* The Bill falsely assumes that RFAs have been and will be properly conducted, and that their outcomes will be accepted by the community.
* The RFA process across Australia has been a sham and a fraud; it is being used to give resource security to the woodchipping and whole log export industries, at the expense of jobs and other values, and under the cloak of a very expensive public relations exercise. The latter seems designed to make the public and the media believe that genuine public participation has occurred, and that RFAs are achieving an appropriate balance of industry and conservation interests.
* RFAs, particularly in Victoria, have been based on poor science and inadequate surveys of threatened species, dubious statistical techniques and many technical errors. Old growth forests (e.g. in East Gippsland) known to contain threatened species have been left to the woodchippers, while "imaginary owls" have been created to protect forests of less interest to loggers and alike.
* In Victoria, the RFA process has been seriously pre-empted. Unrealistically high volumes of timber to be extracted were locked in place prior to the process, and RFA documents themselves describe the method of determining 'sustainable yield' as "unreliable" and as having "a lack of basic resource data". Major woodchippers (e.g. Amcor) were given legislated guarantees of access and woodchip volume. All this leads to a distinct appearance of predetermined outcomes. In pre-RFA areas woodchipping has increased already leg the Otways, Strzeleckis, Cobboboonee and other Southwest forests, the Northeast and the Northwest). A second woodchip mill is now operating in Geelong.
* The RFA process hands control over logging back to the States. This Bill not only enshrines the process - it also removes Commonwealth powers which until now have protected the forests. The Australian Heritage Commission is crippled and unable to intervene. The States' record on conservation issues strongly suggests that all this will result in a major loss of environmental accountability and safeguards, Dramatic increases in logging and woodchipping reported in post-RFA areas indicate that this is already happening.
* In Victoria, following big staff reductions, DNRE numbers are so low that they cannot protect our native forests from illegal logging and code of practice breaches. In any case, DNRE decisions are biased towards logging under the present State Government.
* The RFA legislation panders to the narrow interests of the native forest logging industry, which exerts an influence far beyond its importance to Australia's economy and society. Has any other interest group ever been offered similar far-reaching exemption from the laws of the land?
* The legislation will lock in place for another 20 years the current anti-competitive situation under which the native forest logging industry is propped up at the expense of the far more efficient and sustainable plantation industry.
* The Bill will make termination of an RFA virtually impossible and require the payment of compensation to an industry that receives massive subsidies while it enjoys virtually exclusive rights to exploit and destroy a publicly owned resource.
* There has been a notable lack of genuine public participation in the RFA process, particularly in Victoria and WA.
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.