Dailan Pugh

Integrity of the CRA process

While the Australian conservation movement was justifiably skeptical about the CRA and RFA processes, NSW conservation groups took the decision from the start to become involved. This was in part because we were aware that our forest reserve system is one of the worst in Australia. It was evident that a major expansion in reserves is required, even with the minimalist national reserve criteria.

The NSW forest assessment process has been based upon a three staged process agreed to with the current NSW Government before the last election:

1. Urgently rescheduling State Forests' logging programs to avoid logging and roading in all high conservation value old growth forests and identified wilderness areas pending the completion of an interim assessment process;

2. Initiating an interim assessment process, to be completed within nine months, to examine all available information bases to determine areas to be placed under logging moratoria at the completion of the interim assessment process; and

3. Undertaking comprehensive environmental regional assessments of both public and private lands to establish a comprehensive, adequate and representative reserve system.

The process has been ongoing for over three years and is now in the third stage. It has evolved and been varied with each stage. The most outstanding feature of the process in NSW is that it is a participatory process, which allows conservation and timber industry representatives to be involved in decision making.

In this paper I outline the differences between consultative and participatory processes and highlight some of my recommendations for fixing the CRA process based upon both my experience in NSW and my knowledge of other CRA processes.

Public Consultation and Participation.

Consultation involves seeking public submissions on documents and sometimes public meetings. It can include groups set up to advise the government, proponents of activities or other bodies.

By the time proponents get to the public exhibition stage they have usually determined what they are going to do, thus submissions are often ignored by the decision-makers. Sometimes key issues raised in submissions from the principle interest groups are heeded, though generally it is only significant numbers of submissions that have any political effect.

Advisory groups usually allow earlier consultation on a proposal or process. My experience with a variety of advisory panels, boards and committees is that they are a waste of time. Their advantages seem to be limited to being better informed about what is happening. Though there appears to be limited ability to affect the outcomes of a process. I am still amazed how often months of effort can be put into developing consensus positions from the full range of stakeholders only to have such advice ignored.

When involved in such groups the key issue becomes balanced representation of interest groups. Too often advisory groups are established with a predominance of vested interest groups, often appointed under the guise of some other interest group. From a conservation perspective, there is even less point in being involved in a stacked process.

Is it any wonder that conservation groups have little faith in public consultation processes when, even if they overcome problems with stacking of advisory groups, they know that they will largely be ineffectual? It was because of past experience that NSW conservation groups insisted upon a genuine and balanced participatory process as a prerequisite to becoming involved in the CRA process.

Genuine public participation differs from consultation in that it includes involvement in decision-making forums. Public participation is one of the principle factors which distinguishes the NSW and Queensland CRA processes from other states. In NSW, conservation, Aboriginal and timber industry groups are involved in the technical working groups planning and overseeing assessment themes. Until recently we were also involved in the principle decision making body, the NSW/Commonwealth Steering Committee.

The NSW CRA process was established on the basis of achieving balanced representation of four state officials, four commonwealth officials, two (timber) industry people and two conservationists. This basic structure was replicated on the Steering Committee and in each of the four technical working groups. This level of participation gave interest groups a real and meaningful say in what was done and how it was done.

The later addition of Aboriginal interests to the process was welcomed. It was the insistence by the Commonwealth of adding other vested interest groups onto the Steering Committee that undermined the principle of balance and began to make the Steering Committee unworkable. Though it was the bickering between the State and the Commonwealth leading up to negotiations over Eden, and a perception by the timber industry that they would be better off if conservationists weren't able to keep an eye on proceedings, that led to interest groups being excluded from the Steering Committee in November last year.

Since then the Steering Committee has become even more dysfunctional. The absence of interest groups has given the Government officials more scope for political maneuvering and less worry about accountability. The efficiency and integrity of the NSW CRA process have suffered as a result.

What are the lessons to be learnt from CRA processes to date?

Full participation in a complex process involves endless meetings, developing and commenting upon multitudes of documents and arguing your case as best you can. It consumes significant time, resources and energy. It can also be frustrating and unrewarding. It provides access to data, gives a real say in what happens (even if you are ignored) and maintains a higher level of honesty and integrity.

· Public participation, based upon balanced representation of the principle interest groups and their involvement at all levels in the decision-making processes, should be a basic requirement for CRAs.

· Effective participation requires significant resources, appropriate skills and adequate funding.

Most public consultation processes are ineffectual and outmoded, though there is still a need for improved processes to ensure wider community involvement and accountability in decision making. Too often community meetings held as part of CRA processes sample an unrepresentative section of the community.

· More accurate identification of wider community attitudes on specific aspects and issues requires greater use of state and regional public attitude surveys.

· Informed community debate requires all data and reports to be publicly available, and improved dissemination of factual material in an appropriate form to the community.

Government agencies are highly politicised, both by internal attitudes and external ministerial pressure. Ecological requirements are compromised to reduce perceived timber industry impacts at every opportunity, rather than making all compromises transparently at the end of the process.

· The presence of conservation stakeholders helps constrain excesses.

· Independent scientific expert review processes are necessary to resolve disputes and help maintain the integrity of decisions.

What distinguishes the CRA process is the development of national reserve criteria (CoA 1995, JANIS 1997) to act as a baseline from which to assess each state's reserve systems. For years conservationists have watched these criteria being compromised and watered down. Rather than now being regarded as a national baseline by the states, they are too often regarded as a maximum to be avoided where possible. By identifying a benchmark, the reserve criteria have significantly assisted the recognition and protection of conservation values in the CRA process. There is a tendency for states to believe that once they can claim to have satisfied these minimalist criteria then it can be open slather on the remaining forests. The National Forest Policy requirement to establish national baseline environmental standards for non-reserved forests has been stalled for years.

· The national reserve criteria need to be regarded as a minimum (in need of improvement) to be expanded upon and adapted to suit regional circumstances.

· There needs to be greater recognition that even if a reserve system fully satisfied all the criteria it would still be inadequate to maintain the majority of a region's biodiversity in isolation from other native forests.

· National baseline environmental standards, aimed at ensuring ecologically sustainable forest management, need to be developed and applied (as a minimum) across the full native forest estate as soon as possible.

The CRAs have severe limitations; it is dangerous and naive to consider that they will provide the final solution to the forest debate. While it is apparent in NSW that the best available data is being used, there is still significant uncertainty associated with the limited data, there are major gaps in knowledge and assessments, and there are high probabilities of irreversible environmental impacts. There is a need for periodic adjustments to accommodate changes in community values, improved ecological information and understanding, improved timber resource data, required changes in forest practices, changes in wood products technology and market conditions. In other states the processes have been more dubious, under their cloaks of secrecy politics have often run riot. Their processes and outcomes are not publicly credible.

· None of the RFAs completed in Australia to date deserve public credibility.

· The CRA process should be considered as establishing a database that can be built upon over time and used periodically to assess the adequacy of land use allocation and management. Even when faithfully undertaken, there is an absolute necessity for RFAs to include meaningful reviews every five years and no commitments should be given to industry which exceed levels of ecological sustainability or last longer than 10 years.

References

CoA - Commonwealth of Australia (1992) National Forest Policy Statement. Commonwealth of Australia.

CoA - Commonwealth of Australia (1995) National Forest Conservation Reserves, Commonwealth Proposed Criteria. Commonwealth of Australia.

JANIS - Joint ANZECC / MCFFA National Forest Policy Statement Implementation Sub-committee (1997) Nationally Agreed Criteria for the Establishment of a Comprehensive, Adequate and Representative Reserve System for Forests in Australia. Commonwealth of Australia.

Dailan Pugh

North East Forest Alliance and Nature Conservation Council representative on NSW Resource and Conservation Assessment Council.

NEFA
123 Keen St
Lismore NSW 2480
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