The following constitutes my submission to SCS Global Services as part of its assessment of Sustainable Timber Tasmania for FSC Certification.
https://blackwoodgrowers.com.au/2019/04/10/public-notification/
https://au.fsc.org/en-au
https://www.sttas.com.au/
http://www.scsglobalservices.com/
The idea that public native forestry in Tasmania is “environmentally appropriate, socially beneficial and economically viable” (FSC’s very own criteria!) is complete and utter fantasy.
Just the history of the industry over the last 5 years demonstrates the hypocrisy of this idea, never mind the forestry wars of the last 40+ years!!
The above image is taken from the Forest Stewardship Council (FSC) website. Unfortunately none of these three titles on the FSC website are live/linked. You can’t click to find out what the FSC means by “Environmentally Appropriate” or “Economically Viable”. So I typed “Economically Viable” into their search box and I got this result:
FSC “could not find any results”!!
I think the FSC has got some issues to resolve.
Luckily I have a clue as to what the FSC means by “economically viable” from the last time Forestry Tasmania attempted to gain FSC certification. The following quote comes from SCS Global Services website:
Can a company that operates at a loss achieve certification?
The FSC certification standard requires that a forest management entity have sufficient financial resources [taxpayer subsidies] to manage the defined forest area in conformance with the full scope of the standard. The standard does not require that the certified forest is managed at a profit provided that other sources of working capital [taxpayer subsidies] are available and sufficient [$ billions] to enable management in conformance with the standard.
https://www.scsglobalservices.com/news/scs-responds-to-questions-about-the-forestry-tasmania-fsc-forest-management-assessment
So the FSC defines “economically viable” as pretty much anything, including major loss-making public native forestry.
The problem is, under Australian law that is ILLEGAL!!!!!!!
It’s called Competitive Neutrality, and I wrote a blog about it back in 2016:
https://blackwoodgrowers.com.au/2016/10/17/competitive-neutrality-in-forestry/
It is Tasmania’s view that all the State’s PTEs and PFEs, together with its GBEs, are significant Government businesses for the purposes of the CPA. Accordingly, in applying the competitive neutrality principles, significant Government business enterprises are defined as those enterprises which are classified as PTEs, PFEs and/or GBEs.
https://www.economicregulator.tas.gov.au/Documents/Competitive%20Neutrality%20Principles%20Guidelines%20June%201996.pdf
This includes FT/STT.
In 1995 Australia’s governments agreed to the National Competition Policy (NCP) and Related Reforms.
http://ncp.ncc.gov.au/pages/home
The problem is many of those reforms have never been implemented, or have since been watered down.
FT/STT is a classic example!
It was corporatized according to NCP policy, but it has never been run as a commercial business. And yet it competes in the marketplace against private tree growers.
FT/STT has never publically acknowledged that it is a Government business competing in the marketplace against private forest growers both here in Tasmania and on the mainland
FT/STT has never publically acknowledged the need for it to behave in a competitively neutral manner.
FT/STT has never had any Competitive Neutrality Policies and objectives…..ever!
And every week that FT/STT gets another taxpayer handout is another breach of Australia’s Trade Practices Laws.
The fact that FT/STT has never been prosecuted illustrates the broken nature of Australia’s political system, and a conflicted forest industry.
The NCP does not discuss what should be done with Government businesses that cannot survive in a commercial world, businesses like FT/STT.
The FSC does not say where these “other sources” of money may come from or place any limits on the extent of subsidisation.
I wonder what economists think of this idea?
I wonder what private forest owners who compete in the marketplace against loss-making, forest squandering Sustainable Timber Tasmania think of this idea?
So Sustainable Timber Tasmania passes the FSC “economically viable” criteria with flying colors! What a joke!!
Never mind the long suffering Tasmanian taxpayer, or the lowly paid Tasmanian public servant!
The last 20 years
Last year this article appeared in a major Australian news media site detailing the extent of commercial losses from public native forestry in Tasmania:
https://www.theguardian.com/environment/2018/mar/29/tasmanian-forest-agreement-delivers-13bn-losses-in-giant-on-taxpayers
And that analysis was using FT’s own accounting methods!
If FT had to do its accounting like a private forest grower (ie. Competitive neutrality) the losses would be far greater. What private forest grower can value its entire land estate at $0.00??
No doubt the FSC would see this article as glowing praise for world class forest management!!
Greenpeace
The environmental organisation Greenpeace was one of the founding partners of the FSC. In March last year Greenpeace resigned from the FSC citing ongoing and significant issues with the way the FSC was being managed:
https://blackwoodgrowers.com.au/2018/03/30/greenpeace-leaves-the-forest-stewardship-council-fsc/
With Greenpeace gone it now seems that the FSC is moving towards becoming another forest industry rubber stamping organisation like the PEFC.
Buying FSC certified wood products does not save the world’s forests.
New Zealand
Imagine if this response on economic viability was given within a New Zealand context, where the forest industry is fully commercial and profitable?
“Yeah we just waste taxpayers money to grow trees and give them away! Who cares about farmers?”
New Zealand farmers would be marching on their Parliament House to bring down the Government!
Here in Tasmania? Not a whisper of protest!
Bunnings
Bunnings, Australia’s largest timber retailer, is threatening to stop selling public native forest products next year (2020) unless the products achieve FSC certification.
https://blackwoodgrowers.com.au/2018/08/04/bunnings-finally-takes-a-stand/
The marketplace is finally saying “enough is enough”!
For both Vicforests and STT this is crunch time!
Wind up
Four years ago former State politician Sue Smith called for the winding up of FT/STT. How she described the forest industry then is still the same today, but worse.
https://www.themercury.com.au/news/politics/former-mlc-sue-smith-urges-forestry-tasmania-windup/news-story/50272c2ae1798a9358999278b5563073?fbclid=IwAR2YxZMeGSksYF7eI5NxmEmnPxYe2BQ3a8vUdCmr38t1hclWC7tS3JqC-xc
How in anyone’s imagination can this agency achieve FSC certification?
Blackwood
Who is going to grow commercial blackwood when the Tasmania State government and STT waste taxpayers money giving away public native forest blackwood, supported by taxpayer subsidies and the Forest Stewardship Council?
Nothing has changed
Sustainable Timbers Tasmania does not have a business plan, nor does it have commercial objectives.
Neither does it apologise every year for its continuing waste of Tasmanian taxpayers money.
“This is the number of teachers and nurses you missed out on this year thanks to our activities. But don’t worry! We are sustainable!!”
Nothing has changed.
But from my perspective it is the failed economics of public native forestry that is the primary reason that Tasmania will never have a Tasmanian Blackwood Growers Cooperative.
If the FSC “Economic Viability” criteria are so easy to achieve, one must assume the other two criteria – “Environmentally Appropriate” and “Socially Beneficial” – are just a walk in the park!
As a forester I believe this is about the worst possible outcome for the forest industry. It is certainly the worst possible outcome for the Tasmanian community.
- And finally, who gets to pay for STT’s FSC assessment? That’s right! The long suffering Tasmanian taxpayer. Show me a private forest grower who has their FSC assessment paid for by the taxpayer. Answer! NONE!!
PPS. STT is just the forest manager. The State Government owns the forests! The same State Government that wants to log the Tasmanian Wilderness World Heritage Area. The same State Government that IS logging ancient rainforests in Conservation Reserves. For the FSC to certify STT would be an even bigger act of hypocrisy than that of the Tasmanian State Government. The Tasmanian Government determines Forest Policy NOT Sustainable Timbers Tasmania!!
When will Tasmania get a real forest industry based on profitable private tree growers?
Timber supply chain constraints in the Australian plantation sector
https://www.aph.gov.au/Parliamentary_Business/Committees/House/Standing_Committee_on_Agriculture_and_Water_Resources/Timbersupply
On 26 September 2019, the Standing Committee on Agriculture and Water Resources received a referral from Assistant Minister Duniam for an inquiry into timber supply chain constraints in the Australian plantation sector.
The Committee invites submissions addressing any or all of the terms of reference for the inquiry.
Submissions are requested by Monday, 17 August 2020.
The Committee is dominated by conservative Government members so the chances of anything useful coming from the inquiry are very limited.
Nevertheless here is my submission
Submission
Yet another inquiry into the forest industry in Australia!!!
I think it would be useful for the Committee to do a quick review/summary of every other forest industry inquiry/report. There have been hundreds over the past 50 years, with most of their recommendations having never been implemented.
The Committee could seek to answer the question why have so few previous recommendations been implemented?
Terms of Reference
To inquire and report on:
The question needs to be asked, does current and projected wood supply from Australia’s plantation sector meet current and future needs? Answer. NO!
The next question needs to be asked, if growing timber in Australia is profitable why doesn’t everyone (farmers) know about it? If it is not profitable, then what is the point of this inquiry?
Another relevant question is, what’s wrong with imported timber? If New Zealand farmers can grow timber cheaper than Australia then good luck to them I say! We do not need to be self sufficient in wood products just for the sake of self sufficiency!
This TOR definitely smacks of protectionism and market manipulation. Do you want farmers to invest in trees? If so then get rid of this protectionist bullshit. Domestic processors must compete in open competitive transparent markets, otherwise the domestic processors become increasingly high cost and uncompetitive, which has negative impacts throughout the supply chain from growers to retailers and consumers.
Who in Australia knows what the domestic and export log prices are, let alone whether they are competitive? I’m a forester with 40 years in the industry and I have never ever known!! What does that tell the Committee?
A former Director of Forestry Tasmania once said:
The lack of price transparency for forest products, particularly from hardwood forests/plantations [in Australia], represents an impediment to the uptake of farm forestry. Unlike other commodities, price information for forest products is not published through the newspaper or accessible online. Better price transparency is required to encourage smallscale investment in trees.
Curiously Forestry Tasmania has never ever supported price transparency.
New Zealand has a REAL forest industry with excellent log price transparency. Australia has a completely dysfunctional forest industry.
This TOR, like the second TOR above, is all about destroying the forest industry through market manipulation and protectionist policies. Local processors must compete in open competitive transparent markets. It is NOT the job of dairy farmers to subsidise cheese makers NOR is it the job of tree growers to subsidise local industry.
There are abundant opportunities to increase Australia’s wood supply, but they are vastly outnumbered by the barriers to plantation establishment. Many previous forest industry reports have addressed these issues, with all those previous reports now collecting dust on library shelves around Australia.
I have to ask why we need yet another report when the answers are already known! The forest industry in Australia is completely dysfunctional. Does it behave like a commercial business desperately wanting a future? No it does not!
All State Governments that engage in public native forestry (WA, Vic, NSW and Qld) are all engaged in industry-destroying Welfare Forestry. Welfare Forestry is all about subsiding processors and “saving jobs”. It has nothing at all to do with real commercial forestry.
The forestry industry in Australia has no future whilst Welfare Forestry continues to undermine the industry.
State Governments should be encouraging profitable tree growing, but all of them refuse to do this.
Please read all previous reports and inquiries and implement the recommendations!
But as just one example, New Zealand has a single set of environmental regulations that apply to all primary producers. The regulations do not discriminate against the forest industry. Similarly to overcome differences between local Council regulations, the NZ forest industry implemented a single set of plantation management guidelines that work across the entire country. Contrast this with Australia where the industry faces a mountain of diverse changing regulations across the country.
How can Australia hope to compete with NZ? We can’t! It is not possible!
Blackwood
Blackwood (Acacia melanoxylon) is Australia’s premium appearance grade timber. It can be grown successful in plantations, as NZ farmers are doing, and potentially it has a very high market value. But most blackwood comes from Tasmania where the State government and the forest industry work to undermine the market and supply the market with cheap taxpayer subsidised blackwood. Transparent competitive markets for blackwood do not exist because neither the Government nor industry want transparent competitive markets.
Attempting to establish a Tasmanian Blackwood Growers Cooperative is therefore impossible due to Government and industry policy.
Conclusion
I’m a forester with 40+ years experience in the industry. And for all that time, after hundreds of forest industry plans/strategies/inquiries and reports the industry in Australia remains moribund and dysfunctional.
New Zealand has a real forest industry, one of the most successful in the world. But we choose not to learn from their example. Up until 1990 the NZ forest industry was run by the Government, including public native forestry, plantations and sawmills. In the early 1990s the New Zealand Government decided to get out of the forest industry entirely. Public native forestry was shut down, and plantations and sawmills were sold. Since then the NZ industry has gone from strength to strength, and is now one of New Zealands major industries; fully private, commercial and profitable!! Do they still have challenges and opportunities? Absolutely! But they are committed and capable of resolving every one!!
The NZ forest industry is now 30 years ahead of the Australian forest industry and pulling further ahead of us every day. Will Australia even have a forest industry in another 30 years time? Not if we keep going the way we are!
Good luck with your Committee and its report and recommendations.
Sincerely,
Dr Gordon Bradbury
Hobart
Tasmania
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