Whats wrong with the Qld forestry code of practice (3)
Part 2 Exposing the over-inflated need for HBTs (Continued)
11. No assessment has been made of species propensity to co-occupy different hollows in the same tree on the same day or the resulting sensitivity to HBT needs.
Wormington (p147) reports that in up to 16% of observations, two different species co-occupied a HBT on the same day. And this was in a drought year with reduced animal densities. It is a behaviour that is more likely to take place in good seasons when the animal density is higher and the demand for hollows is greater. It is clearly another strategy through which animals ensure that any short term contraction in HBT supply does not lead to species collapse.
12. They fail to consider the “musical chairs effect” in the provision of den diversity.
Much has been made of the Greater Glider’s supposed need to occupy many hollows but they can still only occupy one hollow at a time. It is true that animals do use a number of hollows within their range but this does not mean there must be a surplus over actual usage. And there is no evidence that this usage must be exclusive over time.
Arboreal mammals achieve the variation in den sites in the same way that children in a game of musical chairs enjoy variation in sitting location. And unlike in the game, if the number of chairs is equal to or exceeds the number of participants then the game can go on indefinitely and produce no losers.
To further punish the analogy, in the forest habitat game, some chairs are for big people and some are for small people but some chairs can also sit two people of different sizes. Indeed, a whole family can sit on one chair and in these circumstances having too many chairs may actually inhibit access to the table where the cake and candles are.
13. Wormington’s estimations of age at which species form hollows appears inconsistent with observed evidence.
Wormington (p108) provides estimates of the age at which various species will form hollows. His Figure 6.6 appears to have used the aggregated PAI data from the DPIF permanent plots to justify result that most private forest owners would regard as absurd.
His Table 6.8 (p109) suggests, for example, that >50% of stems will have hollows when Eucalyptus citriodora (Lemon Scented Gum) reach 61cm DBH. This may or may not be the case in private forests but the suggestion that the tree would have to be 220 years old to reach that DBH is far from the case in private forests.
The estimate is at substantial variance with the 15 year old example of this species in my own front yard that is already 43cm DBH. And to suggest that this tree will need another 205 years to achieve a DBH of 61 cm is to seriously test the credibility of the claimant.
It is possible that growth rates in a publicly owned forest, with a history of negligent and culpable mismanagement of a valuable asset, may achieve highly degraded growth rates. This would be especially so if the stand had an over burden of non-contributive stems, and understorey competition that impaired the growth of the stem in question. It would also be true if the tree was the only good nosh in the paddock and it was continually over-grazed by four legged caterpillars.
But what is absolutely clear is the fact that the estimates of time taken for new HBTs to form in public forests are totally inappropriate for use in private forests. Indeed, photographic records are available that are fully capable of establishing that new HBTs can be created within the time it takes for most dead stags to collapse. That is, within 60 years.
There is no evidence to suggest that there is any significant gap between the rate at which stags become non-contributive as HBTs and the rate at which new contributive HBTs can be recruited. Consequently, the need for any recruitment HBTs should not exceed the existing number of dead stags that contribute to any retained HBT requirement.
14. No attempt has been made to determine the full cost of HBT retention.
The cost of a recruitment habitat tree is not it’s stumpage value. Many private forestry uses are in association with the small (formerly) licensed mills and many others are in association with on-site portable milling. Other forests that are not directly associated with portable milling retain an indirect association through contract milling and a complex network of barter deals based on full retail value of sawn timber.
So even if there was a pretext for only using stumpage value to measure the costs of Code of Practice prescriptions in public sector forests, this is totally inappropriate for private forestry.
A typical recruitment habitat tree of 60cm DBH is likely to have a round wood volume of 3m3 each. This would produce 1.5m3 of sawn timber with a minimum value of $800/m3 or $1,200 each. So 11 such recruitment trees in a hectare of young remnant would amount to $13,200 in foregone income from profits and personal exertion per hectare.
If these proceeds were paid against a typical mortgage at 6.5% interest then annual savings of $858 per hectare will accrue to the beneficiary for the term of the loan. And the net present value of such a foregone saving is 10.5 times the annual benefit, or $9009 per hectare.
And to this must be added the value of timber that may have grown where the recruitment HBTs have occupied space or for which the harvest date has been postponed due to impaired growth rates. At a loss of only 2m3 in annual growth/ha this amounts to an additional $800 per hectare with a net present value of about $4,000. This puts the total cost of an 11 recruitment habitat tree prescription at $26,200/ha. And we don’t even get a tax credit for it.
15. There has been no examination of alternatives to HBTs where none exist.
The forest and wood products industry employs an extraordinary range of tools, techniques and technologies to produce an even greater range of products. Trees are specifically grown for specialised uses from cricket bats to masts. Wood is sawn, split, shaven, carved and chipped. It is dried, moulded, bent, glued, nailed, bolted, coopered, laminated and, recently, micro-waved and resin impregnated. It is painted, impregnated, coated and reconstituted.
It produces paper, cardboard, fibreboard, plywood, laminated veneers, mouldings, structural timber, beams and planking. It produced one of the best fighter planes of its time, the Japanese Zero, the 3000 tonne ships of Ming Admiral Cheng Ho, railway carriages, trucks, buggies, drays and wheelbarrows that built nations. It produces windmills, windlasses, propellers, pumps, cranes, boxes and furniture. It produces newspapers, chip wrappers, books, packages, tetra packs and tubing. It produces an outstanding array of dwellings from kennels, cages, barns, stables, cabins, houses, apartments, castles, churches and parliaments.
All these splendid transformations for the betterment of mankind and his environment begin in a forest. They are anticipated by, and dependent on, an on-going forestry purpose. But not one of these century old and even millennia old technologies has been considered as a means through which the dwelling needs of wildlife can be met in those very same forests.
A private forest owner with few HBTs left after historical compulsory clearing must set aside up to 11 perfectly good sawlogs/ha to wait, dumbly and inefficiently, for up to a century, until age, termites and pure chance can provide a service that his wildlife dependents are supposed to be in urgent of need right now.
In a landscape that has been extensively modified by man, it seems the only creatures that are to be excluded from enjoying any benefit from man’s intellect are the creatures that can be adversely affected by his actions. But even this exclusion is a selective one based on discrimination by occupational class.
As the brochure (34) says, “The Land for Wildlife program is proudly co-ordinated by the Queensland Government, Environmental Protection Agency & Queensland Parks and Wildlife Service”. It is also supported by the Natural Heritage Trust through the Bushcare program, Greening Australia and 61 local councils, funded by 14 councils in SE Queensland.
Land for Wildlife Note 19 (35) is specifically titled, “Nest boxes for native wildlife”. It recognises that HBTs can, and have been, depleted and states that “nest boxes can help species survive by providing artificial hollows for breeding and shelter”. A number of references are also provided as well as links to the web sites of nest box makers such as The Australian Nest Box Company (37).
This company sells a range of boxes for the large Possums, smaller Gliders and many bird species with prices ranging from $35 for kits and up to $95 for fully assembled and painted products. They highlight the preferences of various species, advise on multiple users, occupancy rates etc, and include a trap for feral pests like the Indian Myna. And their major customers appear to be local councils throughout the country who have allocated significant budgets for this purpose.
So if these measures are not effective, then why are they spending this money? The aim of the program is obviously to provide hollows for the period it takes for HBTs to form in forests where they are not present. These community owned forests do not have an on-going forestry purpose so there is no foregone production or economic loss that may result from waiting for a perfectly good tree to form hollows.
This is not the case with existing forestry uses. The cost of providing hollows by entirely natural means is very significant and this significance places a burden on any regulatory process to assess alternatives for that delivery.
And if a legal obligation exists for forest owners to provide housing for dependent wildlife households, one must ask, why is such a long delay in delivery of this obligation regarded as acceptable? And one must also ask, if this obligation applies to the owners of native forest without HBTs then why does it not also apply to the owners of plantations without HBTs. Are they not also subject to the environmental duty of care?
Clearly, artificial nest boxes can provide for the housing needs of all dependent wildlife. And despite the relative immaturity of this industry sector, they have already demonstrated the capacity to address this environmental need for a fraction of the cost of the prescribed natural alternative.
It must also be stated that far superior options with lower costs, cheaper and more efficient installation and relocation, easier inspection and maintenance and enhanced resistance to fire and harvest damage have already been tested and found to be preferred by wildlife over most natural hollows. But this intellectual property will remain suppressed until the socio-legal treatment of forest owners returns to accepted community benchmarks.
The sum of the above mentioned errors and omissions leaves little room for doubt that the need for the current HBT retention prescriptions has been based on partial and fragmentary statements of fact, false assumptions and questionable conclusions from selected primary data.
The natural climatic and seasonal range of variation in animal density has not even been studied properly, let alone understood. This ignorance has been exacerbated by an ‘in full knowledge’ failure to consider the extent to which arboreal mammals form family groups to co-occupy nest hollows with resulting over estimation of hollow needs.
A fundamental failure has occurred, to consider the ways in which species adjust their ranges, family size and reproductive behaviour to cope with climate based population peaks and troughs and the resulting changes to the relative supply of Habitat Trees.
A fundamental failure has also occurred, to recognise a clearly inelastic relationship between HBTs and species diversity and density over the ‘whole number’ portion of the graphs the relevant ‘experts’ have been studying. This has obscured the actual point of potential species collapse which most likely exists in the fractional scale between zero HBTs/ha and 0.5 HBTs/ha.
There has also been a fundamental perceptual problem in the minds of the people responsible for examining this issue. They have assumed that the survival of species is contingent on their capacity to maximise population in good seasons. This is the only time when anything approaching a shortage of HBTs would be evident.
But the overwhelming evidence indicates that they have got it the wrong way round. Species survival depends primarily on their capacity to survive on the minimal food resources in a bad season. It is this surviving remnant that determines the size of a good season population surge. But there is no shortage of available hollows for a depleted dry season population.
The current departmental position is the ecological equivalent of suggesting that the survival of starving Africans in a famine is dependent on them maximising their birth rate in good seasons. It is the very opposite of the inescapable truth and as equally dangerous.
The detailed modelling of Wormington’s actual plot samples that is attached to this paper is fully capable of advising the policy process on the actual need for retained HBTs under the Code. It is also capable of examining the sensitivity of various levels of HBT retention to both underestimation of populations and actual population changes. And the proper use of such a model, once available, would appear to be a minimum requirement for satisfying the Minister’s general duty of care.
The detriment that forest owners may suffer from the negligent investigation of the need for, and utility of, the habitat tree prescriptions under the code is very significant and entirely foreseeable.
We urge the Minister for Natural Resources, Mines and Energy, and The Premier of Queensland, to take all reasonable and practicable steps to ensure that any detriment that private forest owners may suffer is minimised. For the harm that forest owners may suffer from misapplication of measures is not quarantined from the broader community.
Many forest owners are starting to question whether the community this Minister represents is still worth them donating their time to causes like the rural fire service. They often form the core expertise of such groups and risk their life on-call and often leave their own family vulnerable while they protect the wider community. And they could not help but notice that nowhere, in either the Vegetation Management Act 1999 or in this Code, is there even the slightest provision, or trace of any obligation on the Minister’s part, to maintain what used to be called the cardinal principle of forest management. That is, there appears to be not the slightest desire, on the part of the community this government represents, to ensure that their forest is capable of producing timber in perpetuity.
It would appear, from the matters raised in this paper, that the social contract between the community and private forest owners has been abrogated. And in this circumstance, forest owners have a duty to themselves and their families to reassess the nature and content of any contributions that they have been making to a community that no longer treats them equally before the law.
To paraphrase ‘70’s rock group ‘The Eagles”, in their classic, “The Last Resort”,
“They will provide the grand design, of what is yours and what is mine.
Then try to make a new frontier, by driving families out of here.
They called it sustainable, I don’t know why.
If they call something sustainable, then kiss it all good-by”.
Secretary, The Landholders Institute Inc.
PO Box 5375 Manly Qld 4179
Ph. (07) 38930612
1 Ratnapala, S. Vegetation Management In Qld, IPA Review 12/2004 (p10) See http://www.ipa.org.au/
2 Judicial Review Act 1991 See http://www.legislation.qld.gov.au/
3 Public Sector Ethics Act 1994 See http://www.legislation.qld.gov.au/
4 Criminal Code Act 1899 See http://www.legislation.qld.gov.au/
5 Code applying to a forest practice on freehold land. See http://www.dnrm.qld.gov.au/
6 Qld DNRM, Habitat Tree Technical Advisory Group, Managing Habitat Trees in Qld Forests, 4/1998 Lamb. D, Loyn. R, Smith. A, & Wilkinson. G.
7 Op. cit. (p38)
8 Qld Herbarium. “Coreveg” unpublished data set for normal height & canopy cover.
9 Smith. C & Lees, N. 1998, Density and distribution of habitat trees required to support viable populations of hollow dependent species, Qld DNRM.
10 Ross, Y. 1998, Hollow bearing trees in native forest permanent inventory plots in SEQ. Qld DNRM.
11 Wormington, K. 2003. The habitat requirements of arboreal marsupials in the dry sclerophyll forests of SEQ. PhD. Thesis, University of Qld.
13 Ibid. Appendix I (p21)
14 Ibid. (p6)
15 Op. cit (p6)
16 Op. cit Fig 5a & 5b (p56)
17 Op. cit (p20)
18 Ibid. (p20)
19 Strahan, R. Ed. 1995. The Mammals of Australia, Aust. Museum/Reed (p264)
20 Op. cit (p26)
21 Op. cit (p271)
22 Op. cit (p22)
23 Op. cit
24 Op. cit Table 3a & 3b, (p47)
25 Op. cit Table 5. and Figs 2a to 4b (p52)
26 Op. cit (p24)
27 Smith, A. & Lindenmayer, D. 1998 Tree hollow requirements of Leadbeaters Possum and other possums and gliders in timber production ash forests of the Vic. Central Highlands Aust. Wildl. Res. 15: (p347-362)
28 Op. cit (p52-56)
29 Op. cit (p22)
30 Op. cit Smith & Lees Fig 5a & 5b (p56)
32 Op. cit HTTAG (p23)
33 Op. cit Strahan (p263)
34 Land for Wildlife program. 2003 Qld Government, Environment Protection Agency.
35 Op. cit Land for Wildlife Note 19
36 The Australian Nest Box Company. See http://users.bigpond.net.au/ozbox