Premier Bob Carr,

Andrew Refshauge, Minister for Planning,

Bob Debus, Minister for the Environment,

Kim Yeadon, Minister for Forestry,

C/- NSW Parliament, Macquarie Street

Sydney NSW 2000

Thursday, 22nd April 1999

Dear Premier and Ministers

Friends of the Earth (FoE)/Southern Forest Alliance rejection of Southern Forest Region "comprehensive regional assessment" (CRA) process

I refer to:

* the writers previous 3 years as NSW campaign co-ordinator for The Wilderness Society (1992-5) including participation in successful forest blockades at Deua, Badja, Croobyar in NSW's Southern Forests as well as Coolangubra's 1402 area in the Eden region in 1992, and now similar position with Friends of the Earth Sydney since 1995;

* the writer's central role amongst others in organising the 1,500 strong Sydney Town Hall Meeting on February 28th 1999 (refer to attachment A, note contact number at bottom);

* the 160,000+ signatures in recent years on the Forest Protection Petition to NSW and federal politicians (refer attachment B) administered by Friends of the Earth, Sydney, including 30,000 signatures to the Prime Minister's Sydney electorate office in 1998;

* the role Friends of the Earth, Sydney played in successful lobbying against privatisation of NSW electricity assets (refer attachment C at page 10).

Specifically, I am writing to lobby against the "southern comprehensive regional assessment" of forests in the Batemans Bay and adjacent management areas. I do so because the process inevitably leads to more forest lost than protected, with 20 year logging resource security over an area which has never had an environmental impact statement, let alone restructure into existing plantation resources. These existing plantations already provide at least 75% of domestic timber production in Australia: resource economist Ms Judy Clark 1999. Nor can a CRA process possibly equate to independent environmental impact assessment. In particular FoE and the Southern Forest Alliance (referred to below) opposes the grant of funding for the southern CRA to any stakeholders on the basis it would be better to make a political decision immediately to protect all forest in community reservation proposals. Such an approach would rely on:

* the precautionary principle and the moral imperative to maintain the accumulated 3 billion years of evolution in the form of existing forest biodiversity in the Southern Forests of NSW;

* existing scientific knowledge of the environmental importance of the native Southern Forests of NSW;

* the weak economic and weak employment role of clearfell/woodchip logging industry in the Southern Forests of NSW particularly in comparison to the domestic and international tourism market and other economic sectors in this region;

* the public interest in having this area protected such that an RFA will never provide security against environmental protest and that groups like The Wilderness Society, Friends of the Earth, Conservation Council of South East Region & Canberra, and the new ChipStop group (Bega/Eden/East Gippsland) have resolved to campaign publicly outside the CRA process for our forests and are fundamentally opposed to any role for woodchippers in the broader region;

* even the few groups still tolerant of the CRA process in the Southern Forests of NSW do now specifically condone public campaigning outside a government sponsored CRA process given the evidence of the first 3 CRA outcomes (Upper North East, Lower North East and Eden). The true democratic and majority view of the largest most representative environment groups involved in forest protection campaigning in the southern region of NSW for the last 10 years completely oppose the direction of the CRA process including consequent broad logging resource guarantee legislation.

In addition to the specific circumstances surrounding the Southern Forest Region of NSW other relevant factors suggestive of a new more intelligent and progressive direction in forest policy include:

* the recent NSW marginal seats poster campaign exposing old growth and forest logging resource guarantees affecting about 800,000 hectares under the Carr Labor Government - refer attachment D - National Parks Journal (April 1999) with a mailing list of about 5,000 by Dailan Pugh; attachment E Northern Forest Flyer by Clarence Environment Centre/Dailan Pugh; Attachment C - Friends of the Earth newsletter article by this writer at page 2; "Report back" brochure by peak NSW environment groups - attachment F; and poster card re Boral old growth logging - attachment G;

* the historically low primary vote for either the ALP or Coalition parties at the recent State election as reported by Alan Ramsay in the Sydney Morning Herald indicating voters are actively looking elsewhere for a more environmentally responsible, more responsive government. This flow of voters may become a flood;

* the resignation of Mr Dailan Pugh of North East Forest Alliance from the government CRA technical committees, and Ms Lynn Orego in December 1998 (from the Ecologically Sustainable Forest Management Committee);

* the lack of an EIS ever in the Southern Forests of Batemans Bay Management Area and the grossly outdated EIS for Wandella-Dampier public forests;

* resurgence of a ChipStop campaign against Daishowa driven by Bega landholders and environmentalists and allies in East Gippsland and elsewhere determined to rid Australia of the immoral foreign owned company Daishowa;

* the statement of opposition from peak state, national and some international environment groups to the effect that international customers could not buy timber from ecologically sustainable native forests in NSW - refer attachment H;

* broad academic opposition, including the National Biodiversity Council, to regional forest agreements (RFAs) in NSW under the national forest policy statement (now 8 years old) as indicated by the recent Senate RFA inquiry and consequent announcement by shadow environment minister Nick Bolkus to give the Senate veto power over defective RFA's;

* the alarming CSIRO report of major siltation in only the last 30 years based on studies of the Murrah River in southern NSW surely indicating similar impacts in all other waterways near clearfell/woodchipping operations. Recently the national press reported that a private water authority paid $9 million in Western Australia to prevent logging damage (salinisation, siltation) to its catchment. A simple diagram attached at J indicates the loss of clean water flow;

* protests at the Boral woodchip pile recently including mock blood spilt symbolising the death of wildlife associated with the clearfell/woodchip native forest industry in north east NSW with broad media coverage in the Hunter (see clipping attached) and refer to our web page: http://homepages.tig.com.au/~foesyd/;

* recent very large public protests in Western Australia (WA) seeking forest preservation for future generations;

* the disgust of the public at the recent attempt of the national logging industry body (NAFI) which sought to ban a forest friendly timbers book with consequent investigation announced by the ACCC/Professor Fels. (Noting that BBC hardware chain have a significant commercial interest in supporting that book - which promotes plantation and recycled timbers - in competition with Bunnings hardware chain (orginally from WA), which relies on native forest logging products. Noting also the breathtaking hypocrisy of NAFI giving moral and financial succour to the misleading and deceptive "Forest Protection Society" which supports old growth forest logging and thus is literally in breach of s.52 of the Commonwealth Trade Practices Act.);

* The revelation that the WA based National Party is adopting a no old growth logging platform;

* The concern expressed by sixteen international environmentalists visiting south eastern Australia late in 1998 regarding logging practices here: see FoE newsletter attachment C at page 6.

FoE in NSW, which includes our Southern Tablelands and Shoalhaven groups, is convening a city and regionally based network under the registered name of the Southern Forest Alliance (refer attachment K). The business of the Southern Forest Alliance is environmental education and merchandise relating to the forests between Wollongong south to Narooma/Bega District, and from the western slopes/Tumut region east to the coast. (Note FoE represented by the writer was a party to the Commission of Inquiry at Tumut into the Visy pulpmill before Commissioner Kevin Cleland.) The foundation members of the Southern Forest Alliance expect to collaborate with the highly representative environment groups already named. The objective of the Southern Forest Alliance includes:

* preservation of all rare and endangered flora and fauna (and fauna habitat), all old growth, all large intact natural areas (or "wilderness"), all sensitive water catchment forests including community forest reserve proposals in the Southern Forest Region (see for instance brochure at attachment L at page 2);

* peaceful direct action;

* rejection of the southern CRA process as politically flawed;

* no woodchipping e.g. closure of the foreign owned environmentally irresponsible Daishowa woodchipping company;

* ethical sourcing of timber from existing plantations and recycled sources;

* closure of all industrial logging and milling operations using native forests in the southern region with appropriate financial packages for retraining, re deployment, and relocation for workers affected.

It could be argued that a light logging zone excluding integrated woodchipping may be an environmentally acceptable approach in the Southern Forests of NSW. However when this approach was tried by the environment groups in the Eden management area with endorsement of the South Coast Labour Council, the proposition was ignored by industry, timber union and Labor Government ministers. Clearly there is no future in compromise proposals with such an outdated industry comprehensively out-competed by the plantation sector.

Please contact the writer urgently regarding this submission to abandon the CRA process for the Southern Forests of NSW in favour of immediate comprehensive protection of Southern Forests in national parks for the reasons outlined above. I look forward to discussing this with you as soon as possible.

Yours faithfully,

Tom McLoughlin, NSW Forest Campaigner

FRIENDS OF THE EARTH, SYDNEY

CC

NSW Southern Forest defenders

FoE International Forest Campaigners

South Coast Labour Council