Chapter 4
Comment on Issues Raised by the Bill
RFAs and confidence in the forest estate
4.1 The Tasmanian State Office of the Forest Protection Society told the inquiry the Bill will allow
Australia's commercial forests to be managed according to the principles of sustainable management. It is
the view of the Society that sustainable development of native forest resources will give “ … a future to
regional communities and ensure that the social and economic benefits of each Regional Forest
Agreement are achieved.” [1]
4.2 The Bill provides RFAs with the legislative backing to ensure that all Australians have confidence in
the long-term future of Australia's forest estate. It is the view of the Commonwealth Government that this
confidence will be further sustained through:
- the enactment of State legislation, where necessary, to authorise wood supply arrangements and to
declare and protect agreed forest reserves; and
- the provision of ongoing wood supply agreements and contractual arrangements between
individual States and companies where State owned forests are involved. [2]
4.3 Minister Tuckey told the House of Representatives that the Government firmly believes that “…
community and investor confidence in forest industries will be best secured by strong RFAs which
provide for ecologically sustainable management of our forests.” [3]Mr Tuckey went on to state:
This Bill, together with complementary State legislation and strong wood supply
contractual arrangements between industry and State governments, will provide that
confidence. [4]
RFAs and ecologically sustainable management
4.4 In the view of some contributors to the inquiry the Commonwealth Government's confidence in the
potential of RFAs to bring about ecologically sustainable management of our forests is misplaced. The
Southern Tablelands NSW Branch of the Friends of the Earth told the inquiry that any forest
management that uses clearfelling and other intensive harvesting methods “cannot possibly achieve
ecological sustainability”. [5]
4.5 The Native Forest Network, Southern Hemisphere, advised the inquiry that in relation to Tasmania's
RFA; “This failure to adequately reserve old growth immediately calls into question the validity of the
`ecologically sustainable forest management' process.' [6]
4.6 The WA Forest Alliance commenting on the West Australian RFA stated:
At the moment, the forests are not being managed in a way that is remotely ecologically
sustainable, and that is true whether you are talking in the narrowest terms of rates of log
extraction right through to the much broader concept of maintaining the ecosystems and
biodiversity. Under the RFA, it is inconceivable that the situation will improve, so the
conflict and the debate are just going to continue indefinitely until we can actually resolve
those issues. [7]
4.7 It was alleged during the inquiry that:
The development of sustainability indicators and 5 year monitoring currently appears to
be more of a delaying tactic to maintain business as usual than any substantive drive
towards sustainability. [8]
4.8 Mr Robert Pearce replying to a question from Senator Brown concerning sustainable ecology during
the Melbourne public hearing presented a different view of the issue when he stated:
I have noticed that when people like yourselves who argued for sustainable development
20 years ago discovered that in fact you can have a sustainable development
arrangement in the forests whereby the needs of the environment are looked for and the
forests are harvested on a sustainable basis, you have jumped ship on sustainable
development and started trying to develop other definitions which mean, in effect,
sustainable ecology, that you cannot do these things. You have done that, Senator,
because you have discovered over time that the sustainable development thing which you
argued for 10 or 15 years ago did not produce what you want, which is no industry at all
in a good many areas of Australia. Although you are here arguing that about the forests
today, you will be in other committees arguing about other industries in other areas of
Australia on other occasions.
My definition of these things is that you strike a balance between all of the needs of our
people, and they do require large areas of untouched natural forest, on your definition
and mine, put aside and safeguarded for all generations in the future. I agree with that and
our industry agrees with that, and it is the striking of the balance which is important there.
But our people also need jobs and our people use timber and paper and timber
products. They use more than they produce, Senator, and people in Australia who argue
for the proposition that we should not touch our own forests but continue to use wood
and paper products in the way that we are simply arguing for ripping off other people's
forests, and that is not a position which I believe is morally sustainable. [9]
4.9 Professor Harry Recher noted:
If there were any doubts that the RFA process was ever intended to be more than an
exercise in granting resource security [to the timber industry] under the mantle of scientific
credibility, these were dispelled by the re-working of the original scientific criteria by the
National Forest Policy Statement Implementation Sub-committee (JANIS). JANIS
rephrased the criteria in ways that ensured that science and the conservation of forest
biodiversity did not interfere with the political agenda of resource security.
4.10 Mr Alan McMahon (p 114 et seq) gave evidence that the scientific assessments that formed the
basis for the Central Highlands RFA were incomplete -
Under the deferred forests process with the Central Highlands RFA, the Commonwealth
sought an undertaking that Victoria protect cool temperate mixed forests. In the Central
Highlands Forest Management Plan it was stated that mapping of these forests was
incomplete but, once completed, an assessment would be made and reservations would
be in accordance with the ecological vegetation class guideline, that is, up to 90 per cent
of the cool temperate mixed forest could have been reserved if they were found to be a
rare EVC.
4.11 Mr McMahon also questioned whether ecological sustainability would be achieved through the
RFA -
I think one of the problems is that the forests are overcommitted. One of the principles of
the RFA is ecologically sustainable forest management, but nowhere in the RFA has it
been proved that this is occurring. Sustainability indicators have not even been chosen
yet. Predetermined timber volumes were built into the RFAs, meaning that everything else
had to fit around them, whether this could be done realistically or not.
4.12 The Aboriginal Legal Service of Western Australia (Inc) also emphasized that Indigenous people
have a range of interests in relation to forests
The part of the Regional Forest Agreements Bill 1998that we have concerns about is
clause 5 of the bill, which provides that the effect of forestry operations can be discarded
for the purposes of the trigger sections of the Australian Heritage Commission Act, the
World Heritage Property Conservation Act and the Environmental Protection
(Implementation of Procedures) Act. Our objections are in two main areas. The first one
is that it is improper to remove the Commonwealth heritage and environmental
protections from areas covered by regional forest agreements.
The second focus of our objections is that at the moment it is quite premature to be
considering this bill given that it is impossible at the moment to consider what heritage and
environmental protections will exist in place of these key pieces of Commonwealth
legislation, particularly when only a few regional forest agreements have yet been
finalised, and when nearly all the relevant Commonwealth and state legislation in heritage
and environmental protection is either under review or is actually in the process of being
repealed or replaced.
Termination of RFAs
4.13 Under the provisions of the Bill (clause 6) the Commonwealth Government proposes that all existing
and future RFAs be strengthened by providing that termination by mutual consent of the parties can only
take place 12 months following a notification of intention to terminate the agreement. This provision will
allow a full review of the operation of the RFA to be carried out. [11]
4.14 The Bill's second reading speech in the House of Representatives stated:
The Bill will ensure the termination of an RFA will have no effect unless it is done in
accordance with the RFA's termination provisions. It will also ensure that the
Commonwealth is liable for any breach of an RFA it makes which occurs while it is in
force, even if the agreement is subsequently terminated or expires.
The Bill's provisions will mean the Commonwealth will not be able to agree to `water
down' such termination or compensation provisions in the future without legislative
amendment. [12]
4.15 The Environmental Defenders Office in Tasmania was critical of the termination provisions set out in
the Bill, arguing that:
The RFA Bill presently provides that the Commonwealth may terminate an RFA with a
State if that State commits a material breach of the agreement. The Commonwealth does
not, however, have the power to enforce compliance with provisions of the agreements
where a breach is not material. This gives rise to two possible outcomes when an RFA is
not being strictly adhered to - the Commonwealth can do nothing but wait until the
breach worsens and thus becomes material, or it can fully terminate the agreement. Due
to the costs involved with termination and renegotiation, the States will realise that the
threat of termination of an RFA is a toothless tiger unless a breach is substantial, Small
breaches are likely to go unchecked. [13]
Resource security and RFAs
4.16 The Commonwealth Government claimed that the Bill “ … provides a high degree of certainty for
conservation and environmental interests, forests and forest products industry operators, recreational
users of forests and the broader community in that significant commitments made under RFAs will be
supported by legislation.” [14]
4.17 The Forest Protection Society advised the inquiry:
The most fundamental issue confronting regional communities involved with forest
industries relates to 'security' and 'certainty' following decades of insecurity and
uncertainty surrounding access to forest resources. [15]
4.18 The RPS went on to comment, “…the absence of reasonable security of access to forest resources
has negative effects that touch all levels of the economic and social structure of timber communities.”
[16]According to the FPS:
The need for security and certainty is often magnified at the local community level given
the high levels of personal investment and debt risk undertaken by businesses in the forest
industries as well as the limited range of local employment/business alternatives. [17]
4.19 Senator Shayne Murphy, appearing as a private witnesses, stated in evidence:
What we have to ensure is that those people that seek to draw on the resource to create
employment and downstream processing get access to it. That is the critical factor. We
also have to ensure that the contractors that have made investment in plant and
equipment are able to continue in employment by proper utilisation of the resource that
ensures that there is more work for them. [18]
4.20 Mr Paul Lennon, Deputy Premier and Minister for Infrastructure, Energy and Resources in
Tasmania commented to the inquiry:
What we need is the security of resource. Then we can develop our commitment to
downstream processing. The Commonwealth legislation provides us with that. We
believe we have delivered on our part of the commitment. We are looking for the people
of parliament to support the Tasmanian regional forest agreement and to honour the
commitments in the document that was signed some 12 months ago. We have honoured
our commitment; we have legislated the reserve system provided for in the Regional
Forest Agreement. What we now require to show to the international community, the big
investors in particular, that Tasmania is a place you can invest in now with some security
is the Commonwealth to honour its commitment. [19]
RFA and employment
4.21 Mr Geoff Law of Tasmania, in his submission, detailed the reduction of employment in Tasmania's
forest industry that has taken place over the years over recent years. However, Mr Law argued that the
“… adverse impacts on employment in the Tasmanian timber industry have occurred not because of
conservation, but because of economic rationalism, in particular the de-regulation of trade and the
large-scale takeovers by multinational corporations …” [20]
4.22 Ms Patricia Townsend of the WA State Office of the Forest Protection Society claimed that if all
remaining old-growth forests in WA were reserved the cost would be 1 313 direct jobs and 1 576
indirect jobs. It was estimated such a reservation would have an impact on 7 222 people in Western
Australia. [21]
4.23 The Busselton-Dunsborough Environment Centre in Western Australia advised the Committee that:
The argument that jobs will be lost if old growth forest is protected is short sighted. This
same argument was used in support of maintaining the whaling industry in Albany. Timber
workers, like the rest of Australians, must be prepared to change their employment to
suit the changing times. It is considered that funds should be used to assist timber
workers in re-training and finding other employment. [22]
4.25 In her evidence to the inquiry Ms Judith Clarke stressed the importance of plantations to the
creation of employment in the forest industry. Ms Clarke stated:
Let us get to the point about the RFA. How has the RFA process taken into account this
plantation resource? I will read some of the key points from my submission. The Western
Australian RFA document was presented for public consultation. Not one Western
Australian RFA option presented for community consultation included the plantation
resource. Plantations already account for two-thirds of Western Australia's production of
sawn timber and wood based panels, and production of these products is projected to
almost double virtually immediately. But none of those current activities or processing
opportunities was included in this document—the RFA options presented for community
consultation. ...…
…
That contrasts with the native forest sector that puts most of its wood into a chip mill and
onto a ship. There are virtually no jobs in that part of the industry, so from a social
perspective the first thing you would focus on is an industry policy surrounding processing
plantation wood in Australia. From a social perspective, that is where the jobs are
generated, and that is where the stable jobs are, because the plantation industry is the
more competitive part of the industry. [23]
4.26 Ms Clark told the inquiry that the forestry industry in Australia is not a native forest industry any
more but a plantation industry and that the plantation sector of the industry is dominated by a
manufacturing ethic. Among the most significant points made by Ms Clark were:
- today plantations account for 70 per cent of the wood used by Australia's pulp and paper industry,
60 per cent of the country's sawn timber, 90 per cent of the wood panels produced and 80 per
cent of the veneer produced;
- native forest account for only one quarter of Australia's production of wood products;
- Australia's wood and wood product industry is now clearly plantation based and the domination of
the forest industry by plantations will continue to increase; and
- woodchip exports from native forest now account for about 60 per cent of the volume of wood
logged from Australia's native forests. [24]
4.27 Ms Clark also noted the lack of data to enable identification of employment levels in the
plantation-based and native forest-based industries.
The RFA process in a bureaucratic sense has already cost Australian taxpayers over
$100 million. That is conservative. It will probably be increased by a factor of many
times. As an aside, I was intrigued yesterday when Robert Bain of the National
Association of Forest Industries was asked by one of the senators, `What is the
employment level in the plantation industry and the native forest industry?' That most
basic question could not be answered. We have seen $100 million expended on a
process and we still do not have the answers to basic information; namely, how many
people are employed in the plantation industry and how many people are employed in the
native forest industry. Last night I looked up the figure of how many people are
employed in the entire industry and again in this document the figure is 62,000, not the
80,000 that Robert Bain stated. [25]
4.28 In evidence to the inquiry's public hearing in Melbourne Mr Keith Kessell of Bunnings Forest
Products described his company's activities in Western Australia involving value adding. Mr Kessell
stated:
In terms of value adding, with one of our sawmills, the Deanmill sawmill down at
Manjimup, 10 years ago about 70 per cent of the output of that mill went into structural
use, into roof timbers and general structure use. Now up to about 95 per cent of that
mill's output has been achieved into value adding … Bunnings is up to about 70 per cent
of its jarrah intake being value added. Our corporate planning contains a similar objective
for karri … our clear strategy is to move these hardwoods into value added uses. [26]
Mr Kessell went on later to state in evidence:
The industry is in transition in Western Australia and increasingly pine is already starting
to replace the traditional uses of hardwood in structural uses. … the Deanmill sawmill
used to produce 70 per cent in the structural and it now gets up to about 95 per cent to
97 per cent in the value added. We have a big investment and it is part of our strategy
that pine increasingly is used in the traditional areas where hardwood used to be used.
That is why we are investing so much money in value adding hardwoods, for them to be
used in higher value uses—furniture and flooring and other uses—and developing
markets for that. [27]
RFAs and compensation
4.29 Clause 7 of the Bill sets down the obligation of the Commonwealth Government to pay
compensation to a State for a breach of an RFA by the Commonwealth. [32]
4.30 As stated in the Bill's second reading speech the Commonwealth proposes that all RFAs will
include obligations on the part of the States to initiate compensation action on behalf of industry where a
Commonwealth breach of an RFA results in a case for compensation. [33] The right to compensation
will exist even if the RFA is terminated or expires. It is claimed that this will ensure that the
Commonwealth Government cannot “… effectively change RFA termination or compensation provisions
in the future without legislative action.” [34]
Opposed to compensation provisions in the Bill
4.31 The Conservation Council of Western Australia expressed opposition to the inclusion of
compensation provisions in the Bill:
If there is any justification for paying compensation to timber and woodchip companies
for any reduction in the extent of the privilege extended to them to exploit for their own
profit the publicly-owned forests of Australia, this can be adequately covered in.
contracts between forest management agencies and the companies. [35]
4.32 The Amcor Green Shareholders Strategy Committee stated:
The payment of compensation by the Commonwealth Government for the changes in an
RFA locks future generations into our mistakes by dint of the prohibitive economic
penalty imposed on them if they (sic) were change. …
As tax payers we should not have to compensate an already heavily subsidised industry
for the change that has been expected an undertaken in other more competitive areas
without legislated provisions for compensation. [36]
4.33 The National Council of Women of Australia expressed concern about the imbalance between the
timber industry and ecological protection in relation to the compensation provisions in the bill, and also
pointed to the lack of any minimum requirement for investment and downstream processing --
The Bill requires that the Commonwealth compensate State and Territory Governments,
as required by the Regional Forest Agreements. This appears to our membership to
require the Commonwealth to pay unspecified damages from taxpayers' money.
However, there is no provision for a reverse process if those with access, or States and
Territories fail to adequately protect and maintain Australia's forestry resource and its
eco-systems. The Commonwealth will be also responsible for trying to re-build damaged
eco-systems, etc. when a species, habitat or eco-system becomes threatened, etc. This
will be a tremendous drain on its resources.
Support for compensation provisions in the Bill
4.34 The NAFI supported the compensation provisions set out in the Bill. The Association argues that
investors must have confidence that under a worse case scenario, for example if their wood supplies
were diminished they would have the legal opportunity to seek compensation from the “offending
government”. [37]
4.35 The FPS in its submission to the inquiry expressed its strong support for compensation provisions in
the Bill. According to the Society, “… a legally binding agreement, including provision for third party
compensation should offer communities reasonable security and certainty as well as a formal avenue of
recourse should an RFA be changed or terminated resulting in economic hardship for businesses,
workers and communities affected by the decision.” [38]
4.36 The Forest Industries Federation of WA commented that:
Legislative support for termination and compensation will act to prevent future
governments simply 'walking away' from Regional Forest Agreements without
consideration for the stakeholders involved. This is particularly important for the smaller
businesses, which are vulnerable to changes and need security. [39]
4.37 Mr Allen Grant, Assistant Secretary, Forest Assessment Branch of the Commonwealth Department
of Agriculture, Fisheries and Forestry told the inquiry that the Commonwealth Government agreed in the
RFAs to pay compensation only if it does “certain things which are limited”. Mr Grant went on to state:
… the precursor is that the intent of the action by the Commonwealth has to be to
protect the environment and heritage values in native forests in connection with those
values. Then the Commonwealth will pay compensation to various activities, defined as
forestry activities or mining activities. The intent of that process is to build up the degree
of certainty that we are hoping the RFA and the associated legislation will provide to
industry to continue to invest and provide regional community security for employment.
… In the case of a woodchip company, for instance, if it breaches the conditions that it
has for harvesting in the state, through the state practices timber board or through
whatever environmental restrictions are in place within the state, then it must answer to
those conditions through the state legislation. [40]
4.38 The Committee considers that the provisions of clause 7 of the Bill provide an adequate
compensation regime for RFA activities, and notes that the provisions of clause 7 only become effective
upon breach of an RFA terms by the Commonwealth.
Review of RFAs
Support for review of RFAs
4.39 A number of contributors to the inquiry recommended some formal method of reviewing RFAs.
4.40 The WA Forest Alliance recommended to the inquiry that “a judicial review of all RFAs in place or
still underway be instigated.” [41]
4.41 The Aboriginal Legal Service of WA (ALSWA) stated:
Parliament is being asked to approve all future Regional Forest Agreement processes
before they have been undertaken and in the absence of any scrutiny. As there is no
mechanism included in the Bill enabling Parliament to review the adequacy of future
Regional Forest Agreements, this is particularly dangerous. [42]
4.42 Dr Ian Crawford of WA in his submission to the inquiry was critical of the lack of provision in the
Bill dealing with monitoring the performance of States:
The Bill contains no provisions for the Commonwealth to monitor any State's compliance
with the Commonwealth's obligations under international agreements or its own
legislation, no provisions to vary the legislation in the light of new or revised conclusions,
and no penalties for breaches of the RFA agreements. In these respects, the proposed
legislation appears to me to be seriously inadequate. [43]
4.43 Ms Heather Whitelk submitted that:
Instead of, this RFA Bill, there should be an independent scientific review of RFAs
signed or unsigned. It should be public, with ample opportunity for all stakeholders to put
their views and to have representation for the creation of the final report. There should
also be a public, independent and representative peer review of forest management
protocols, and a moratorium on logging in controversial areas before damage is
irreversible. [44]
Opposition to review of RFAs
4.44 The Forest Protection Society is opposed to any review of the Regional Forests Agreements once
they are operating. According to the Society any “post-signing analysis would ensure political
intervention” in the operation of the agreements. The FPS noted:
This is the very kind of political action that the RFA process was designed to avoid and
would open the way to endless debate and political bargaining over the content of an
RFA. The losers would inevitably be the people in the communities whose livelihoods
would be the pawns in a purely political negotiation. [45]
4.45 North Forest Products expressed their concern that:
… an amendment has been suggested that will involve a Parliamentary review of
completed RFA's. We believe that this move would drag the Commonwealth back into
the forest debate. This goes against the whole idea of the RFA, that is to hand control of
forest management back to the State where it was always meant to be. [46]
Review of RFAs - Committee view
4.46 The Committee considers that an annual review of the operations of RFA'sRFAs during the first 5
years of operation should be made public.
4.47 To make the process of review of RFA operations more transparent, and more available to the
public, the Committee recommends that annual reports of the operation of RFAs for the first 5 years of
the period of an RFA be tabled in the Parliament to allow both public and Parliamentary scrutiny of RFA
operations.
Footnotes
[1] Submission, Tasmanian State Office of the Forest Protection Society, p. 5.
[2] House of Representatives Hansard, 26 November 1998, p. 612.
[3] House of Representatives Hansard, 26 November 1998, p. 612.
[4] House of Representatives Hansard, 26 November 1998, p. 612.
[5] Submission, Southern Tablelands NSW Branch of the Friends of the Earth, p. 3
[6] Submission, Native Forest Network, Southern Hemisphere, p. 3.
[7] Evidence, WA Forest Alliance, p. 180.
[8] Submission, Mr Roger Martin, p. 3.
[9] Evidence, Forest Industries Federation of WA, pp. 173-174
[10] Evidence, Judith Clark, p. 150.
[11] House of Representatives Hansard, 26 November 1998, p. 612.
[12] House of Representatives Hansard, 26 November 1998, p. 612; see also Regional Forest
Agreement Bill 1998, Explanatory Memorandum, p. 4.
[13] Submission, the Environmental Defenders Office, Tas, Inc. p. 3.
[14] Regional Forest Agreement Bill 1998, Explanatory Memorandum, p. 3.
[15] Submission, Forest Protection Society, p. 1.
[16] Submission, Forest Protection Society, p. 2.
[17] Submission, Forest Protection Society, p. 3; see also Submission, Boral Timber.
[18] Evidence, Senator Shayne Murphy, p. 81.
[19] Evidence, Forestry Tasmania, p. 135. For a description of the importance of the forestry industry
to Tasmanian see Evidence, Forestry Tasmania, pp. 136-137
[20] Submission, Mr Geoff Law, p. 3.
[21] Evidence, Forest Protection Society, p. 194.
[22] Submission, Busselton-Dunsborough Environment Centre, p. 2.
[23] Evidence, Judith Clark, p. 153. For a discussion dealing with the issue of forest plantations in
Australia see Submission, Ms Judy Clark. For information on the number of people employed in the
WA forest industry see Evidence, WA Forest Alliance, pp. 179-180.
[24] Evidence, Judith Clark, p. 150.
[25] Evidence, p. 152.
[26] Evidence, Forest Industries Federation of WA, p. 168
[27] Evidence, Forest Industries Federation of WA, p.172
[28] Submission, WA Forest Alliance, p. 2.
[29] Submission, Aboriginal Legal Service of WA, p. 2
[30] Submission, Dr Ian Crawford, p. 1.
[31] Submission, Ms Heather Whitelk, p. 1. The following is a selection of submissions which supported
reviews in relation to RFAs and related activities: Ms Stefanie Rennick, Ms Jill Bartlett, Mr Ralph
Bartlett, Ms Georgette Courtenay, Mr Marc de Vecchi, Mrs E J Wright, Mr C RA Lang, Ms Peg Jones,
A and B Cook, Mr Peter Campbell, Ms Helen Goedemoed, A and J A Schmidt, Ms Lois Loftus-Hills,
E L Minifie, Richard and Alison Harcourt, Ms Carolyn Pile, Mr Neil McLogan, Phillip Island
Conservation Society, Mr Murray Winter, Knox Environment Society, Ms Doris L Metcher, Ms Dallas
Kinnear, Ms Margaret Files, Ms Alfrieda Booth, Mr David Cook.
[32] Department of the Parliamentary Library, Bills Digest No. 50 of 1998-99, p. 9.
[33] House of Representatives Hansard, 26 November 1998, p. 612
[34] Regional Forest Agreement Bill 1998, Explanatory Memorandum, p. 4; see also Department of
the Parliamentary Library, Bills Digest No. 50 of 1998-99, p. 5
[35] Submission, Conservation Council of Western Australia, p. 1.
[36] Submission, Amcor Green Shareholders Strategy Committee, p. 3. See comments by Senator
Brown Evidence, p, 67. See also Evidence, Tarkine National Coalition p. 106; submissions from:
Braidwood and Bega Greens, Ms Christine Milne.
[37] Submission, NAFI, p. 5.
[38] Submission, Forest Protection Society, p. 6.
[39] Submission, Forest Industries Federation of WA, pp. 3-4.
[40] Evidence, Commonwealth Department of Agriculture, Fisheries and Forestry, pp. 212-213.
[41] Submission, WA Forest Alliance, p. 2.
[42] Submission, Aboriginal Legal Service of WA, p. 2
[43] Submission, Dr Ian Crawford, p. 1.
[44] Submission, Ms Heather Whitelk, p. 1. The following is a selection of submissions which supported
reviews in relation to RFAs and related activities: Ms Stefanie Rennick, Ms Jill Bartlett, Mr Ralph
Bartlett, Ms Georgette Courtenay, Mr Marc de Vecchi, Mrs E J Wright, Mr C RA Lang, Ms Peg Jones,
A and B Cook, Mr Peter Campbell, Ms Helen Goedemoed, A and J A Schmidt, Ms Lois Loftus-Hills,
E L Minifie, Richard and Alison Harcourt, Ms Carolyn Pile, Mr Neil McLogan, Phillip Island
Conservation Society, Mr Murray Winter, Knox Environment Society, Ms Doris L Metcher, Ms Dallas
Kinnear, Ms Margaret Files, Ms Alfrieda Booth, Mr David Cook.
[45] Submission, Forest Protection Society, p. 7. See also the following submissions opposing reviews:
Tasmanian Farmers and Graziers Association, Forestry Committee, p. 3, Forest Industries Federation of
WA, pp. 5-6, North Forests Products, p. 2, Queensland Timber Board, Professor Emeritus E P
Bachelard. See Evidence, Australian Workers' Union (WA Branch), p. 181.
[46] Submission, North Forest Products, p. 2.