Introduction

Coastwatchers Association Inc (CW's) is a conservation group formed over twenty years ago and based in the Eurobodalla area. Over this time we have witnessed many changes in the management of the States' forests including a greater reliance on "waste products" to underpin the sawlog industry, job losses due to mechanisation and the introduction of the Regional Forest Agreement for Southern NSW (RFA).

We note that the plan upon which we are asked to comment was "approved as operative from 1/7/2004". Despite this, the CEO of Forests NSW has still asked the community to review the document and to comment, letting the local regional manager know reactions before the Plan is adopted. Has the Plan been adopted yet or merely approved and waiting adoption? Does this Plan need to be tabled in Parliament?

This submission will address our concerns about some of the strategies outlined in the Ecologically Sustainable Forest Management (ESFM) Plan for the South Coast. We will also provide photographic evidence that demonstrates that current practices are not working as well as could be reasonably expected. Our aim is to expose the gaps between the theory of ESFM and its on-ground application in a positive way that will hopefully lead to an improvement in forest management.

Part 1: Objectives and Targets.

The RFA for Southern Region is scheduled for the first five-yearly review in 2006. These ESFM plans cover objectives and targets for the five year period 2004-2009. Maybe for ease of administration and coordination the time for review of both documents should be the same.

Forests NSW has undertaken to provide an annual report of the quantity of all timber products harvested. Could this detail be provided on a regional basis rather than just the accumulated statewide report?

Has there been silvicultural demonstration areas established locally? Maybe these areas might be used to better make known Forests NSW ideas for forest management to the community at large.

What consultation with the public is planned during the development of the three year plan of operations? Can public forums be conducted to gauge community views on the logging operations planned? Community concerns must be taken into account in the development of the plans. Consultation with relevant stakeholders on major operational issues is to be undertaken; will the general community, certainly relevant stakeholders, be invited to such consultations?

Recommendation: That coordinated time frames be adopted for the review of the Southern Region RFA and the ESFM Plan.
Recommendation: That timber harvest records by sub-region be made available to the public.
Recommendation: That public forums are conducted to gauge reactions to planned operations.

Part 2: Natural Heritage

Biodiversity

How does Forests NSW maximise ecological niches and diversity by reducing, through harvesting, the area of naturally evolving forests? Coastwatchers are of the opinion that only by leaving the native forests to evolve naturally would diversity be enhanced. Forests NSW appears to agree with this statement on (p2) by stating biodiversity may reach pre-disturbance levels.

Coastwatchers would like to know which "land management planning instruments" Forests NSW will be assisting the community and neighbours to develop and deliver?

Recommendation: Forests NSW provide Coastwatchers with examples of relevant land management instruments.

Soil, Nutrients and Water

Coastwatchers reject the assertion that forestry operation assist or even enhance soil fertility. Timber harvesting operations interrupt the natural cycles. Even if nutrient foliage is left on the forest floor after harvesting such is destroyed and all supposed benefits lost during post harvest burning. Forest harvest operations carried out in the catchments of the region to date could hardly be seen as having any benefit towards Forests NSW stated aim of minimising ground disturbance.

An issue that has emerged over the years is the unrestricted use of trail bikes in the forests of the South Coast. This association is aware of several unofficial motocross tracks, utilising forest roads and snig tracks that exist in the area. These tracks are used mainly on the weekends and occasionally on week days. Observations indicate that up to 40% of these machines are unregistered and possibly unroadworthy due to non complying exhaust systems. Forests NSW needs to deal with this issue as the road manager of the network as it may have at some future time costly implication in case of an accident.

The immediate presenting problem is that the trails cross 1st, 2nd and 3rd order and prescribed streams,(see photos) have their erosion control cross banks compromised and thus provide significant amounts of sediment directly into waterways.

Peter Duncan, CEO Forests NSW, states in his covering letter to the ESFM Plan that "we won't be fully effective unless we work in conjunction with the community and other agencies" and "have openness to ideas and transparency in decision making". Given that the Clyde River catchment in identified in the South East Catchment Management Board Blueprint as a river of high conservation value this issue needs urgent addressing.

Recommendation: Coastwatchers and regional Forests NSW management, local police organise a meeting with us to discuss this issue and formulate a plan to resolve this ongoing problem.

Landscapes

The figures in the 8th paragraph are slightly confusing and may need rewording for the purpose of clarification. For instance, the 4% of State forests gross area is harvested per annum but what is the percentage of productive forest available for harvest that is utilised? In other words what is the percentage of the estate excluding non harvestable areas? Coastwatchers would also like to see these figures broken down into sub regions and catchments.

Coastwatchers are very sceptical that maintenance of landscape connectivity on private land can be guaranteed through the application of the Native Vegetation Act.

Recommendation: That Forests NSW provide clarification of the figures in Paragraph 8

Part 6: Forest Health

Fire Management

From time to time fires are lit either by humans or natural causes during high fire danger periods. If these fires are on lands managed by Forests NSW they are their responsibility. Recently, one such fire burnt in compartment 97 of the Boyne SF. Logging had ceased earlier but the winter conditions proved incompatible for a post harvest burn. This fire was managed by Forests NSW throughout that month and on December 25th flared into a wildfire due to extreme conditions causing adverse environment damage and community angst amongst neighbouring landholders. Coastwatchers believe that more resources should have been committed earlier to this blaze when it was detected.

Members of this organization visited Compartment 62 of the Boyne SF (see photos) after a post harvest burn and provided us with evidence of the burn reaching Wet Sclerophyll forests and exceeding the prescribed flame height by an estimated order of 3 times. It appears that Forests NSW employees either have a very cavalier attitude to the use of fire or are acting under the directions of management.

Regarding understocked stands, could this term be clarified and locations of this type of forest forwarded to this organization?

Recommendation: That in future, full multi agency resources be brought to bear to avoid the scenario of fires burning unhindered unfolding in the future.
Recommendation: That the locations of understocked stands be provided to Coastwatchers Association.

Eucalypt Decline, Disease and Insects

This section gives an overview of the problems associated with dieback but does not address the issue in any serious manner. The 2,500 Ha effected by dieback is less than 2.5% of the productive forest available for harvest given that some effected forest are gullies.

Coastwatchers question how seriously Forests NSW treat this threat to the native forests of the South Coast.

Weed Management

As mentioned above Coastwatchers members visited Compartment 62 and were surprised by the number and variety of weed species that had invaded the area. It appears that apart from the post harvest burn there is very little monitoring of other issues that effect the compartments once harvesting has ceased.

The list of major plants of concern is very limited.

Recommendation: that Cassia (Senna), Wild Tobacco Bush and the plethora of ground covering weeds is added to this list.

Pest Animals

Assuming conservationists aren't included; this is one area where Forests NSW does a very good job, particularly in the fox mound baiting program. In regard to pigs they seem to have reduced in numbers over the last 20 years in the coastal forests however feral deer may present as worthy of attention in the coastal foothills in the future.

Chemical Handling

Several drums of chemicals were left in Compartment 62 for a considerable length of time (see photos). At the time a Forests NSW employee was in the area and drove past the containers on his way into the compartment. Coastwatchers members assumed that he would remove them on his return; however on a later visit the containers were still in situ. This could be happening in other parts of the estate and does not inspire confidence in Forests NSW chemical handling procedures. It is not uncommon to find fuel, oil and grease containers in compartments after logging operations.

Recommend: that the chemical handling procedures be tightened up to avoid adverse impacts on the environment.

Part 7: Sustainable Timber Supply

Central to the harvesting of sawlogs locally is the provision of pulp grade timber to the wood chip facility in Eden. This is the single most contentious issue in the community and one that requires resolution. If the chip mill was not in Eden would native forest harvesting in this region be viable? If not, the community must face the fact that only by the wholesale destruction of the forests for the chip mill can we have a sawlog operation. Forests NSW publicity to date suggests that wood chipping supports saw logging…reality suggests that saw logging is the poor second priority to wood chipping. Whilst the timber supply might be sustainable, is the timber industry sustainable without wood chipping.

Coastwatchers believe that the answer in an unequivocal in the negative.

Timber Supply Strategy

This strategy is deficient in several areas due to the inability of Forests NSW to implement the various actions underpinning the supply calculations. Coastwatchers understands that the important actions of purchasing private land/ timber rights and the silvicultural treatment of forests are behind schedule. This throws into confusion any forward planning to meet the contractual obligations of Forests NSW and threatens the long term future of the RFA.

This must, combined with the other elements of forward planning outlined below have a negative effect on the yield predictions.

Recommendation: That Forests NSW continue to use conservative yield predictions in the future.

Silviculture

Basal rate retention in some compartments (see photos) seems to be less than prescribed under the Single Tree Selection (STS) criteria.* Is the basal rate calculated over the entire compartment or is it restricted to the harvestable area? If non harvested areas are added to the equation then the 45% figure can be exceeded in the harvest zones. The attached photo is a good example of the canopy being very open indicating that the basal rate has been exceeded.

We also note that a basal rate of 45% is indicative of heavy logging which indicates to us that the cutting regime in place in these forests is at the maximum level and may be unsustainable in the long term.

* Coastwatchers used canopy cover as a close approximation of basal rate.

Recommendation: That the basal rate be applied to the net harvestable area so that the forests are not opened up too much during operations.

FRAMES

Since the introduction of the RFA there seems to be an intensification of the harvesting within compartments. Coastwatchers understands that FRAMES has a significant error rate and that it is applied in a conservative manner. Forests NSW must be aware of this situation as the Sustainable Supply Strategy calls for improvements to FRAMES. We would discourage any increase in yield above the present rate.

It is interesting to note that 200 year time frames are used in calculating future yields. This raises the question of what happens to the predictions if the time frames are shortened. Do the predictions decrease or increase? Do they stay the same?

Recommendation: No increase in yield over time and that predictive yield in 30 year time frames be produced and made public.

Part 8: Economic Development

Commercial Use of State Forests

Forests NSW Annual Reports have indicated that the harvesting of native forests records a financial loss and the profitable arm of the organization is the plantations. There needs to be serious consideration given to alternative uses of the estate in order to turn this situation around into positive figures. This may require Forests NSW taking on new ideas that are outside of the fields of expertise currently contained within the organization.

Coastwatchers support the development of further native species plantations on degraded farmland but strongly oppose the further destruction of native forested areas for the development of plantations. Further to this, a definitive economic study is needed to address the benefit of the sawlog industry to the South-East including the amount of subsidies provided to the industry. If the findings are that the industry cannot exist without subsidy than why should it be maintained when near-by plantations are capable of providing greater economic returns and social benefits?

Recommendation: That a definitive economic study be commissioned to investigate the true benefits of the sawlog industry to the South-East.

Part 9: Social Development.

Forests NSW seems to want to imply that despite their best efforts at management of the forests, they receive no return from the water flowing from the forests. If a commercial return is warranted than this needs to be applied across all tenures. Forests NSW are the management agency responsible for the welfare of the estate but does not however produce water. Water is of inestimably more worth to the community than the timber harvested by Forests NSW and needs protection even at the expense of the timber industry. The question is, as the region grows and the communities expectations change over time, will the harvesting of native forests be a compatible use of the public estate into the future?

This position does not necessarily advocate turning all State Forests into National Parks but encourages exploration of new ideas and emerging industries.

Photo 1.Compartment 96 Boyne SF 3rd order stream
Photo 2.Compartment 97 Boyne SF 2nd order stream
Photo 3.Prescribed stream crossing Sheas Road
Photo 4.Compartment 62 Boyne SF non complying burn
Photo 5.Compartment 62 Boyne SF full chemical drums
Photo 6 Compartment 97 basal rate exceeding 45%