APRIL 1999 9 .

Carr's CAR reserve system by Dailan Pugh

The Carr Government has now reserved 576,000 hectares in north-east NSW since being elected: this represents an increase of 6% of the area of the north-east now reserved. This is a major and urgently needed expansion of the reserve system. So why is it that despite this significant and historical increase in reserves the outcome is considered grossly inadequate?

Prior to the last NSW State election, Carr achieved the support of conservation groups (in part) because of promises to protect old growth forest and wilderness and to undertake comprehensive regional assessments (CRAs) to establish a comprehensive, adequate and representative (CAR) reserve system. The process was to be scientific; comply with the 1992 National Forest Policy Statement; fulfill the national forestreserve criteria; and involve conservation (as well as industry) groups.

The Commonwealth Government released the first proposed national reserve criteria for forests in 1995.

Finally in 1997 the Howard and Carr governments, along with other States, agreed to a significantly watered-down version of those proposed. The criteria were meant to establish a baseline to ensure that all States met minimum national requirements.

For the north-east NSW CRAs, data on environmental entities (including 240 forest ecosystems, populations of 152 animal and 444 plant threatened species, old growth forest, wilderness and core areas for endemic species) were collected. Targets were established for each of these in accordance with the national reserve criteria. Data on cultural and nationalestate values were also collected, but were ignored by the State agencies.

The State agencies initially applied the data and reserve targets to identify over one million hectares of public lands in north-east NSW as required for addition to existing reserves. Without the artificial constraints applied by the agencies, conservationists identified 1.2 million ha as required to reasonably establish a CAR reserve system for public lands.

On 12 November 1998 Premier Carr announced for north-east NSW the creation of 358,200 ha of new national parks and nature reserves; 20,100 ha of new Crown reserves (still available for mining); and 3,800 ha of new State Forests' Flora Reserves. This total area of 382,100 ha is comprised of 141,200 ha in the Upper North East (UNE) and 240,900 ha in the Lower North East (LNE).

This brings the total area reserved in north-east NSW in the CRA process (including the 1996 decision) to 544,000 ha. An additional 32,000 was reserved in 1995. The total area covered in north-east NSW is 9.7 million ha, so the area reserved since Carr was elected represents 6% of the land area. The Government is now also considering establishing reserves over some 30,000 ha of vacant Crown lands (which is less than half of what the State agencies agreed to).

Carr's reserve additions increase the area reserved to 13.6% of the UNE and 20.4% of the LNE. It is important to recognise that the LNE includes the distinctly separate Sydney Basin biogeographical region south of the Hunter River, which already has large reserves encompassing sandstone areas. When just the area of LNE north of the Hunter River is considered, the new reserves increase the reservation to only 14.9% of the area.

The primary scientific means of assessing the outcome is to compare it to the environmental targets established to fulfil the baseline national reserve criteria (see Table). This shows that of all targets, only an average of 28% was achieved, while 21% achieved less than 10% of that required. Threatened plant and animal species were those with the poorest outcome. It is of particular concern that those species and ecosystems identified by the expert committees (including State Forests) as most vulnerable to logging did worse than the average across all entities.

Features No of %full target targets achievement 0-9.9 10-49.950-99.9 100+ Forest ecosystems 360 14% 23% 23% 39% Old growth 315 10% 26% 37% 27% Fauna 788 23% 34% 15% 28% Flora 543 29% 30% 19% 22% Centres of 45 11% 40% 47% 2% endemism All entities 2052 21% 30% 22% 28% Most vulnerable 1276 25% 35% 23% 17% entities After the new reservations there are still some 748,100 ha of forest ecosystems and 397,400 ha of old growth requiring reservation to achieve the national reserve criteria. Respectively, these target shortfalls are 3 and 4 times the total of all such shortfalls in the Carr's CAR reserve system Dailan Pugh* 10 APRIL 1999 Victorian, Tasmanian and Western Australian CRAs added together!

Almost half the forest ecosystems still requiring reservation in north-east NSW occur on public lands where they could have been reserved. Only one-third of old growth forest identified on public land outside existing reserves (as at 1998) was added to reserves, leaving 240,300 ha unreserved. Of this, 170,900 ha (71%) is still required to achieve the baseline national reserve criteria.

Old growth forests which have been protected since 1990 by Premier Greiner and since 1995 by Premier Carr will now be opened up for logging. Some form of off-reserve management is proposed for some proportion of this old growth, though as the timbersupply crisis deepens any such discretionary protection will prove to be very tenuous.

The total area of NPWS-identified wilderness in the north-east is 1,002,500 ha, of which 795,100 ha (79%) is protected in reserves. Of the 208,000 ha of wilderness to remain unprotected, some 65,300 ha occurs on available public lands excluded from reserves. In the UNE only 66% of `high quality wilderness' (NWI 12) is reserved, despite the national target of 90% or more if practicable (there was no assessment for LNE).

While the best scientific data ever assembled for north-east NSW's forests was available, in the end Carr's reserve system was a political decision aimed at appeasing mining, grazing and logging interests.

Carr's reserve system clearly fails to deliver on the science, his pre-election promises, his own forest policy, the national reserve criteria and the National Forest Policy. It is most worrying that Carr apparently ignored these when he made his decision.

The scientific data was not totally irrelevant as it did ensure that some significant areas of the very poorly reserved coastal and tableland forests were included in the outcome. It now also provides a basis for justifying the need for a greatly expanded reserve system and for identifying some of the most important areas for inclusion.

While progress has been made, north-east NSW still does not have a comprehensive, adequate and representative reserve system. There will need to be a prolonged battle to achieve even the minimalist national reserve criteria.

R.I.P. ESFM The most significant loss as a result of Carr's decision is the public forests which will remain outside the reserve system. The available timber is to be grossly over-allocated in 20-year wood-supply agreements.

With increased woodchipping, rapidly dwindling sawlog volumes, the official adoption of a phased clearfelling regime in the north-east forests, and a reduction in environmental controls, the forests outside the reserve system are in peril.

As well as the establishment of a comprehensive, adequate and representative reserve system, the National Forest Policy Statement commits both State and Commonwealth governments to implementing Ecologically Sustainable Forest Management (ESFM), though Carr has also ensured that this concept is well and truly dead.

While Carr was elected on the promise to protect old growth forests and wilderness, he left large areas of both outside the reserves with some proportion of these proposed for logging. Numerous threatened species and ecosystems remain below national reserve targets, those most vulnerable to logging being the most poorly done by. While this remains the case no-one can claim ecological sustainability.

The Carr Government has over-committed timber resources from public forests based upon the premise of over-logging for the next 20 years and then undergoing a reduction of over 50% for the next 80 years.

However, due to gross over-estimations of the available timber, the supply is likely to crash within the next decade - even the concept of sustained yield has been thrown out.

Carr was not satisfied with just reneging on his preelection promises to protect old growth and wilderness, delivering the worst forest reserve system in Australia and over-committing timber resources. In addition, his Forestry and National Park Estate Act 1998 (FNPE Act) exempts State Forests from complying with the provisions of: the Environmental Planning and Assessment Act 1979 (notably the need to prepare environmental impact statements [EISs] or species impact statements); the Wilderness Act 1987; Section 124 of the Local Government Act 1993; the National Parks and Wildlife Act 1974 and Threatened Species Conservation Act 1995 relating to stopwork orders and interim protection orders; the Timber Industry (Interim Protection) Act 1992 relating to the need to prepare EISs before logging moratoria over old growth and wilderness areas are removed; and any Act (notably the Environmental Offences and Penalties Act 1989 and Protection of the Environment Operations Act 1997) that gives any member of the public a right to institute proceedings in a court to remedy or restrain a breach of any relevant Act.

The FNPE Act establishes that integrated forestry operations approvals covering all Crown timber lands (including leasehold lands and any private land purchased by State Forests, even though they were not assessed in the CRA process) will be established for periods of up to 20 years for each CRA region.

These approvals are to be determined jointly by the Ministers responsible for environment, forestry, planning, mining and fisheries. The approvals replace independent regulation by government agencies with Ministerial discretion for determining prescriptions for the protection of threatened species and clean waters.

The FNPE Act also removes any need for public consultation over the finalisation of forest agreements for the Eden, Upper North East or Lower North East NSW. The only formal opportunity for public comment will be when the Government undertakes an extremely limited review of an integrated forestry operations approval at some unspecified future time.

APRIL 1999 11 But this was still not enough, so Carr also approved a logging regime mis-named by State Forests as "Australian Group Selection - medium". The original specifications for this regime were that 20% of the net loggable area of a compartment would be clearfelled every 10 years (with the first cut occurring immediately, taking this as Year zero); thus over a period of 30 years effectively clearfelling 80% of the loggable area (that is, at Year 30). State Forests also have a more intensive version which involves clearfelling 22.5% of the loggable area of a compartment every 7 years (again with the first logging starting at once), resulting in 90% being clearfelled over a period of 21 years. Either way, it represents a staged clearfelling of forests which will ensure that vast areas of public forests are further degraded without any due consideration of the environmental consequences.

State Forests' recognition that they have significantly degraded the sawlog productivity of vast swathes of public forests has led to their belief that the only solution is to clearfell such areas as quickly as possible, restart it, and try again. State Forests also wish to more firmly stake their long-term claim to as much productive public forest as possible by converting it into pseudo-plantations.

The Government's decision to increase export woodchipping in north-east NSW is one component of this strategy. The woodchipping will provide income to help fund this intensification. It will also help fund the extensive logging that will be required over the next decade to eke out the dwindling quota-sawlog resource. As noted by State Forests' Northern Rivers Sales Manager (in Possible RFA Outcomes - the Northern Rivers Experience, from Ross Sigley, Sales Manager, to Forest Resources, 29.10.98): The only way to realise any of the volume that is there, (assuming that would in any way be an intelligent approach), would be to have an unlimited pulp market and clear fall the forest.

While at this stage no regional integrated forestry operations approval has been granted, it is already apparent that the NSW Government has abandoned the basic concepts and principles of ESFM and replaced it with the most devastating and unregulated logging regime inflicted upon public forests in the past two decades.

The cut-an'-come-again forests State Forests' latest timber assessment descends into the realms of sheer fantasy. While State Forests have always maintained that timber is a renewable resource, they have now taken this concept to an extreme with their latest modelling software Forest Resource and Management System (FRAMES).

The architects of FRAMES were apparently so taken by Norman Lindsay's 1918 fantasy The Magic Pudding in their childhood that they incorporated its basic concepts into their modelling. FRAMES is effectively portraying that State Forests: has been eatin' away at this Puddin' for years, and there's not a mark on him. FRAMES would have us believe that the forests are indeed a magic pudding - they can be cut down one day and reappear the next.

State Forests' management history database is showing that there have been 2.87 million cubic metres (m 3 ) of quota sawlogs** removed from 1,501 compartments in north-east NSW since January 1990.

FRAMES is showing that these same compartments have a current standing volume of harvestable quota sawlogs totaling 3.26 million m 3 . It is as if they were never logged.

It is apparent that according to FRAMES not only do the sawlogs come back again as soon as they are logged, but in many cases they apparently reappear even bigger than before. FRAMES is showing that these same compartments can now be logged again and yield 114% of the quota sawlogs that they did last time (even if it was only a couple of years ago).

The most productive little puddings according to FRAMES now contain over twice the volume of quota sawlogs as that removed since 1990: Taree (320%), Urunga (259%), Coopernook (233%), Bulahdelah (324%) and Morisset (221%).

According to FRAMES and State Forests' logging history, 39% of the currently harvestable volume of quota sawlogs in north-east NSW occurs in compartments logged since January 1990.

The most extreme is the Morisset District where 84% of FRAMES's claimed quota sawlogs are in compartments logged since 1990. Overall, some 67% of the resources claimed by FRAMES are in compartments which have been logged during the last 20 years.

This clearly shows how the omission of a few key ingredients (such as logging history) from FRAMES has enabled it to perform just like a magic pudding: That's where the Magic comes in. The more you eats the more you gets.

Cut-an'-come-again is his name, an' cut, an' come again, is his nature.

PHOTO NO 2 (REMOVE WHITE BORDER) REDUCE BY 1/3 Protesters in Chaelundi State Forest Photo: T & S Grant Photographics 12 APRIL 1999 For the 223 compartments recorded in State Forests' management history database as being logged since January 1997 (the time from which FRAMES is meant to be current), FRAMES is claiming they contained 203% of the quota sawlogs which were actually removed from them. This was in a period when State Forests were trying to maximise their yields. This, and numerous other comparisons which have been made, show that the problems with FRAMES are far more significant than can be explained by its failure to account for logging history alone.

The Bulahdelah Management Area exemplifies the problems with FRAMES. After decades of overcutting and yield reductions, both State Forests and the industry agreed that, as from 1996, the annual allocation of quota sawlogs could be no more than 10,000 m 3 . Yet FRAMES identifies an annual yield of 31,721 m 3 as sustainable for 20 years. Even after the reservation of 37.5% of the area last year, State Forests are still basing their strategy upon Bulahdelah supplying 19,238 m 3 per annum for the next 20 years.

FRAMES estimates a total harvestable volume for the 30 compartments logged in 1997 and 1998 that is 703% of what was actually removed! The timber simply doesn't exist.

FRAMES gives the total volume of quota sawlogs currently available for logging in north-east NSW outside the new reserves as 8.35 million m 3 , though a reality check (taking into account logging history and actual as compared to predicted yields) suggests there may in fact only be 2.24 million m 3 in existence.

Yet the Carr Government is determined to give 20year wood-supply agreements to select private sawmill owners for a total of 5.38 million m 3 of quota sawlogs from public forests. They will be given these volumes at no cost, despite one estimate of their saleable value being at least $270 million. This is in addition to an industry assistance package worth more than $53 million on top of the existing $120 million Forest Industry Structural Assistance Package.

As well as quota sawlogs, the Carr Government is also intending to give Boral and North Forest Products an initial one million m 3 of timber over the next 5 years for export woodchips. This will be in addition to Boral's existing woodchip operations. Even FRAMES says that this volume doesn't exist!

Of course, when the timber cannot be delivered the public will have to pay the mill owners massive compensation for timber that never existed, as well as compensating them for their investment in their sawmills. However, before this occurs we will witness a major intensification of logging as State Forests utilise woodchipping to help clearfell vast swathes of public forests in the hunt for the scattered sawlogs remaining, and in an effort to "restart" the forests by converting them into pseudo-plantations.

Even if FRAMES was correct, Carr had already abandoned the concept of sustained yield by deciding to maximise timber volumes for 20 years, knowing that there would have to be a significant reduction after this time.

Given that FRAMES is so grossly overstating resources, a crash in sawlog supplies is likely to occur within the next decade.

While it will be State Forests and the Carr Government who are held accountable for this travesty, it will be the public of NSW and future governments who will pay for the Carr Government's folly, in more ways than one.

State Forests have not concocted their magic pudding in ignorance.

Many of them know it is a fantasy, as recently noted by State Forests' Northern Rivers Sales Manager: Don't we have a much greater responsibility than the one to this government, don't we have a responsibility to the people of this State _ We have just one last chance to come clean and be honest about the way things are before this UNE RFA is signed.

Neither can the Carr Government plead ignorance, as they were informed of the problem in October 1998 and were recently presented with a 190-page report assessing the availability of resources in north-east NSW which clearly proves that FRAMES is sheer fantasy.

**A quota sawlog is a large log of the highest quality with minimal defect and a centre diameter >40 cm.

* Dailan Pugh is the Nature Conservation Council of NSW's representative on RACAC.

PHOTO NO 3 (REMOVE WHITE BORDER) REDUCE BY 5% Inside a strangler fig, Cooper's Creek Photo: Dailan Pugh