22 May 2000
[3.2 Operational Planning-Forest Practices Plans: j)] Effects on neighbours cannot just be dismissed because someone has done a "plan" and there is little or no specification in the code for limiting effects on neighbours or taking into account what has occurred on neighbouring land in the past and is occurring at present.
[3.2 Operational Planning-Forest Practices Plans: page 11 at top] Does Waratah/Wynyard Council have areas zoned for landscape protection in its scheme and is the zoning proposed in the new model planning scheme? What are the mechanisms for imposing the landscape protection zones on both private and public forestry operations?
Further, how much consultation has occurred over the protection of the Cam River catchment for the town water supply given that pine plantations are known to diminish surface runoff by 50%. Already the area west of the Cam River has taken a beating and plantation development can only exacerbate the problem of maintaining adequate flow and water quality in the Cam.
[B 1 Planning and locating roads: page 13 dot point 9] Watercourse crossings should take account of the particular needs of the giant crayfish which apparently doesnot cope well with cement batters or other unsympathetic modifications to watercourse banks. This particularly applies to rivers and major creeks in this municipality and in Circular Head.
[C Harvesting of Timber: 1.1 dot point 2] I would have thought that in planning a cutting coupe that requirements for safe burning would be incorporated within 100 hectares not given exception. [page 32 (a) and (b)] It appears to me that there is no requirement that one method of harvesting in anticipation for regeneration be followed through and that regeneration will actually be carried out. On the Preolenna Road area diagonally opposite the start of the Ten Foot Track, Forestry Tasmania undertook a clearfell operation with the published intention by site signs of regeneration to eucalypt forest. It subsequently changed its mind and ploughed the area up to establish a pine plantation. The excuse given was that the soil was unsuitable for regeneration. Surely soil assessment is carried out at the planning stage and not in the middle of operations.
This is a big concern given the propensity to establish plantations at the risk of destroying the sustainability of the remaining native forest areas to retain adequate biodiversity. Forestry Tasmania should be particularly required to favour regeneration in native forest areas over conversion to plantation.
Further, the age and height requirements of dispersed coupes and aggregates should be extended to the upper limits indicated by research for sustaining biodiversity and habitat requirements. They are currently inadequate.
[page 13 dot point 32] Clearfelling "will" not "should" be prohited in vulnerable karst soils and in all other karst areas.
[Coupe design: page 33] In steep country why plantation establishment at all? On page 34 the words "wherever practicable" should be deleted from the sentence. No streamside reserves and Class 4 streamside vegetation should be planned for burning.
[Page 53 and 54 in discussion of treatment of streamside reserves] All streamside reserves should be planned to protect them from any logging, selective or otherwise.
We have the statement (e) that "no trees will be felled in the 10m adjacent to a Class 1 or 2 watercourse": what happened to the 40 metres?
[4.2 Streamside Reserves in plantations] (a) has already been breached in the Calder State Forest area on the Inglis and Calder Rivers: on the south bank to the west of the Calder bridge even the silver wattles which managed to survive in the 5 metre strip either side of the river bordered by the older pine plantation are being cut down. Surely in situations like this any surviving native plants should be fiercely protected on a Class 1 watercourse when surrounded by pine plantation harvesting. (f) on page 56 says "remnant native vegetation will be retained". Again: firmness in the wording of all sections of the code will minimise conflict of opinion.
[Page 58 dot point 1] Salvage logging of fire damaged areas should be avoided to minimise disturbance to natural regeneration.
[Page 62 point(b)] I would suggest that if compensation mechanisms are invoked for reservation of significant old growth forest and vegetation types on private land under the duty of care principle then compensation should not be given unless at least 50%, not 5%, of the area in question is reserved and managed for conservation. This should exclude reforestation areas.
[Pages 66 and 67] The steamside reserves should be protected from all logging selective or otherwise given that the minimum widths have not been altered despite the general public's constant concern of their inadequacy. Of all the requirements under the code, streamside reserves offer so much potential to protect so much of the values held dear by the community at large including water quality, vegetation diversity, recreation values and scenic preservation. Compromising this by dividence about practices will only continue to destroy the credibility of the industry.
I suggest it is time to move to increase the Minimum Streamside Reserve Widths or Machinery Exclusion Zones to better educate the forestry and plantation developer community on the need for protection for these areas. In field days I have attended it is patently obvious that proponents of operations are conceding only the minimum width (usually even reluctantly) and taking no account of local conditions to improve on a management situation. The bigger the coupe size, the wider should be the buffer strips on water courses (a recommendation from early research in SE NSW by Recher, Rohan-Jones and Smith).
I propose
[Page 68 dot point 3] Significant springs require further consideration particularly where they are the catchment of a neighbours' water supply.
[3. Flora and Fauna] There appears to be no consideration of the mapping that has progressed on "CAR Values": surely in the Waratah/Wynyard area the mapping completed would help to define particular corridors for effective reservation.
[Page 72 dot point 3] Of particular concern is the management of all operations for prevention of the spread of phytophtora. The Calder State Forest area is particularly vulnerable. Machinery hygiene should be a prerequisite in all areas of operation to prevent the migration of the fungal disease.
[Page 73 dot point 2] Here we have the first recognition of a problem already rampant on the mainland and unacknowledged (to now) here: the issues of plantation eucalypt hybridisation and incursion of plantation pine into native bush areas. One obvious solution is to make the decision to regenerate native forests rather than create weed conflict by creating plantation coupes within native forest areas.
[4.2 Harvesting] Roadside vegetation retention , steep country operations and landscape preservation are little understood and currently inadequate. Prescriptions should be included in this section of the code.
[4.3 Plantation development] Retention of major vegetation on watercourses and gullies and of the amenity plantings extant on the area should be prescribed. "Landcare" type restoration of degraded and steeply sloping areas with native vegetation types should be prescribed in plans. A classic example exists on the plantation area to the east of Coal Mine Road where Forestry Tasmania has established its plantation on level land and ignored any need to restore the degraded slopes leading down to the road. In fact it continued to allow further land degradation by leasing the land for cattle grazing well after plantation establishment. Surely an obvious situation for prescription.
[E. Establishing and Maintaining Forests]
In the Reforestation Technique Guide [Page 91] Plantations are seen as "where most appropriate" on Class 3 soils or better. The code recommendation means, in our municipality, that Table Cape fits the bill perfectly! This needs a rethink: plantations should be targetted to Class 5 or worse soils. Institutional encouragement through a code such as this is irresponsible given the higher value uses of prime soils and their limits of availability.
[Page 92 Use of fire] There was no mention of the alternative use of smoke for regeneration sites to burning. Recent Western Australian research could prove useful here given the current problems with burning regimes.
[Page 92 Mechanical site preparation] Machine hygiene is not mentioned here and should be prescribed.
Where sufficient established trees and an adequate seed bed exists following logging, further site preparation should be unnecessary and the code should make this the "best practice" standard.
[1.2.2 Plantation development]
The prescriptions for retention of slash to retain nutrients is defeated by considerations to burn. There are no prescriptions for fire breaks for community and neighbour protection, overshadowing of neighbouring pasture or crops and the mitigation of the loss of light to neighbouring residential properties. Given that by the year 2001 the Preolenna/Meunna area will have something in the order of 4500 hectares of highly volatile eucalypt plantations unrelieved except by the Flowerdale River wildlife corridor and a few small acreages ranging from 1 to 25 acres. Gunns' current prospectus which targets farms in our area suggests 3.5 metres but says insurance is the investors' problem. However there is no mention of protection for 3rd party property.
I would recommend the following:
Surely observations such as this need to be incorporated in some form in the code to bring home the necessity for the "sustainable management" of our soil resources.
[Page 94 dot point one] On weed control, mowing is not mentioned as a preferable option. Some areas in recently established plantations are being managed in this way given the failure of chemical regimes to control huge outbreaks of thistle infestation.
[Page 96 dot point 4] Plantations should not be permitted on any karst soils.
[Pages 98-99 Streamside reserve and watercourses in relation to plantations] The streamside reserves and watercourses in relation to plantation establishment consistently allows unacceptable exceptions for the planting of plantation within these areas. Plantations should be excluded and prescription be made for "landcare" type plantings in these areas with no expectation of harvest. The clauses on page 98 are at best a copout and allow for all the best aspects of the code to be brought into disrepute. We are talking of "establishment" here, and, 2 metres from a Class 4 watercourse and 10 metres from a Class 1,2 or 3 watercourse for future logging is totally unacceptable. Further direct application of fertiliser to watercourses not "should", but "will" be avoided as it is against the law.
[Page 100] In the choice of plantation species every encouragement should be given in the code to the planting of local indigenous commercial species, e.g. E. obliqua or E. regnans. Further non local indigenous species should not be included in the seed mix for native forest regeneration, particularly as suggested in Phytophthora mitigation. There are non eucalypt local species which can be included in the mix to achieve the same aim.
[Page 103 a) and b) Protection of planted seedlings] 1080 should only be used, very selectively and locally, if fencing and trapping and shooting have failed. 1080 should not be used within 1 km of a residence. Priority attention in research needs to be given to the assessment of species (usually local) which sustain insignificant browsing damage. This would enable 1080 to be taken out of use and diversify the genetic base of the plantation industry leaving less susceptability to widespread disease and insect attack currently experienced in the unsustainable monocultural regime we have at this time.
[Page 106 f. Use of Chemicals and Disease and Weed Control] Aerial spraying should not be carried out due to the dangers of drift into streams and watercourses and the threat to neighbouring enterprises. Machinery hygiene should be observed both for the mitigation of disease such as Phytophtora and to minimise the spread of weeds. The Waratah/Wynyard area is becoming susceptable to the spread of ragwort and machine hygiene observance is essential to keep this threat at bay. Weed mitigation combined with strategic mowing outside of the plantation canopy would certainly contribute to a lessening of the need for extensive herbicide use.
It seems to me that plantation and forestry managers have an addiction to the extensive use of unacceptable and dangerous herbicides and poisons. They appear to be unable to think strategically and laterally about alternative options for protection of plants. After all, possums and wallabies are irrational creatures in our terms. We are supposed to be the rational intelligent managers of our environment. Possums are still in front when it comes to demonstrating just who is rational in this world!
In our orchard situation we manage for exclusion around the immediate production tree. Our NZ dairy farmers considered exclusion fencing of their pastures to be far more economical and effective than repeated applications of 1080. They are the ones who had to deal with the feral brushtail possum in New Zealand where 1080 is banned. In most NW dairy areas now a little strategic thinking and co-operation would see very effective fencing around most plantations without exceptional cost. After all, our dairy farmers "whole farm plan", why cannot plantation developers?
Until attention is given to consideration of impacts of forestry and plantations on neighbours the current draft code is totally unacceptable.
Colleen Dibley B.A., Grad. Dip. Ext., ALAA