm#sign

The announcement was made with Trust for Nature and the US based Nature Conservancy. Logging within the Cores and Links was supposedly put under moratorium for one year until Trust for Nature and Nature Conservancy raise the finance to “buy back” the land in question). There is the option of extending this deadline but we have not been privy to these details. The Cores and Links Reserve is about 9000 hectares in size and also contains about 2000 hectares of highly “sensitive” reforested land (such as cool temperate rainforest buffers), which Hancock have effectively had to hand over to create the reserve. Hancock announced in August 2004, that they intended to log about 80 hectares of the Reserve in 2004/2005, prior to the signing of the moratorium. Naturally this has infuriated conservation groups, who see the logging as the “thin edge of the wedge” whereby Hancock will continue to “chip away” at the reserve indefinately. It has been rumoured that Hancock is lobbying Trust for Nature to allow once only logging to occur within the supposed Reserve.

It should also be stated that the Cores and Links Reserve boundary was originally drawn up by Biosis Pty Ltd. Green groups acknowledge that there may have to be some redesigning of the reserve boundaries, to include areas missed in the original assessment and to possibly remove areas of low conservation significance. Any changes to the boundary would however occur only with consultation with local stakeholders and having the Reserve ground truthed by an ecologist. Hancock has refused to employ a mutually accepted ecologist to negotiate with boundary redesign. Instead Hancock has already logged boundary areas, without adequate consultation. Hancock Watch have twice caught Hancock logging inside the Cores and Links boundary in December 2004 at College Creek and April 2005 at Gunyah Gunyah.

http://www.hancock.forests.org.au/docs/04dec.htm

http://www.hancock.forests.org.au/docs/05april.htm

"Constant monitoring by FoE and FoGB of Hancock has paid off in that Smartwood has prepared a 6 page list of 30 conditions and pre-conditions that Hancock must meet in order to keep the FSC certificate (see: http://www.smartwood.org/reports/pdfs/hancock-victorian-plantations.pdf. Many of these conditions relate to positive initiatives beyond the existing Code of Forest Practice, such as the replanting of buffers in critical stream catchments, not using Simazine unless a Pesticide Advisory Group is established, supporting the 1997 historic 8 point agreement between Amcor and FoGB, publicly announcing herbicide regimes, looking at impacts of truck haulage routes, revegetation of steep slopes, protection of sensitive waterways etc. It was disappointing however that the certification seemed to ignore issues of rainforest definition and buffer zones, however it is FoE's assertion that Hancock will have to significantly 'lift its game' in order to keep the certification." 6/4/04.

It would appear that very few of these conditions have properly been met to the expectation of Friends of the Earth. We have seen no examples of replanting of buffers in critical stream catchments, and we believe that Hancock wish that the 8 Point Agreement agreed to Friends of Gippsland Bush in 1997 had never happened. We have seen no revegetation of steep slopes, unless you include Shining Gum plantations. Rainforest Buffers continue to be a sore point with Hancock leaving buffers of only 20 metres on Myrtle Beech and in some instances leaving absolute minimum buffers on cool temperate rainforest species. At least 4 breaches of conditions have occurred in the first year. To make matters worse we have documented examples of where Hancock left decent roadside buffers in 2002, when they had a different forest manager. When we revisit those places a year or so later we find those buffers clearfelled.

Such was the level of concern about rainforest buffers and the Cores and Links reserve, that Smartwood conducted an audit of Hancock's operations in June 2004. Hancock was granted with two Corrective Action Requests pertaining to rainforests and the Cores and Links.

CAR-2004: GRP shall postpone plantation harvesting operations from the proposed Cores and Links identified in the Biodiversity Study until the process required under Condition 9.1.1 is complete, and/or there is broad stakeholder input on the specific precautions/strategies that should be put in place so that any harvesting which occurs in the proposed Cores and Links will maintain high conservation values.

"CAR 1 -2004: The Rainforest Management BMP shall be completed by 1 March 2005 including an independent peer review and further stakeholder input. The current accepted practice of stakeholder involvement in boundary marking is to continue with coupes where HVP/GRP harvests plantations adjacent to any areas of Cool or Warm Temperate Rainforest.

Observation 1 -2004: Given stakeholder concerns and limitations, GRP should explore short-term alternative mechanisms for ensuring that it can obtain stakeholder input into the design of rainforest buffers and related management activities until such time that the Rainforest Management BMP is completed and practices dictated by the new BMP are fully internalized by HVP/GRP staff."

The audit was released in October 2004. Since October, not only have Hancock twice breached the CAR regarding the Cores and Links, they have also breached the CAR regarding Rainforest Management in possibly 15-20 instances. Observations by local stakeholders have revealed that Hancock has left 20 metre buffers on myrtle beech in cool temperate rainforest of regional significance, at numerous locations on the Morwell River East Branch catchment (with one beech buffer as low as 7 metres) and buffers of only 20 metres in the Morwell River and Albert River catchments (with one Myrtle Beech buffer in the Albert River being as low as 13 metres. Morwell River East Branch and Morwell River were logged prior to 1 March 2005, but no consultation occurred with stakeholders. The Albert River coupe at Rytons Junction was inside a Victorian Site of Botantical Significance and was logged post 1 March 2005, where 40 metre buffers are now supposed to occur. The Rainforest BMP has not been peer reviewed and the Forest Management Plan released by the company to the public only under great duress, is actually a great step backwards from existing documents written earlier by the company.

Examples of rainforest buffer infringements post October 2004 can be found at;

http://www.hancock.forests.org.au/docs/04dec.htm

http://www.hancock.forests.org.au/docs/05jan.htm

http://www.hancock.forests.org.au/docs/05Feb.htm

http://www.hancock.forests.org.au/docs/05march.htm

http://www.hancock.forests.org.au/docs/05march2.htm

http://www.hancock.forests.org.au/docs/05april.htm

The March 2005 audit team consisted of two foresters. Whilst not criticising the auditors for their skills and expertise, it would be fair to say that Smartwood's 2005 audit team probably lacked expertise in cool temperate rainforest and forest ecology. It is odd that an ecologist was not employed who could have provided that same advice at such a crucial time in the process. The first Smartwood audit team in September 2002 included three foresters, an ecologist and a social scientist. Input was also provided by a soil scientist and an engineer. It has been suggested that because Hancock pay for the audit, Smartwood have been limited in who they could employ. It is not beyond the realm of possibility that if a company does not agree with the comments provided by auditors, they withdraw funding for the next audit or employ different auditors.

In regards to herbicides and the fact that Hancock, under FSC conditions, was supposed to provide a list of chemicals used by the company during the past year, Friends of the Earth wrote to the company requesting this information in January 2005 and the company's stewardship officer has not even had the courtesy to reply to the request.

Not only do we have no details of what and how much pesticide has been sprayed in particular catchments, we also have no information regarding chemical sampling after spraying. We do not know which species have had their habitat sprayed or which human population, have had their drinking water catchments intensively sprayed with herbicides. Hancock have plantations in water catchments that provide thousands and thousands of Victorians with drinking water. Over 130 towns have been identified getting water from plantations located in domestic water supply catchments that have Hancock plantations located in them. Herbicide spray rates must be made public if the industry and FSC is to have any credibility regarding plantation certification.

Pestcides used by the plantation industry in Australia have rarely been tested on the species that they are likely to impact on. Australian crustaceans have been found to be more sensitive to Roundup than their northern Hemisphere cousins. Yet habitat for the endangered Strzelecki Burrowing Crayfish and other species has been and will be sprayed by Hancock. Likewise Hancock plantations are located in endangered fish habitat. The state and federally listed Australian Grayling, Macquarie Perch, Murray Cod and Trout Cod live in streams sourcing water from Hancock operations. Many of these species are also highly sensitive to sediment.

Hancock is also replacing pine plantations in the higher elevations with Shining Gum, a non endemic species to the Strzeleckis which may be more prone to insect attack than radiata pine. If this is the case, widespread application of insecticides may occur in the future. Hancock is also converting endemic mountain ash hardwood trees, with shining gum, meaning that species relying on the ash as a food and shelter source will be left disadvantaged. Perhaps most at risk is the Strzelcki Koala which can eat young Mountain Ash leaves, but will not eat Shining Gum leaves.

" FSC will allow for continued logging in the Strzeleckis in 2004 at volumes 30% less than what the conservation movement was recommending less than 10 years ago. It may also hold the key to keeping the woodchippers out of key Strzelecki rainforest catchments. In terms of the Central Highlands, it may now be worth pulling the bull by the horns and look seriously at FSC certification in of native forests in the Central Highlands and Gippsland. At least this way ENGO's can have a say in areas they want set aside, which is in complete opposition to the situation we have now, where we are losing almost everything. NNFL groups should understand that native forest logging will be here to stay and rather than ignore it and hope that it goes away, work positively to reduce the impacts of both the native forest and plantation industries." 6/4/04.

It would appear that although Hancock has yet to enter logging coupes in sensitive rainforest areas within the cores and links reserve, ie Franklin River, Agnes River, Dingo Creek, College Creek, Jack River, South Middle Creek, Hancock appear to be deliberately targeting key rainforest areas outside of the reserve ; most notably at Morwell River East Branch, Albert River and Morwell River. This is not a sustainable outcome for cool temperate rainforest in the Strzeleckis. Under the Victorian Code of Forest Practice there are different standards for cool temperate rainforest protection on public and private land. Public land can have buffers depending on significance of the stand of between 40 and 60 metres. Some stands can have 100 metre buffers and sub-catchment protection. In regards to private land the Code states that an unspecified buffer should be reserved.

By allowing an interim plantation standard, without a National Standard, FSC certified operations in Victoria are allowing standards to occur in private land which would be illegal and breach the Code of Forest Practices in state forests. Hancock is taking full advantage of these loopholes, as did their predecessor, Australian Paper Plantations (Amcor).

Weaker conditions on private land are also a problem in other regions of Victoria. For instance under the Forest Management Plan for the Daylesford region, coupe sizes of 15 ha maximum are allowed in State Forests, in the Korweinguboora domestic water supply catchment. Plantations however are currently being logged in sizes of several hundred hectares, in the close vicinity to Korweinguboora Reservoir which provides drinking water to Geelong.

It also appears that if FSC is to work then the local community needs to be involved with coupe monitoring. FSC cannot work if it relies on yearly audits that have minimal community input. If Friends of Gippsland Bush and Friends of the Earth have not been involved with coupe monitoring, it would be interesting to see just what would have transpired with the FSC process. Most importantly, FSC will not work if industry is not committed to the process.

Therefore there are two ways forward for Smartwood. If FSC is to have any credibility, Hancock will be stripped of their certification. If Hancock continue to be certified, not only will FSC lose a great deal of credibility in Australia, they will be seen as just another stamp approving high conservation value forest destruction. By losing the certification, it could well mean that Hancock will start aerially spraying Simazine in Gippsland, including catchments that provide drinking water to thousands of people. The only tangible gain FSC has granted is a moratorium on the use of this chemical.

Anthony Amis 16/4/05 Friends of the Earth Melbourne

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