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27 March 1998 Visy pulpmill Commission of Inquiry for the NSW Planning Minister

Submission by Tom McLoughlin then of Friends of the Earth Sydney 27/3/98 relating to Visy pulp/paper mill at Tumut NSW Australia based on exotic plantations in that area.

Commissioner Kevin Cleland,
Visy Kraft Pulp & Paper Mill Proposal (Tumut) Inquiry
Office of Commission of Inquiry
Level 13, 301 George St
Attn Stuart Wilmot

Friday 27th March 1998.

Dear Sir

Re Submission to inquiry at Tumut as a party Mon 30/3/98 - Thurs 2/4/98

I refer to our letter to the Commissioners dated yesterday regarding an extension of time for the following submission (attachment A), and concerns regarding time for submissions and lack of resourcing for community environment organisations.

Introduction and some background documents

A profile of Friends of the Earth relating to our status as a community based voluntary conservation organisation at local, national and international level (currently 58 countries) is found at attachments B, C, D, and F.

Significantly we have regional NSW groups at Southern Tablelands, Shoalhaven, and Cooma (refer attachment C).Along with other environmentalists the author attended two meetings in recent months with the Visy project team to discuss their proposal.

Similarly the author assisted with lobbying of the NSW government prior to their introduction and recent passage of "resource security" type legislation for access to publicly owned plantation to feed the current proposal. In this respect please refer to attachment G.

The concerns reflected in the letter at G. is discussed further below. Also refer at H. to the response of the Deputy Premier. I refer the Commissioner to the Visy Mill Facilitation Act 1997 (NSW).

Other source documents I strongly urge the Commissioner to obtain and peruse relate to:

* recent academic research regarding the ecological sustainability of pine plantations produced in the last couple of years by Greenpeace New Zealand by Mr Grant Rosoman called The Plantation Effect. This document is well regarded and leading research accepted by the international environment community as a significant contribution to policy analysis. A copy will be tabled at the Commission in Tumut.

* the Report of the National Plantation Advisory Committee 1990 produced by the Commonwealth Government, possibly the former Dept of Environment Sport and Territories. A co-author from memory is a Mr Sean Cadman currently employed by the Commonwealth in Canberra.

I will try to obtain this document for the inquiry in Tumut.

* refer to attachment J. indicating the position of the NSW environment movement in support of splitting the ownership of publicly owned plantations (but not the land) from State Forests to private owners subject to rigorous environmental controls.

* refer to the Timber Plantation (Harvest Guarrantee) Act 1995 (NSW) and the scathing criticism of this legislation which I understand was not proclaimed for perhaps 18 months because of numerous policy problems including the promotion of native vegetation clearing that it created (attachments K1-4).

* refer to the Timber Plantation (Harvest Guarantee) Regulation 1997 (NSW), the harvesting code within that regulation (schedule 1) and Regulatory Impact Statement (April 1997). There are ongoing concerns about the rigour of this code and the necessity for a strong code to apply at establishment stage (refer attachments S 1-2).

* refer to other indirectly related background material on plantation utilisation and policy issues at attachments

L1-3 (re unused plantation stockpile to substitute for native forest), and M1-2 (opposition to export of whole logs causing a loss of domestic processing jobs for Australians).

Specific concerns to resolve about the Visy proposal

FoE acknowledges the limited environmental benefit of the proposal mentioned in the Summary to the EIS at p11-2 regarding use of waste paper and consequent saving in landfill capacity.

However we are unaware of salinity issues for this region (p11-2 EIS Summary) and whether tree plantings are needed around Tumut as urgently as other agricultural regions for water table management.

Further, the implication that the proposal assists with net greenhouse reductions needs to be more thoroughly analysed to be proven. There is no doubt greenhouse gases are bound up in newly established plantation trees just as other gases are released in massive amounts in the short to medium term when plantation trees are pulped then converted to packaging products and then disposed of via landfill or perhaps burnt. Note too that byproducts of the proposed manufacturing process here are to be burnt as fuel adding to greenhouse emissions. It appears that this proposal at best may only be greenhouse neutral.

Our view of claims regarding greenhouse emissions may vary depending on the volume of sawn timber produced and the longevity of that timber product in the marketplace. In any case assessment of greenhouse gas additions and reductions is a complex one. The supporting documentation in the EIS does not appear to address these calculations at all.

In this regard reference may be made to an analysis of the false claim that "logging of old growth native forest with replacement by quicker growing regrowth forest" provides a net greenhouse reduction. The Commonwealth's now disbanded Resource Assessment Commission 1992 report into the timber industry debunked that claim by tracking the amount of native forest to woodchip transformed in the short term to greenhouse producing waste paper. This indicated keeping the old growth in place was far more significant for providing an ongoing storage of greenhouse gases than regrowth was in providing a new sink for greenhouse gases.

Environmental management of timber plantations

The NSW environment movement displays mixed feelings about pine plantations in terms of their environmental impacts. Some frequent issues raised by the public and environmentalists are mentioned here:

There was outrage in previous decades when Australia's forest biodiversity was laid waste for the establishment of the exotic softwood plantation estate. This is the first most devastating environmental impact of many pine plantations. One critical test of the ethics of the current proposal before the Commission of Inquiry will be to what extent this proposal will avoid native vegetation clearing. A worrying comment in the EIS states at p11-27 says

"Some clearing of individual trees, patches of regrowth and isolated remnants is inevitable, but the processes in place to consider a range of values provide adequate protection." [emphasis added]

Really? The NSW State of the Environment Report 1997 p172 states South Eastern Highlands has 59.2% already cleared or thinned, while the adjacent south western slopes has an appalling 94.2% cleared or thinned. The same report at p174 indicates statewide clearing rates up to recent years are somewhere between 120,000 ha and and 150,000 ha and perhaps even more. Therefore there is absolutely no reason to be complacent about protecting native vegetation that is still in place.

Presently the majority of the forest conservation movement has a pragmatic approach to this historical destruction. The focus is now threefold. Firstly prevention of the same clearance happening again and protection of existing native forest heritage - hence the current Comprehensive Regional Assessment process being undertaken in NSW for native forest protection.

The secondly concern is for substitution of existing stockpiled plantation for jobs and wood products which previously were sourced from native forest. In this respect refer to attachments L1-3 Similarly refer to attachments M 1-2 regarding the intense opposition amongst environmentalists and unions to whole log export of plantation timber resulting in the loss of domestic processing jobs and the ability to transfer employment to a plantation base.

The third concern is to expose and reform ecologically unsustainable tree farming practices associated with industrial plantations. For instance there is major concerns emerging in the environmental community and FoE regarding chemical and fertiliser poisoning of watercourses, clearfell harvesting causing soil erosion and further water pollution. The leading academic work on this policy area was referred to in the background documents above by Greenpeace New Zealand's Mr Grant Rosoman in The Plantation Effect.

There are also serious precedents in Australia of real environmental damage. A sister group within Friends of the Earth based at Lorinna in north west Tasmania, and the Native Forest Network also in Tasmania report significant current effects of pine plantation establishment on their region's social and environmental viability:

- vegetation clearance for plantation establishment. (There needs to be a condition of consent preventing this from happening.) There have been examples in South Australia in recent years of significant clearing for plantation (refer to end of attachments to attachment K30. Also there has been great alarm over clearing of private land on Mt Pikapene near Casino in north east NSW in a joint venture with State Forests of NSW (formerly known as the Forestry Commission of NSW).

- the loss of community fabric as a result of mixed farming being ousted by land sales to a single plantation developer

- use of chlorinated triazine compounds which include Atrazine and Simazine which have poisoned the local water supply. These chemicals have been shown to cause cancers, tumours and lymphomas in both humans and animals. The plantation operator Boral in Tasmania continues to use triazine compounds including Hexazine for its pine plantations and Simazine on its private land.

- Boral has a belated trial of repellent alternatives to the wildlife poison 1080 which targets and kills thousands of native animals in Tasmania annually. [These issues relating to Boral were raised in a leaflet circulated to all Boral shareholders present at their 1997 AGM held in Sydney - refer page 2 of attachment Q.]

- loss of 1/3 water yield from catchment areas in the early plantation establishment stages, which lost water yield returns over time - as the plantation canopy closes - but always 1/10 less in water yield thereafter (Ms Annie Willock pers. comm, and see generally her statement at Q2).

Similarly in north east NSW at Dundurrabin there has been controversy in the last two years over the threat the water supply of that small rural community from a State Forest plantation trial. One response to the dispute was the trial of chemical free weed control methods: contact Ms Rosemary Crane, Dundarrabin Land Care Group.

Again another area of concern in this third category is post harvesting re-establishment issues: Is the area appropriate for native revegetation as a conservation link, or to ameliorate serious environmental damage of past years? Is the plantation area appropriate for mixed eucalypt hardwood plantation instituting a different and more bio-diverse form of tree farming. Would this be better economically in terms of longer fibre inputs to the pulp process?

For another aspect of the management issues refer to correspondence at attachment P 1-3 regarding cable logging impacts on stability and soil erosion on the hillsides around Blowering Dam by Frank Miller of FoE Southern Tablelands, and the consequent unanimous 1997 annual conference resolution of the Nature Conservation Council of NSW amplifying his concern. (The NSW NCC represents over 100 environment groups in NSW including local and national peak groups.)

These above examples indicate the necessity for an environmentally rigorous plantation management and harvesting code for the NSW plantation industry to take the timber industry into a sustainable agricultural future. One must ask and answer the question therefore just how rigorous and protective of the surrounding environment is the legislative harvesting code now in place in NSW and the timber plantation practices code (EIS p11-29) being developed by Visy? It is noteworthy that the Visy code is not a formal part of the EIS. This is a significant gap in the documentation of the proposal, perhaps making approval quite uncertain in terms of the actual scope and shape of the proposal in fact before the authorities for determination.

As the Commissioner will know there is legal precedent against any determination of a development proposal leaving significant decisions still unmade such that no real determination has been reached.

Certainly there is grave reservations in the environment movement as to the environmental integrity of the legislative code for which NSW State Forests has carriage of policy decisions. Over more than 18 months since the 1995 Act the draft code was stalled for this lack of environmental integrity and now that it has been proclaimed it is clear that the final code is mainly unresponsive to the constructive criticism and suggestions from experienced environmental negotiators representing environment groups e.g. North East Forest Alliance (Ms Lynn Orego) Friends of the Earth (the author) and others.

For a critique of the Timber Plantations (Harvest Guarantee) Act 1995 refer to attachment K1-4. For a critique of the legislated code refer to correspondence and copies of working/handwritten documents at S1-3.

It seems clear that a process is needed to develop a plantation management code that properly reflects Visy's commitment to environmental excellence. FoE urges the Commissioner to recommend the proponent develop at their expense a best practice timber plantation management code in consultation with experienced, representative environment groups, with those groups resourced by the proponent to do real justice to the task.

Ultimately, Friends of the Earth is seeking ecologically sustainable agricultural practice in tree farming as for other agricultural pursuits such that there is less and less reliance on damaging chemicals, and realistic levels of domestic and foreign consumption of wood products to fit our ecological space and to respect inter-generational equity.

Lastly FoE includes a discussion paper from Clarence Environment Centre on issues around plantation policy. FoE Sydney has not had time to review this document but includes it for the information of the Inquiry. Refer attachment T.

Forest resource impacts

Attachment G is a copy of correspondence from the peak environment groups in NSW seeking amongst other things assurances that the plantation feedstock for the Visy Mill do not ruin transition strategies in other parts of NSW including Eden and Southern CRA regions e.g. plantation stock at Bombala. Visy has argued this proposed mill will not impact on other employment and processing opportunities because sawmilling will not be affected by pulp production.

FoE submits there must be guarantees to prevent pulping of sawlogs grown at significant public cost in terms of social, environmental and financial outlays.

Waste water - p 5-3 EIS Summary

It is stated future private re-use of waste water and runoff will comply with "the Visy environmental objectives for sustainable irrigation". these are not defined" [query are they contained in the EIS proper and if so what is the merit of them?]

Winter storage of irrigation runoff - p5-3, 3-8 EIS summary

It is stated at p5-3 "A runoff collection and recycling system for irrigated pasture, and a discharge pipeline to Sandy Creek from the winter storages to allow for particularly wet years which will occur 1 in every 10 years on average."

The community has demonstrated its concern to achieve the objective of primary contact water quality standards compared with maintaining the status quo or merely protecting aquatic ecosystems or achieving secondary contact quality: EPA community forums mid March 1998 held at Holbrook, and Tumut which considered environmental objectives for inland river water quality and river flows.

In this respect the Tumut River already fails this community standard now for a significant period of time: Refer p3-8 EIS Summary indicating there is a 25% non compliance with the NSW EPA objective of "protecting aquatic ecosystems", a standard which is already a lesser standard than "primary contact" sought by the community.

It is submitted the proponent must ensure that the Tumut River water quality is not degraded further. For instance even in high flow times when there is significant irrigation runoff discharged to Sandy Ck and then Tumut River this chemical load is still an incremental impact along with all other pollution sources. Also the Tumut's chemical load still ends up in the Murrimbidgee which presently is severely compromised in terms of water quality.

It is submitted the winter water storage will need to be of significantly greater capacity to contain irrigation runoff up to a level of one in every 50 years.

Transport impacts - rail upgrade

Impacts from truck transport are a concern to the local community and will affect road maintenance costs and create noise with consequent loss of amenity.

Serious consideration is warranted for the re-establishment of a branch railway line from Cootamundra - Gundagai - Tumut - Batlow.

It has been suggested that this might cost in the order of $75 million. Therefore the Commissioner is urged to make recommendations to the proponent and all levels of government to develop a funding package for this overall more efficient and environmentally friendly method of transport.

Some avenues for funding might include:

- the proponent Visy


- the orchardists at Batlow and surrounds

- FreightCorp/Freight Rail Corportion

- the new owner of National Line railways

- the Federal Government's Federation Fund

- the tourism industry and their related government agencies

- timber industry restructuring and/or development funds

- private enterprise generally

Air quality impacts

FoE shares the concerns of Tumut Shire Council (Report to Council dated 17/3/98 pp 3-4) that air quality impacts may be unacceptable unless rigorous controls are in place. It is for the proponent to prove ahead of time they are capable of this high standard of compliance, rather than by trial and error. Incremental air quality impacts must be factored in to conditions of consent for individual development applications.

Aesthetic impacts

Another impact is an aesthetic concern of many in the community often stated by way of comparison with the visual diversity of under storey, middle storey and canopy of a native forest. This is quite a subjective matter, especially on existing cleared or agricultural land but it is still surprising the genuine rejection stated by a section of the public.


There are major unresolved issues challenging Visy to achieve it's stated goal of environmental excellence. One area is movement toward and achievement of ecologically

sustainable plantation management. Another is integration with the forest reform process in NSW in terms of forest resource impacts.

Other challenges include maintenance of water quality and air quality.

Lastly, there is a general challenge to all stakeholders to push for re-establishment of a rail link to the region.

Thankyou for consideration of our submission.

Yours faithfully

Tom McLoughlin Bsc (zoo)/ Llb (hon)


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