Part 1 - Objection
to Plantation Submitted by Neighbours
TO : East Gippsland Shire
RE : Planning Application Permit No. 329/2007/P
(Proposed Plantation at 1119 Buchan-Ensay Rd, Reedy Creek)
This submission is drafted on behalf of, and presents the views of, ... The owners of these two properties (and our partners) currently have twelve children between us with nine of those children being under ten years of age. The number of children is likely to increase in the future.
We would like to make it clear from the outset that our concerns about the plantation proposal relate to the broadacre scale and industrial nature of the development. If this proposal was for a agroforestry or integrated farm forestry project that enhanced or rehabilitated the land, thereby adding value to the location, and in keeping with the current ambience and amenity we would have no reason to object.
We do not trust that ISO14001 and the Australian Forestry Standard will provide adequate protection of environmental values. Midways P/L is, in our view, one of the worst plantation companies in the state and is unlikely to reach even that low standard..
Please find the following objections including examples of Midways' poor record in meeting environmental standards and guidelines as set out by legislation and regulations.
Objections to the proposed development at 1119 Buchan-Ensay Rd
1/ Existing vegetation
Even if Midway claim to have the intention of preserving native vegetation, as outlined in the management plan, we doubt their capacity to do so given their history of poor management practices.
Any clearance of existing vegetation, or loss of existing vegetation resulting from poor management practices, will negatively impact on the existing aesthetic amenity of our land. The aesthetic amenity of the area will also be impacted upon by the cyclical works and harvesting associated with the short rotation of Blue gum plantations.
Midways P/L claim to observe the Code of Practice for Timber Production but they have not left a buffer zone on Skinners Creek which supplies Warrnambool with drinking water.
The proposed 5 meter buffer on existing remnant trees and on stands of existing vegetation may be inadequate. With Midways proposing soil cultivation the risk of introducing pathogens into the soil and plant tissue and damaging existing roots systems is high. These buffers would need to project at least 5 metres beyond the extent of the canopy to be effective.
We also question in-fill plantings in small areas that are surrounded by existing vegetation. For practicality, in terms of managing the existing vegetation, these areas should be excluded from production.
In light of Midways' proven inability to self regulate with regard to the Code of Practice for Timber Production, if the plantation proceeds, it would be necessary for Council, or an independent third party, to monitor Midways' activities.
This raises the questions:
what, if any, penalties would be applicable for breaches?
would the penalties would be adequate deterrence? And,
who would be responsible for the cost of monitoring practices?
It would be unreasonable to expect ratepayers to absorb this cost so it should be covered by arrangements similar to those used to recover road maintenance costs.
(See Attachment 1)
Many of the pesticides and fertilisers currently used by Midways P/L in its forestry operations are known carcinogens and toxins and their use would pose a threat to our health. This issue relates to aerial spraying in particular(1). We are also concerned that, on top of the risks of incidental exposure, such chemicals will contaminate the water that we collect and store on our land and the headwaters of Sandy Creek(2). Such contamination poses health risks not only to humans, but could impact on other organisms that rely on the water in Sandy Creek and the waterways it flows into including the Tambo River and the Gippsland Lakes.
The Code of Practice states that "Water quality and river health must be protected by maintaining buffers and/or filter strips (to each side of the waterway)" and then specifies 10m buffers on each side of Class 2 and 3 watercourses and 20m on each side of Class 1 watercourses.
The proposed management plan is not clear in terms of what will happen with the buffer zones and filter strips on the watercourses. Some of these areas have existing vegetation but the management plan does specify how the rest of the buffers and filters strips will be managed.
On one hand, poorly managed buffer zones would harbour weeds and act as seed banks to spread weeds, while on the other we are concerned that chemicals will be used for weed management in the buffer zones and filter strips.
The more desirable and effective filter on the drainage lines would be appropriate indigenous vegetation. It would be difficult for this vegetation to become established and survive if there was regular spraying of herbicides in the buffer zones and filter strips and in the plantation itself .
It is impossible to assess the possible risks from chemicals (and erosion) unless Midways clarifies and details the treatment it proposes for these areas.
The convoluted design of this in-fill plantation means that it will be virtually impossible to apply the herbicides and insecticides that Blue gum plantations require without affecting watercourses, the existing native vegetation and possibly new vegetation planted in drainage lines on the site. For this reason, some areas should be removed from the area to be planted with Blue Gum. All of the area north of Sandy Creek is one example.
We do not believe it is possible for Midways to prevent over spray and spray drift from affecting existing native vegetation and drainage lines if aerial spraying of herbicides is used. This is particularly relevant given the presence on the site of Yellow Box Grassy Woodlands (ESO12) which is covered by EPBC Act, 1999 and the FFG Act, 1988.(3)
Another aspect of poor plantation management concerns the issue of soil depletion. With large volumes of organic matter being removed from the land during the clearing and planting process the soil rapidly becomes impoverished. Consequently plantation companies must resort to the heavy use of fertilisers which contain various concoctions that may include toxic industrial waste.
“Herbicides have been sprayed on blue gum plantation land within metres of streams through the Otway catchment and in flood-prone areas, prompting a call by concerned farmers for improved practices, water quality, soil and fish testing.
Farmers in the area have collected evidence indicating forestry company Midway had earlier this year helicopter-sprayed a former dairy farm, once owned by the Meade family on the Tomahawk Creek, with a mix of herbicides including Eucmix, glyphosate, metsulfuron-methyl, simazine, clopyralid and terbacil.“ Warrnambool Standard, On the Land 11/11/04 Chemical fears
3/ Local hydrological impacts of short rotation tree cropping.
Logging in short rotations (approximately 10 years in the case of Blue gums) will see sediment loads and turbidity increase in the Sandy Ck when the plantation is established and each time it is harvested. This will be followed by longer term reductions in stream flow as each crop of trees grows.
As the proposed site covers Sandy Creek in the headwaters where it is fed from the Mount Wong / Mount Possum catchment, it has the potential to capture significant volumes of stream flow.
In drier seasons and years the plantation may draw heavily on available soil moisture and ground water which could impact on neighbouring properties such as ours. It is possible that our dams will lose more water, and may even dry out, due to the capillary action created by evapotranspiration in the plantation as it draws on available soil moisture.
While our dams still managed to maintain about 50% capacity at the end of the drought cycle ending in 2007, the effects of a Blue gum plantation in close proximity may have a drastic effect on storage levels during future droughts.
We draw your attention to research on water use by plantations.(4)
Much of the property is covered by the Erosion Management Overlay.
There are numerous examples of activities in Midways' plantations contributing to erosion by pushing heavy machinery through, in and around drainage lines and waterways.
The management practices connected with plantations will inevitably contribute to higher levels of erosion on the property in question. The sediment and turbidity generated by plantation forestry will have significant effects on Sandy Ck and the Tambo River.
A further consequence of this erosion is that it may lead to East Gippsland Shire failing to meet it's obligations to ensure that activities it approves do not pose a threat to rare, threatened or endangered species.
note poor roading and high potential of sedimentation of creek. This
particularly nauseating operation
was found to breach the Code of Forest Practice by Colac Otway Shire
in February 2005.“
5/ Native species/Vermin/Predation.
We have concerns about vermin like foxes being controlled by measures that pose a risk to our health and safety. Shooting and/or baiting may be introduced to control such vermin and could pose a direct threat to us, domestic animals and native species.
are also concerned that native species such as kangaroo, wallaby, wombats
and possums (to name a few) which could be attracted to the plantation
may be controlled by similar measures. The block in question backs onto
a large tract of undisturbed forest and it seems inevitable that a conflict
will emerge between commercial interests and native species.
6/ Traffic issues and road maintenance costs.
We understand that Midways P/L intend to convert around 2000 hectares of land in the South Ensay – Reedy Creek area to plantations as part of a plan by Midway Plantations Pty Ltd and a subsidiary of Macquarie Bank to establish 20,000 hectares of new plantations in Gippsland by 2019 . If this occurs, it would seem reasonable to assume that the increase in heavy vehicle traffic will be a permanent feature rather than intermittent and sporadic.
Midways P/L expect to harvest around 60,000 tonnes every ten years from this site. This will mean around 1500 loads(based on 40 tonne loads), or 3000 rounds trips, travelling more than 200 kilometers to, and from, the Maryvale Pulp Mill over a four month period. That's around 25 trucks coming and going each day during the logging operations.
If they acquire and plant out 2000 hectares this would equate to about 22,000 round trips for log cartage alone.
Local residents and landowners will have to face increased risks on the roads due to the frequency of these heavy vehicles. During harvesting operations there will be large numbers of trucks travelling over 200 km's between the site and Maryvale. This will affect many residents of the region including those in the towns of Bairnsdale and Bruthen.
This seems an unnecessary burden on local residents, tourists and other economic sectors when 80 to 90 per cent of the land suitable for plantation growing in the region is within 50 km of the major transport and processing centres.
The increase in log truck traffic will lead to accelerated road and track deterioration which will in turn lead to more dangerous conditions on local roads. Deteriorating tracks will also increase sedimentary run-off into, and turbidity within, local waterways. Higher traffic volumes and longer distances travelled by log trucks will also lead to commensurately higher maintenance costs for authorities managing local roads. Given that the rate base is more likely to decrease rather than increase with this type of plantation activity the higher level of funding needed to maintain roads will mean that Council will have less money to spend on other services. Ratepayers would be effectively subsidising the plantations.
Council should consider the implications of the number of log trucks using the Great Alpine Road. This stretch of road is quite hilly and has numerous bends, many of which are quite dangerous. As the Great Alpine Road is the only route into the region it already caters to large agricultural and tourism sectors. It is a key regional tourist route and, as such, is bringing vital tourism generated income into the region. A much larger number of log trucks than currently use the route will directly impact on road safety and the attraction of the winter snowfields and the summer tourism heading to Omeo, Swifts Ck and the surrounding highlands and Alps. (5)
“Charleys Creek. Dismal roading in clear breach of the Code of Forest Practice. “
(See Attachment 3)
7/ Social impacts.
Loss of population and loss of productive farming operations and households;
Less scope and attraction for people to locate into the area;
Undermining of tourism operations and reduction in potential for diversification of economic activity.
Local communities become more isolated in both a practical and emotional sense. This has physical and psychological implications.
Plantations have fewer jobs per hectare than the activities they usually replace and the quality of the jobs they provide may be seen as being diminished.
Increased health and safety risks related to road safety, chemical use and fire risk.
Can lead to higher land prices making it difficult for farmers to expand operations to remain viable (especially with the generous tax benefits available to those wishing to establish plantations). Conversely, it can also undermine land values for land bordering plantations.
Can impact on people deriving income from tourism. Changes to landscape values and vistas and effects on cultural artifacts, along with road and other health and safety issues, may deter tourists.
Plantations can adversely affect neighbouring or nearby land users via management activities such as run-off of chemicals, spread of weeds from plantations to nearby land, erosion, changing water quality/quantity and/or providing habitat for feral animals that can damage crops or farmed animals on nearby properties.
Plantation sector will attempt to lower the rates payable on the properties it owns or leases by removing existing infrastructure thereby lowering overall rate base.
Overall, this plantation offers limited economic benefits as the logs are to be trucked directly to Maryvale Pulp Mill. The combined effects of plantations may result in a net economic loss when taking into account the myriad ways in which this sector would detract from the environment and lifestyle East Gippsland has to offer.(6)
night, representatives from Midway faced a barrage of questions and
criticism at a meeting at Fernbank.
Fernbank resident Peter Drummond says he's concerned his neighbours
will leave the area and the social damage to the community will be irreparable.
Mr Drummond says he knows of 14 local farms that have been bought out
for plantations. Mr Drummond says at least ten families have moved out
of the area. Rob Grant from Bairnsdale is worried about "the loss
of flow into the Perry system." Fernbank farmer John White is concerned
about restricting water flow. Fernbank farmer Lionel Rose is worried
about excessive chemical use and properties being surrounded by trees
and becoming fire traps.”
Part of the property is subject to a Wildfire Management Overlay 44.06.
The closely spaced planting of Blue gums in plantations, along with the micro-climatic effects created by the plantation drawing heavily on available soil moisture may increase the fire risk to our property and the surrounding area.
Blue gum plantations can be extremely volatile and our property would become completely surrounded by high fuel loads. At present the vector between West and South has a relatively minor fuel load so any fire travelling from that direction would be moderated by that lack of fuel. While the predominant fire risk is from the North to West, the 1983 Ash Wednesday fires showed that fires approaching from the vector West through to South can also present extreme fire risk.
The regrowth forest which is on our land, and to our South and West, is over twenty metres in height. Any fire approaching over the farm land to our South and West is unlikely to get into the canopy. A Blue gum plantation in this vector would provide the necessary fuel and structure to cause a crowning fire on our land leading to more potentially devastating impacts and risk from fire.
What are the risks of the genetic material from the plantation contaminating the surrounding forest through cross pollination?
What are the other risks in tissue culture/cultivars/hybrids (and in the future, genetically modified) monocultural crops of trees?
What diseases may be introduced either in plant material or equipment, e.g. Phytophthora?
Control of wildings may become an issue. Not only does the escape of the plants themselves pose a risk, the wilding management regime itself will lead to a physical impact on the surrounding forest and properties.
The property in question is adjacent to a large contiguous tract of undisturbed native forest. Any transmission of pathogens such as Phytophthora from genetic material or mechanical plant could have an impact on adjoining forest.
DAVIS: One day last month, as they collected wood from their perimeter
fence, a helicopter appeared from nowhere and began spraying the adjacent
Gunns plantation. To their horror, the spray crossed the boundary and
they were doused, Howard more than Michelle because she sought refuge
in their vehicle.
(2) - Midway Plantations Pty Ltd are now moving into plantation establishment in Gippsland through a partnership with Macquarie Alternative Assets, a subsidiary of Macquarie Bank. 20,000 hectares of new plantations will be established by 2019 in Gippsland and will feed into the PaperlinX owned Maryvale Pulp Mill. What will the impact be of plantation pesticides, particularly insecticides, on the Gippsland Lakes and local communities?
Pesticides used by Midway include:
Herbicides: Roundup CT, Simazine, Metsulfuron Methyl, Clopyralid, Terbacil, Sulfometuron Methyl
Surfactants: Liase, Wetter TX,
Insecticides: Maldison 50, Dimethoate, Dominex, Fastac. “
“Atrazine is probably the most widely used herbicide in the world and one of the most common contaminants in ground and surface waters [U.S. Environmental Protection Agency (EPA) 1994]. Recently, Tevera-Mendoza et al. (2002) showed that atrazine exposure (21 ppb) for as little as 48 hr resulted in severe gonadal dysgenesis in African clawed frogs (Xenopus laevis). Further, we showed that atrazine induced hermaphroditism at concentrations of only 0.1 ppb (Hayes et al. 2002) when administered throughout larval development. Most water sources in the United States, including rainwater, can exceed the effective concentrations in these laboratory studies (Hayes et al. 2002). In addition, the concentration in our previous study (Hayes et al. 2002) is 30 times lower than the current drinking water standard (Hayes 1993). Despite the significance of the reported effects in X. laevis, both studies (Hayes et al. 2002; Tevera-Mendoza et al. 2002) were conducted in the laboratory on a single species; whether the effects of atrazine are widespread in amphibians and whether effects occur in the wild remained unanswered."
“Atrazine induces breast and prostate cancer, retards mammary development, and induces abortion in laboratory rodents. Studies in human populations and cell and tissue studies suggest that atrazine poses similar threats to humans.”
Scientific studies have found that male frogs grow ovaries when exposed to the chemical at the minuscule level of .1ppb in water.
Further information on herbicides and pesticides used in forestry:
He said anecdotal evidence from local spraying contractors indicated herbicides were frequently used at high-strength levels that exceeded legally prescribed safety levels."
Modes of Actions of Forestry Herbicides
Herbicides/Toxics - Updates to March 2005
Pesticide Health and Safety Data
Yarram Abnormalities and unresolved historical issues concerning 2,4,5-T
(3)- “In late 1993, two pine plantations, owned by the Victorian Plantation Corporation, situated near the City of Ballarat in Central Victoria were sprayed with Hexazinone and Ulvapron. Creswick nursery staff were the first people alerted to something going wrong with this spraying operation a week or two after the spraying, when plants in their nursery started to die. The City of Ballarat first found spotting of trees in Ballarat a month after the spraying. The following timeline is a rough description of some of the events that followed.”
(4) - “In relation to regional or geographical variability, the impact of plantations on water flows is primarily dependent on the level of rainfall. In areas of moderate rainfall (600-850 mm), the typical reduction in the usable water resources (stream-flow and recharge) from establishing plantations on previously cleared land is about 100 mm per year . equivalent to one megalitre per hectare per year. Plantings in higher rainfall areas would result in greater reductions.
A scenario establishing 10 000 hectares of plantation forestry in northeast Victoria could lead to an estimated annual water reduction of some 20 000 megalitres to downstream users and the environment (Riddiford J. in Water and Salinity Issues in Agroforestry RIRDC P No 01/20).”
“Preliminary results and future analysis
The potential impact of a scenario involving the effects of southern blue gum plantation on inflow to the Lake Eildon was investigated. It was assumed that 100% of the area suitable for blue gums above Lake Eildon becomes plantation (90,000 ha). This represents an increase of 16% in forest cover. As a result of this scenario, the mean annual flow to the Lake Eildon will be reduced by 130 GL per year, which is about 7% of the current mean flow to the lake.”
Plantations, water quality and sustainable water use—Rob Vertessy, CSIRO
(5) - “Watch out for logging trucks. They are big and they go fast.”
“QUESTION: On Henwoods Rd & Macnees Rd, 20 to 30 log trucks going out a day. The road is in poor state, and why can’t Council work with Grand Ridge Plantations to follow-up on roadworks after harvesting?”
“Mr DUNNING — Tomorrow I will be going to the Great Alpine Road and there are 28 log trucks using that road at present so we are bound to run into a few of them through the ash ranges, a windy piece of road north of Bruthen for roughly 40 kilometres.
Ms NELSON — We are mixing the trucks in with the motorbikes which are also using the Great Alpine Road. Following the fires we were promoting for people to go up to the high country and be tourists and we have been mixing all of that traffic on a road that is perhaps not suited — it is not a road we manage. There are other impacts which have implications for Road safety; I know you are looking fairly specifically at Road safety issues. An example of a spin-off is the trucks mostly travel through the township of Swifts Creek. You are not going that far tomorrow but there is a need for children to cross the main road in Swifts Creek. It does not meet the Vicroads warrants for a funded school crossing so we are left looking at different ways to be able to fund the safe crossing of kids in those communities. I suppose it just shows that there is an increased impact where we cannot demonstrate the normal warrants needed in terms of volume of traffic and numbers of kids crossing the road but there is a real potential hazard there which we have to try and address because it is a community need.”
ROAD SAFETY COMMITTEE Inquiry into crashes involving country road toll
Bairnsdale–5 February 2004
“Trucks hauling burnt timbers have been using the road since early 2003 but there has been an increase in the number of log truck roll overs on the winding route via the Omeo Highway and Great Alpine Road.”
(6)- “Two studies have examined the proportion of communities holding negative perceptions of plantations. Petheram et al. (2000) found 28% of respondents to a telephone survey conducted in south-west Victoria believed plantations were likely to have negative impacts. Those who held negative perspectives were likely to be located in small rural communities in the region which had experienced plantation expansion. Tonts et al. (2001) conducted telephone surveys in rural communities in Western Australia where rapid plantation expansion had taken place, and found higher percentages of the population (over 50%) reported that plantations had negative impacts. “
Schirmer et al. (2005) examined whether expansion of plantation estate had affected service provision in the Great Southern region of WA. While little reliable data was accessible on service provision in the region over time, it was possible to examine trends in school enrolments in the region in detail. It was found that enrolments in small schools in small towns had declined by a greater amount in areas experiencing rapid plantation expansion (34% over 1991 to 2004) than areas not experiencing plantation expansion (17% decline).
Prospects for Australian Plantations— Social perspectives — Stewart Lockie, Director, Centre for Social Science Research, Central Queensland University
Plantations and sustainable rural communities—Jacki Schirmer, ANU, and Matthew Tonts, Edith Cowan University
Figure 1 - Composite map/Google Earth image showing existing vegetation and property boundaries.
Figure 2 shows the drainage lines and vegetation. This image illustrates why some of the proposed in-fill planting areas are inappropriate given the drainage lines and vegetation.
Articles on forestry chemicals:
“The Tasmanian issue appears to be a symptom of a general breakdown in environmental protection and human health protection processes at every level of government. The practices that appear to be causing the problems should have been addressed at a Federal level in 1982 and were again identified in 1990. The failure to implement the Senate Committee’s findings and the subsequent failure to implement the State Governments own code of practice has allowed the continuation of a practice that was clearly identified as hazardous in 1982. “
“A new study conducted by researchers at the University of Medicine and Dentistry of New Jersey has found the minute amounts of atrazine damage the critical areas of the nervous system that are involved with understanding, intelligence, movement and most importantly over all body function."
“Professor Vyvyan Howard, a toxicologist who sits on the advisory committee on pesticides, which approves such chemicals for use, said: “The biggest threat is to developing children. A foetus can be affected by such tiny traces of chemicals, in concentrations as low as parts per trillion, that no exposure can be safe.”
“AUSTRALIAN drinking water standards are under scrutiny after scientific research linking commonly used herbicides to gender bending in male frogs. “
Macquaria novemaculeata — Australian bass
Both species are present in the Tambo River and it's tributaries. Arthropods are a vital part of both species diet. Both species are protected by legislation to control activities that may compromise the health of these species.
Further reading on species that may be impacted by plantations in the Ensay area:
SUBMISSION TO THE GIPPSLAND REGIONAL FOREST PROCESS
“"Today there are no inspectors. There is no compliance testing. There is just a labelling requirement, and if someone says 'I am not happy with the information, I am going to get a second opinion' it is up to the individual consumer to challenge the company."
The Herald has learned that there are no national laws on the level of contaminants allowed in recycled materials used in agriculture.
State fertiliser laws are restricted to just three heavy metals - lead, mercury and cadmium. Other potential hazards are ignored.
Arsenic has no nutrient value for plants and is considered injurious to human health. It can also be ingested by animals and some table vegetables. But, with a number of other toxic substances, such as uranium, chromium and nickel, it is in some recycled wastes.”
“Ms Grimshaw added that, ”The local water authority Wannon Water was not notified of the spray event and have sought to test the water post spraying. I was also concerned that traces of heavy metals may be going into the water supply catchment. Our group also have concerns that industrial waste could be making its way into the fertilisers, effectively meaning that big business may be ridding their waste products by having them legally dumped into our water supply”. “
“Based on a 1997 series of articles in the Seattle Times by Duff Wilson, the book describes how, in the many states of the US, any material that has fertilising properties can be labelled a fertilizer, even if it contains heavy metals and other dangerous chemicals.
As landfill space became scarce in the US, companies saw the benefits of relabelling their hazardous wastes as fertiliser ingredients. Wastes from smelters, mining, cement kilns, wood-product slurries, incinerator wastes and other industrial wastes could be legally added to fertilisers in many states.
Duff gave various examples, including the way "a dark powder from two Oregon steel mills is poured from rail cars into the top of silos" and stored as hazardous waste. It is then "taken out of the bottom of the silos as a raw material for fertilizer". He described how low-level radioactive waste was disposed of in Oklahoma by "licensing it as a liquid fertilizer and spraying it over 9,000 acres of grazing land".
"Among the substances found in some recycled fertilizers are cadmium, lead, arsenic, radionuclides and dioxins, at levels some scientists say may pose a threat to human health." These substances could pose a danger to farm workers as well as consumers who eat the crops grown on farms fertilised in this way. They can also damage the crops themselves and contaminate ground water.
According to the Environmental Working Group, a non-profit enviornmental research organisation in Washington DC, 600 companies from 44 states were involved in this practice between 1990 and 1995. Of the 270 million pounds of toxic waste they sent to farms and fertiliser companies, 30% came from the steel industry.
Fertilisers in the US are not required to be labelled with their source nor with all their ingredients, not even toxic ingredients. So farmers were completely unaware of the practice until some farmers whose crop yields were significantly down and whose cattle were dying of cancer started making enquiries. The practice still continues and last month the US EPA held a national public hearing in Seattle into the issue of toxic waste in fertilizers. “
“Borschmann correlated rainfall, elevation and geology with growth rates of existing
plantations to estimate the mean annual increment (MAI), expressed in cubic metres per
hectare (m3/ha) per year, that could be expected for new plantations in the region. The area of
private land that is not forested and capable of supporting plantations for Blue gum, Shining
gum and Radiata pine with an estimated MAI of at least 16 m3/ha/year is 761 000, 389 000
and 758 000 ha respectively. Less than 2.5 per cent of the land capable of supporting
commercial plantations has slopes greater than 20 degrees, which require more expensive
harvesting methods. All of the capable land in the region is within 100 km of either a
processing centre or port, namely Melbourne, Geelong, Hastings, Barry’s Beach, Morwell,
Yarram, Sale, Orbost and Bairnsdale, and 80 to 90 per cent of this land is within 50 km of
GIPPSLAND COMPREHENSIVE REGIONAL ASSESSMENT REPORT
1999, Land Capability and Suitability, Ch 6.4 page 71.
Submissions received by the Committee as at March 2003
(Part 2 here)
to Forest Network's plantation page