SCS Global Services,
2000 Powell Street, Ste. 600
CA 94608 USA
Dear Dr. Hrubes,
RE: FSC Certification Evaluation of Forestry Tasmania
Thankyou for the opportunity to participate in the stakeholder consultation process.
As a forester and forest industry representative my submission to the Forestry Tasmania FSC Certification Evaluation focuses on just two issues.
1. Commercial Management
The forest industry in Tasmania is currently home to two mutually incompatible business models competing in the same marketplace.
The historical, traditional and still dominant business model is the taxpayer-subsidised, community service business model that frames current Tasmanian forest policy, and public forest management by Forestry Tasmania.
The fundamental basis of this model is that public forests managed for wood production are there to serve the community largely through providing regional employment. Good business, commercial management and profit play no part in this business model.
The second business model has always been present in Tasmania but has recently become more significant with the expansion of private plantations and the sale of public plantations to the private sector. This business model is used by private plantation and forest owners; it is the fully commercial, market-focused, profit-driven business model.
It is the same business model that will help drive my goal of establishing a Tasmanian Blackwood Growers Cooperative.
These two business models cannot succeed in the same marketplace. This situation is unstable and ultimately destructive to the entire forest industry. It is also a missed opportunity to realise and develop Tasmania’s significant commercial forest potential.
The traditional business model represents nothing more than a destructive antitrust, anti-competitive business model. It undermines the ability of the marketplace to function properly and put a proper price on forest products. It destroys the value of private forest assets and investment.
At the moment logs from public native forest are being transported to market at taxpayers’ expense, whilst private tree growers do not have access to any taxpayer subsidy. This is blatant antitrust behaviour.
Also please read this brief analysis of the deliberate decline in commercial focus at Forestry Tasmania over the past 20 years. Forestry Tasmania is a storm-tossed, rudderless ship:
The Forest Stewardship Council (FSC) must not give its support to this antitrust behaviour. Forestry Tasmania must not be given FSC Certification until it is restructured and managed on a fully commercial profitable basis.
2. Public blackwood forest resource mismanagement
For the last 25 years Forestry Tasmania have been overcutting the public native blackwood resource that currently forms the basis for Tasmania’s iconic blackwood industry. Using Forestry Tasmania’s own data I have summarised this sad sorry episode.
Forestry Tasmania perpetuates the message that the public blackwood forest resource is being responsibly and sustainably managed, when their own data (as shown in the above chart) clearly shows this is not the case!
The recently released Review of the Sustainable Sawlog Supply from the Blackwood Management Zone is a grossly misleading and inadequate document.
The fact that in 2010 Forestry Tasmania announced that henceforth blackwood and all other special timber species were to be managed on a “non-commercial non-profit” basis was a severe blow to the Tasmanian farmers and the blackwood industry.
Blackwood (Acacia melanoxylon) is Australia’s premier appearance-grade timber species. It is a common tree on farmland across northern Tasmania, most of which is unmanaged and until recently had little commercial value. But this is now changing.
The only way to build and grow Tasmania’s blackwood industry is by encouraging Tasmanian farmers to grow it, just as New Zealand farmers have been for the past 30 years. But Tasmania’s blackwood industry will be gone in 5-10 years due to the mismanagement and overcutting of the public resource by Forestry Tasmania. The local blackwood markets and industries will be gone before Tasmanian farmers have a chance to contribute. Tasmanian farmers will have to start the whole industry from scratch with no market price or demand signals.
The Forest Stewardship Council (FSC) must not give its support to this blatant mismanagement of Tasmania’s public forest resource. Forestry Tasmania must not be given FSC Certification until it provides a full and correct report on the nature of the blackwood resource, and manages that resource on a fully commercial, profitable and sustainable basis.
From my perspective as a forest industry representative and stakeholder there is very little positive that can be said about the current state of forest industry policy and practice in Tasmania. The industry is continuing to go backwards year after year. This comes as no surprise to me at all.
Major review and reform is desperately needed.
The Forest Stewardship Council (FSC) should not add its support to this mess by granting FSC Certification to Forestry Tasmania; not until major reforms are implemented.
Dr. Gordon Bradbury
14th October 2014