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Submission to WMLR NRM Draft WAP

Tony Dickson
PO Box 229 Victor Harbor 5211 ferretfarm@bigpond.com 0410501484

To whom it may concern, Three years ago I wrote a submission to the first Draft WAP. Nothing of substance in the policy proposals has changed since that submission. None of the issues I raised in that document have been answered, or even addressed. From my perspective, the consultative process is a complete sham, as is usually the case in our wide brown polity. I understand that the extent to which the Board can change the policy foundations is limited, but suggest that there are some shared moral imperatives involved in heading off the creation of profoundly flawed public policy. I am very much more of a pragmatist than an ideologue and am quite prepared to change my position when cogently challenged. It is not unreasonable to expect the political process to do the same; provided of course that good policy is the first priority of those involved. If my "big picture" issues are ignored by the process of developing the detail, surely there can only be madness in the method. This is where Kafka perhaps becomes a useful reference.

However, where there is life, there is hope. Below is a condensation of the points, explicit and implicit in my previous submission, in the form of some questions that demand recognition for the sake of the credibility of this process.

Why is the policy focused only on water based ecologies at the expense of terrestrial ones? Why isn't connectivity the main ecological priority? Why is the ecological point of reference an arbitrary date, rather than pre-clearance of the land? The reason given, that we cannot turn back the clock, is a logical nonsense. I endorse the concept of ecological triage (or tree-arge) but this can still only be achieved with reference to a time before the catastrophe. Why does the policy refuse to distinguish between industrial scale forestry and the realities of farm forestry? Why does the policy refuse to acknowledge that there are many management regimes for forests and that most do not embrace clear felling.

Why does the policy not acknowledge that there is a difference between water use by forests and irrigation, in that forests only use available water, whereas irrigated crops use more water in dry years? And why isn't the research that indicates that plantations use marginally less water than remnant vegetation acknowledged? Why does a policy that purports to have a raison dtre of protecting the environment, refuse to distinguish between land-uses that differ widely in their environmental and social impacts (except in the context of salinity, in which case why only that?). The market place has only one bottom line, so where does that leave the environment? Why would the NRM board be silent in allowing a policy to be foisted on it that will inevitably favour the recreational drug and gambling industries over food security and the ecological benefits of re-vegetation by way of FF? How does the legal separation of land from water contribute to food security or ecological health? Why does the policy fail to embrace the notion of water quality as well as quantity? Why is it not acknowledged that flood water in the erosion gullies we call the Inman and Hindmarsh "rivers" does huge damage to the littoral ecology of Encounter Bay. These flood events would have been very rare prior to the clearance of 85% of their catchments. Why does the policy fail to acknowledge the research which indicates the surprisingly high ecological values of even industrial forestry, let alone the possibilities for analogue farm forestry in its various manifestations? Why does the policy not acknowledge, when comparing "reveg." with FF that the ecological damage caused by inevitable fire events will almost certainly be greater in the former than the later, periodic harvesting notwithstanding? The policy rightly identifies climate instability as the greatest threat to ecological values, so why does it completely ignore the moral responsibility to mitigate the causes of the problem, as well as its effects. Reveg. has very limited ability to sequester carbon compared with forestry. This is addressed nowhere in the discussion papers. Why not? This failure represents a degree of ethical bankruptcy in the whole process, as does the assumption that land holders are expected to do the bidding of an urban based environmental lobby at their own expense, and thus at no cost to the urban majority. It is easy being green if someone else is footing the bill.

Two things have changed since 2007:

The demise of Adelaide Blue Gum means that any possibility of a viable native forestry industry in the MLR is also dead. With no possibility of an expansion of large plantations (indeed many of the existing ones are in the process of being removed) the justification for the continuing opposition to farm forestry is gone as well. The policy now contains the astounding assertion that, "Forests planted at these densities (ie 250 trees per hectare) are not considered to intercept rainfall or take water from shallow water tables in a significant way." P70 of the Guide to the DWAP.

Assuming that it is envisaged that these trees would be allowed to reach maturity, this is a revelation, because 250 stems/hectare is a greater density than is usual in a commercial plantation of mature trees. Such densities represent a full occupation of the site. The fact that forest management requires initially higher densities could not increase water usage beyond that of the full occupation of that site. This raises two issues. The first is that if this is correct, then forestry should not be considered to be a water effecting activity and should therefore be exempt from the suffocating embrace of the policy. If this is not correct, then the credibility of the science underpinning the policy is profoundly compromised. This is a very important point from both a substantive and political perspective.

In addressing the above questions the observations below are of great relevance. There is a growing body of research that indicates that even industrial forest monocultures have significant benefits for biodiversity. For example:

o Indigenous Biodiversity Conservation and Plantation Forestry: Options for the future.
David A Norton, School of Forestry, University of Canterbury NZ. 1998
Our goals in plantation forests should be to integrate production and protection in the same landscape (as advocated by the Resource Management Act 1991) rather than replacing one with the other. A review of indigenous biodiversity in New Zealand's plantation forests shows that many indigenous plants and animals occur in exotic plantations, with the number of species being dependent on plantation age, proximity to indigenous remnants and a variety of site factors (slope, aspect, etc). Plantation forests contribute to the conservation of indigenous biodiversity through: (i) providing habitat for indigenous species; (ii) buffering indigenous forest remnants; and (iii) improving connectivity between remnants. Options for enhancing indigenous biodiversity conservation in plantation forests include: (i) retention of indigenous forest; (ii) establishing a greater diversity of planted species; (iii) planting a diversity of tree species along streams and roads to provide additional habitat for indigenous animals; and (iv) modifying silvicultural practices within plantations. It is suggested that through the use of spatial modelling, optimisation of the arrangement of different aged compartments, and different plantation species, will maximise both timber production and indigenous biodiversity within a forest thus allowing full integration of these two activities without the loss of production values.

o Fauna conservation in Australian plantation forests

D.H. Lindenmayer R.J. Hobbs. Centre for Resource and Environmental Studies, The Australian National University 2003.

Our review showed that almost all research undertaken in Australian plantations, both in conifers and eucalypts, highlighted the importance of landscape heterogeneity and stand structural complexity for fauna conservation. At the landscape level, patches of retained native vegetation, strips of riparian vegetation, dams, open and clearing areas can significantly increase the number of native species that occur within plantations. Some species that occur in these areas can also use adjacent planted areas, a result common to conifer and eucalypt plantations. The spatial juxtaposition of stands of varying ages throughout plantation landscapes also can contribute to the maintenance of some populations of native taxa. At the stand level, structural complexity is also important for fauna with many species responding positively to the presence of native understorey plants, the presence of windrowed logs, and logging slash left on the forest floor. The management of plantations to promote landscape heterogeneity and stand structural complexity will, in many cases, involve trade-offs that will influence wood and pulp production. The extent to which this occurs will be dependent on the objectives of plantation management and how far they extend toward the complex plantation forestry model to incorporate social and environmental values in addition to wood and pulp production.

o Eucalypt plantations as habitat for birds on previously cleared farmland in south-eastern Australia
Richard H. Loyn*, Edward G. McNabb, Phoebe Macak, Philippa Noble 2007
Mean abundance of forest and woodland birds was higher in eucalypt plantations than cleared farmland, and marginally lower than in native forest. Patterns differed between bird guilds. For example, insectivores that forage in the canopy and tall shrub layers were at least as common in plantations as in native forest, with birds in the latter group using young eucalypts as if they were tall shrubs. Birds that forage from open ground among trees were more common in plantations than native forest, and may benefit substantially from the new habitat fortuitously provided for them. This group includes several species that have declined in natural woodland habitats. Nectarivores, carnivores and birds that forage among low shrubs were less common in plantations than in native forest. Insectivores that forage from eucalypt bark made little use of plantations. Different approaches to plantation design and management would be needed to cater for groups such as these. Specific measures include planting of rough-barked eucalypts in addition to smoothbarked species, and provision of artificial hollows. Retention of existing remnants of native forest (e.g. old trees and forest patches) is a priority, to supply habitat elements that would otherwise be missing for long periods.

o If this is true for industrial scale forestry, it is clear that the ecological value of diverse farm forestry, designed to integrate the complexity of analogue forests with remnant habitat, would be exponentially greater.

The above research and most of the conversation about ecological values in this process of policy development suffers significantly from ecological myopia. The imperatives imposed by the political process and the practicalities of administration, combined with populist, but often facile environmental enthusiasm, has focussed excessive attention on fur, feathers and scales at the expense of the vast majority of the species that inhabit our landscapes.

We must not lose sight of the fact that it is estimated that perhaps 50% of the biomass and 95% of all terrestrial species are to be found below the ground, and that recent estimates of arthropod fauna alone, in the canopies of Australias eucalypt forests, suggest that the number of species could exceed 250,000. The potential significance of farm forestry in providing the structural requirements for biodiversity enhancement should be clear. It is unfortunate that habitat is inevitably synonymous with fuel load. This reality creates an exquisite dilemma for those of us who are passionate about saving as much as possible of our natural heritage from the next approaching and probably inevitable catastrophe. Fire is the knife that has sculptured our environment. It has been the crucible of our unique variety of life forms, but as a consequence of our greed and stupidity, fire has become a mortal threat to many of those species. The insane over clearing of the land has left only isolated pockets of healthy habitat that are extremely vulnerable to the devastating consequences of fire. The dilemma posed by restorative revegetation is that whilst its ecological values are undoubtedly superior to forestry, it is hugely more vulnerable to fire events. The lower ecological values of farm forestry are significantly offset by the lower intensity of fire risk and the consequent increase in ecological resilience. Fire is the focus of another reason why farm forestry is a better ecological option than restorative revegetation. The Kyoto Protocol was deficient in several respects, one of which was the failur e to recognise forestry products as a continuing mode of carbon sequestration. Furniture, buildings, bio-fuel and even paper dumped in landfill; continue to lock up carbon for decades or centuries. This reality is widely accepted and is expected to receive formal recognition in the near future. Given that any form of mature vegetation is only carbon neutral and is constantly at risk of releasing its stored carbon if burnt, the rotation harvesting of plantation forests provides ongoing sequestration. High growth rates, removal of timber, replanting, and reduced fire risk are factors that recommend commercial forestry as the most effective land use for sequestering carbon. With the demise of our best hope of developing a native forestry industry in the MLR, (that could have provided the infrastructure and markets to support associated boutique FF activities), we are left with one obvious market for timber products, the local firewood industry. Burning wood is often denounced by urban environmentalists for reasons associated with air quality and habitat destruction; not to mention CO2 emissions. It stands to reason, wood fires are just bad for the environment, right? WRONG!

Certainly if the wood is sourced from remnant vegetation or windfall hollows, there are significant ecological consequences. However, if the wood is plantation grown for the purpose, the ecological benefits are huge. Adelaides current market for firewood is variously estimated at somewhere between 30,000 and 300,000 tonnes a year. All we know is that retail wood yards sell about 30,000 tonnes a year. Almost all of this product is trucked over 600 kms from the red gum forests in NSW and Victoria, creating a considerable carbon footprint. The opportunity exists to embrace the ecological benefits of farm forestry and create a range of other, broader environmental benefits as well. A tree harvested for firewood leaves almost half of its biomass under the ground and its smaller limbs, leaves and bark on the forest floor as mulch. Thus to produce one tonne of firewood will remove roughly twice as much CO2 from the atmosphere as will be released when the firewood is burned. Modern slow combustion stoves can be expected to achieve efficiencies of about 80%. By comparison, because the generation of electricity from burning fossil fuels is only about 20-25% efficient (this varies depending upon transmission losses), for an equivalent amount of heat, the net emissions from using electricity in resistence heaters will be approximately, 7-8 times greater. Heat pump technology is significantly more efficient, but is likely to still produce double the net emissions of a combustion heater. If the same piece of wood also heats the households water, the efficiency of the firewood increases dramatically. Currently almost all the firewood burnt in Australia comes from wild harvest. This amounts to taking 4 to 5 million tonnes of wood per year out of our woodlands and forests. This must have serious ecological impacts. Activities such as the removal of fallen timber, dead branches, live trees and hollow logs (from the ground, or standing dead trees) are removing habitat for many species. It is estimated that over 300 native species of vertebrates use hollow logs. Other impacts on biodiversity of wood collection include the spread of weeds and diseases like Phytophthora. The NSW and Victorian Governments are severely restricting logging access to their remnant red gum forests. This can only create more demand for wild harvest from either private property or public woodlands and roadsides, as availability declines and prices rise. The habitat loss, particularly of hollows can be expected to be significant. Farm forestry thus provides further opportunity to create positive environmental outcomes by filling this market vacuum.

These factors are by no means arcane and so I remain perplexed and confounded that a body such as the NRM board, charged with managing our natural heritage in a more sustainable way, seems implacably resistant to cogently confronting the case for the equitable treatment of farm forestry.

Thus a carefully designed, strategically placed analogue forest that connects remnant vegetation, improves water quality, reduces fire risk, sequesters carbon, reduces demand for wild harvest firewood and compensates the land owner for the effort of establishment and maintenance, must be granted a permit, or compete against the recreational drug industry (ie vineyards) in the market place for a water license. By comparison, someone who randomly plants the same area with pine trees, or some other exotic species, but calls it revegetation, or indeed anything but forestry or commercial, may do so without any oversight or constraint at all. Brilliant! So, let us charge our glasses with this innocent little wine from our irrigated vineyard and propose a toast: to The Clever Country. Have a nice day, Tony Dickson.