PEFC complaint

Transcription

PEFC complaint

MyEnvironment Inc A0044084N
P.O. Box 519 Healesville
Victoria 3777
03 5962 3461
www.myenvironment.org.au
Attention Dear Mr Ben Gunneberg PEFC Council Secretary General 29th March 2010
Re Complaint against:
(i) Australian PEFC National Member – Australian Forestry Standard Pty Ltd – Kay Watts
(ii) SAI Global Pty Ltd
1.0 Complaint Both Australian Forestry Standards Pty Ltd and SAI Global Pty Ltd have failed to follow their own
complaint procedures.
MyEnvironment Inc believe that there is a large amount of documented evidence which suggests major
non conformances by VicForests over many years in relation to the Australian Forestry Standard (AFS).
The AFS standard clearly states that that if a major non conformance is found that no certification can be
awarded. This has been summarised in Section 2.0 Complaint background.
Following guidance from JAS-ANZ MyEnvironment Inc attempted to meet with SAI Global to discuss our
concerns in relation to the presence of major non-conformances and their issuing of AFS certification to
VicForests.
Despite acknowledgement by SAI Global that MyEnvironment Inc submitted a “customer complaint” to
them on the 28th July 2010 SAI Global have refused to meet and have not given a valid reason.
MyEnvironment Inc have also attempted to meet with Australian Forestry Standards Limited (AFS
Limited) to discuss our concerns in relation to VicForests certification to AFS and SAI Global which has
been met with no correspondence what so ever.
Evidence of our attempts to arrange meetings with SAI Global and AFS Limited are detailed in Section 2
Evidence of Attempts to resolve the issue with SAI Global and AFS Limited.
Always use 100% post consumer waste recycled paper
Victoria 3777
03 5962 3461
2.0 Evidence of Attempts to resolve the issue with SAI Global and AFS Limited Attempts to Resolve the issue with SAI Global
Date
21 June 2010
21 June 2010
28 June 2010
1st July 2010
13th July 2010
Correspondence
Email sent to Sabrina Kerber –
SAI Global - AFS auditor for
VicForests outlining a range of
concerns related to the
certification of Vic forests
Email sent to Susan Williams of
JAS-ANZ requesting advice on
how to address the issue
Email sent to Alex Ezrakhovich
highlighting our concerns and
requesting a meeting to discuss.
Email sent to Alex Ezrakhovich
suggesting a meeting on the
13th July 2010
Received Email from David
Crow incorrectly stating that
MyEnvironment Inc had
commenced an action against
Vicforests in the Magistrates
Court and are therefore unable
to meet
14th July 2010
Emailed David and Alex
clarification that we had not
instigated the case but there
was a case.
17th March
2011
MyEnvironment Inc has not
received any further
correspondence from SAI
Global
Result
No response to date
Attachments
Susan suggested contacting Alex
Ezrakhovich to table our concerns
Appendix 2
Alex replied acknowledging the
email as a customer complaint
and suggested a meeting after 6th
July with General Manager
Australian Operations David Crow
Alex replied back saying he would
contact me next week
Appendix 3
Appendix 4
Appendix 5
No meeting granted. This case
was being brought by the Fauna
and Flora Research collective –
we clearly wanted to talk to SAI
Global about a broad range of
issues in relation to their auditing
of VicForests and the AFS
standard
Appendix 6
Email back from Alex stating that
we were not brining the action. It
is clear from the first email that
there were a broad range of
issues needing discussion and we
did not need to talk about issues
related to the court case.
Despite formally acknowledging
our concerns as a customer
complaint on the 28th June 2010
we have been refused any
meeting to discuss our concerns.
Victoria 3777
03 5962 3461
Attempts to resolve the issue with AFS Limited
Date
4 Oct 2010
Correspondence
Email sent to Kayt Watts CEO of
AFS Limited highlighting
concerns
Result
No response to date
Attachments
Appendix 7
4 Oct 2010
Email sent to Kayt Watts
highlighting additional breaches
and concerns and requesting
that AFS certification be
immediately withdrawn from
VicForests.
Email notifying Kayt Watts that
VicForests is refusing to provide
information for stakeholder
review of their operations.
Several phone messages were
left on both the answering
machine and with the secretary
and none of these were
returned.
Email notifying Kay Watts that
we have not received any
conformation from AFS limited
or SAI Global. This was followed
up with at least half a dozen
phone calls that would all go
through to the secretary.
No Response to date
Appendix 8
No Response to date
Appendix 10
Email notifying Kay Watts that
we have not had a response
from them
No Response to date
4 Oct 2010
13 Oct 2010
13 Oct 2010
Appendix 11
When questioned why the CEO
would not respond the secretary
said that she was told to tell me
that “Kayt had received the emails
and that she was brining this up
with VicForests and SAI Global
and that there was no need for
me to discuss any of the matters
further with her.” I replied that
this was totally un acceptable and
asked her to get the CEO to call
me immediately as this was a
major failure in their stakeholder
engagement. No Response to
date
Appendix 12
Victoria 3777
03 5962 3461
Appendix 2
Adam Menary
From:
Sent:
To:
Subject:
Susan Williams [Susan.Williams@jas-anz.org]
Monday, 28 June 2010 10:48 AM
adam@myenvironment.org.au
RE: SAI-GLOBAL, VicForests and AFS
Hi Adam It was good to talk to you today. Just to confirm our discussion 1. You need to send a formal complaint to VicForests and SAI Global listing your concerns 2. Forward copies of the emails that you have sent to Sabrina to Alex Ezrakhovitch General Manager SAI Global alex.ezrakhovich@saiglobal.com Kind Regards Sue Sue Williams
Manager Learning and Development Phone: +64 (0)4 474 3348
Fax: +64 (0)4 474 3349
Mobile: +64 (0)21 369 264
Email: susan.williams@jas-anz.org
www.jas-anz.org
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From: Adam Menary [mailto:adam@myenvironment.org.au]
Sent: 21 June 2010 10:13
To: Susan Williams
Subject: SAI-GLOBAL, VicForests and AFS
Dear Susan I would like to discuss the audits relating to VicForests accreditation to the AFS standard Please contact me on +61 3 5962 2157 or 0438636279 at your earliest convenience Kind Regards Adam Menary 1
PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
 Please consider the environment before printing this email and if you must please use 100% post consumer waste recycled paper
Important: This message may contain confidential information intended only for the use of the addressee named
above. If you are not the intended recipient of this message you are hereby notified that any use, dissemination,
distribution or reproduction of this message is strictly prohibited. Scanned by the Netbox from Netbox Blue
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2
Victoria 3777
03 5962 3461
Appendix 3
Adam Menary
From:
Sent:
To:
Cc:
Subject:
Adam Menary [adam@myenvironment.org.au]
Thursday, 1 July 2010 9:43 AM
'Alex Ezrakhovich'; 'David Crow'
'sarah rees'; 'Susan Williams'
RE: VicForests and AFS
Hello Alex Thank you for your quick response We are fairly flexible on days after the 6th but would request that meetings are scheduled after 10:30 am Please let me know dates that suit you Today criminal action has been launched against VicForests for illegal logging activities http://www.theage.com.au/environment/conservation/green‐group‐in‐logging‐case‐bid‐20100630‐zmu4.html Kind Regards Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
distribution or reproduction of this message is strictly prohibited. From: Alex Ezrakhovich [mailto:Alex.Ezrakhovich@saiglobal.com]
Sent: Monday, 28 June 2010 3:27 PM
To: adam@myenvironment.org.au; David Crow
Cc: sarah rees; Susan Williams
Subject: RE: VicForests and AFS
Importance: High
1
Dear Adam,
Thank you for your email.
I have sent it to appropriate staff in our Melbourne office and it will be treated as customer complaint.
I am overseas now and will be happy to arrange meeting with you on my return – after the 6th of July.
Please propose suitable date and communicate it to David Crow –General Manager Australian Operations.
Regards,
_______________________________
Alex Ezrakhovich
General Manager - SAI Global Certification Services
SAI Global
GPO Box 5420 Sydney NSW 2001
286 Sussex Street Sydney NSW 2000
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
alex.ezrakhovich@saiglobal.com
To: Alex Ezrakhovich
Subject: VicForests and AFS
Importance: High
Dear Alex I have recently spoken with Sue Williams form JAS‐ANZ in relation to concerns that MyEnvironment Inc have in relation to the accreditation by VicForests to the AFS standard by SAI‐Global. We will be formally submitting these concerns to VicForersts and expect that they will be part of the next audit review at a whole of management level. I have previously sent the following to Sabrina Curber. I would appreciate a meeting to discuss our concerns with you in more detail. Dear Sabrina We have been submitting breaches to VicForests in relation to the AFS certification as fast as we can write them up and will start on breaches for East Gipsland, and the “whole of VicForests” management approach this week. We have brought a number of serious on the ground issues to the attention of Nathan Trushell (Director of Compliance) and he and Peter Appleford (Director of Forests) have requested a tour. We have a scientist finishing off a report that we believe will show that they have just logged zone 1 A Leadbeaters habitat in April this year (Victorias endangered faunal emblem). Our primary concern at the moment is that the AFS certification has been given to VicForests and is giving VicForests and their customers the right to make claims that the wood is coming from sustainably managed native forests. We believe that we have a strong case that shows that they are failing all 7 objectives of their sustainability charter. As the auditor we were wondering what SAI‐Globals position is on the following: 1. Regional Forest Agreements (RFA) and Forest Management Plans Despite being legislated to be reviewed every 5 years, none of the RFA’s have been reviewed in Victoria at either the 5 or 10 year point – A review has now been scheduled for mid 2010 but does this mean that the legislation has been invalid for the last 10 years. The forest management plans across Victoria are the key documents for updating management practices for managing sustainability and despite the requirement for them to be regularly reviewed have never been updated and are now out of date by 2‐4 years. Can an AFS certification be issued under such conditions? 2
2. Sustainability Reporting The State of the forest report is the mechanism by which the sustainability performance is measured however 2/3 of the data is missing from the last report. The other mechanism is third party auditing which has not taken place for three years and the scope and representativeness of audits prior to this have been questioned. Given the lack of public transparency we are concerned at the adequacy of VicForests own “report of operations” however, this only shows progress towards achieving objectives not performance. What criteria is SAI‐Global using to evaluate the performance of sustainability for accreditation to the AFS ?
3. The CAR reserve system The review or the CAR reserve is overdue and out of date especially following the bushfires again key legislation underpinning forestry and sustainability. Should this be considered in the AFS certification? 4. Regeneration and conversion If native forest is being clear felled and not regenerated then it is not a sustainable industry nor is it sustainable for biodiversity. The results from the Department of Sustainability and Environments Monitoring Annual Harvesting Performance 2007/2008 proves that logging in Victoria based on regeneration performance alone is unsustainable. Another aspect is that coupes that have laid fallow for over 3 years have limited capacity to regenerate with the biodiversity of the original native species. Fire breaks cut through national parks and state forest from 2007‐2010 have converted 600 km of forest into cleared land. This wood has been labelled with the AFS certification. This is a considerable component of the AFS certification and at what point does SAI‐Global consider non forest regeneration as land conversion? 3
Further more accreditation to the AFS since 2007 seems to be in contradiction to the EIAP review of the MAHP report: 5. Economic sustainability 4
The following captures have been taken from VicForests Annual report 2009 Economically VicForests
made a 5 million dollar loss in 2009 - and closer to 10 million if you take out "other revenue" not from the
sale of forest products such as 5.7 and 1.3 million dollars given in 2008, 2009 for bushfire recovery.
Approximately 60% of the total revenues are coming from woodchips which is a low value commodity
market that is not going to improve profits in the future
5
As an interested partie that works across the state of Victoria on forest issues particularly in relation to VicForests and forest certification we would like to be involved in the next audit to bring this issues to the attention of SAI‐
Global Could you please advise who we should speak with regarding this? Kind Regards Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
distribution or reproduction of this message is strictly prohibited. 6
Victoria 3777
03 5962 3461
Appendix 4
Adam Menary
From:
Sent:
To:
Cc:
Subject:
Alex Ezrakhovich [Alex.Ezrakhovich@saiglobal.com]
Thursday, 1 July 2010 7:39 PM
adam@myenvironment.org.au; David Crow
'sarah rees'; 'Susan Williams'
RE: VicForests and AFS - Meeting from the 13th
Dear Adam,
I will contact you next week.
Regards,
_______________________________
Alex Ezrakhovich
SAI Global
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
Sent: Thursday, 1 July 2010 7:36 PM
To: Alex Ezrakhovich; David Crow
Cc: 'sarah rees'; 'Susan Williams'
Subject: RE: VicForests and AFS - Meeting from the 13th
Hello Alex Sorry i was out by a week – we would be available from the 13th after 10:30am Thank you for your quick response We are fairly flexible on days after the 13th but would request that meetings are scheduled after 10:30 am Please let me know dates that suit you Today criminal action has been launched against VicForests for illegal logging activities http://www.theage.com.au/environment/conservation/green‐group‐in‐logging‐case‐bid‐20100630‐zmu4.html Kind Regards Adam Menary PO Box 519 1
Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.

Please consider the environment before printing this email and if you must please use 100% post consumer waste recycled paper
Importance: High
Dear Adam,
Thank you for your email.
I have sent it to appropriate staff in our Melbourne office and it will be treated as customer complaint.
I am overseas now and will be happy to arrange meeting with you on my return – after the 6th of July.
Please propose suitable date and communicate it to David Crow –General Manager Australian Operations.
Regards,
_______________________________
Alex Ezrakhovich
SAI Global
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
Importance: High
Dear Alex I have recently spoken with Sue Williams form JAS‐ANZ in relation to concerns that MyEnvironment Inc have in relation to the accreditation by VicForests to the AFS standard by SAI‐Global. We will be formally submitting these concerns to VicForersts and expect that they will be part of the next audit review at a whole of management level. I have previously sent the following to Sabrina Curber. I would appreciate a meeting to discuss our concerns with you in more detail. Dear Sabrina 2
We have been submitting breaches to VicForests in relation to the AFS certification as fast as we can write them up and will start on breaches for East Gipsland, and the “whole of VicForests” management approach this week. We have brought a number of serious on the ground issues to the attention of Nathan Trushell (Director of Compliance) and he and Peter Appleford (Director of Forests) have requested a tour. We have a scientist finishing off a report that we believe will show that they have just logged zone 1 A Leadbeaters habitat in April this year (Victorias endangered faunal emblem). Our primary concern at the moment is that the AFS certification has been given to VicForests and is giving VicForests and their customers the right to make claims that the wood is coming from sustainably managed native forests. We believe that we have a strong case that shows that they are failing all 7 objectives of their sustainability charter. As the auditor we were wondering what SAI‐Globals position is on the following: 1. Regional Forest Agreements (RFA) and Forest Management Plans Despite being legislated to be reviewed every 5 years, none of the RFA’s have been reviewed in Victoria at either the 5 or 10 year point – A review has now been scheduled for mid 2010 but does this mean that the legislation has been invalid for the last 10 years. The forest management plans across Victoria are the key documents for updating management practices for managing sustainability and despite the requirement for them to be regularly reviewed have never been updated and are now out of date by 2‐4 years. Can an AFS certification be issued under such conditions? 2. Sustainability Reporting The State of the forest report is the mechanism by which the sustainability performance is measured however 2/3 of the data is missing from the last report. The other mechanism is third party auditing which has not taken place for three years and the scope and representativeness of audits prior to this have been questioned. Given the lack of public transparency we are concerned at the adequacy of VicForests own “report of operations” however, this only shows progress towards achieving objectives not performance. What criteria is SAI‐Global using to evaluate the performance of sustainability for accreditation to the AFS ?
3. The CAR reserve system 3
The review or the CAR reserve is overdue and out of date especially following the bushfires again key legislation underpinning forestry and sustainability. Should this be considered in the AFS certification? 4. Regeneration and conversion If native forest is being clear felled and not regenerated then it is not a sustainable industry nor is it sustainable for biodiversity. The results from the Department of Sustainability and Environments Monitoring Annual Harvesting Performance 2007/2008 proves that logging in Victoria based on regeneration performance alone is unsustainable. Another aspect is that coupes that have laid fallow for over 3 years have limited capacity to regenerate with the biodiversity of the original native species. Fire breaks cut through national parks and state forest from 2007‐2010 have converted 600 km of forest into cleared land. This wood has been labelled with the AFS certification. This is a considerable component of the AFS certification and at what point does SAI‐Global consider non forest regeneration as land conversion? Further more accreditation to the AFS since 2007 seems to be in contradiction to the EIAP review of the MAHP report: 4
5. Economic sustainability The following captures have been taken from VicForests Annual report 2009 Economically VicForests
5
As an interested partie that works across the state of Victoria on forest issues particularly in relation to VicForests and forest certification we would like to be involved in the next audit to bring this issues to the attention of SAI‐
Global Could you please advise who we should speak with regarding this? Kind Regards 6
Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
Victoria 3777
03 5962 3461
Appendix 5
Adam Menary
David Crow [David.Crow@saiglobal.com]
Tuesday, 13 July 2010 9:52 PM
adam@myenvironment.org.au
Alex Ezrakhovich
Vic Forests
From:
Sent:
To:
Cc:
Subject:
Adam,
Alex has spoken to me re your interest in meeting with us to discuss our client Vic Forests.
I have been advised that you have commenced an action against Vic Forests in the Magistrates Court and as a result
of that we will therefore be unable to meet with you.
Regards
_________________________________
David Crow
General Manager Australian Assurance
Assurance Services
SAI Global
19-25 Raglan Street
Locked Bag 90
South Melbourne VIC 3205
Phone: +61 3 9693 3550
Mobile: +61 413 444 633
Fax: +61 3 9696 1309
www.saiglobal.com
Email: david.crow@saiglobal.com
1
Victoria 3777
03 5962 3461
Appendix 6
Adam Menary
From:
Sent:
To:
Subject:
Wednesday, 14 July 2010 2:32 PM
'Alex Ezrakhovich'; 'David Crow'
RE: Vic Forests
HI Alex Sorry if there has been some confusion – this is a true statement but its not being brought by MyEnvironment Inc Kind Regards Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
Sent: Wednesday, 14 July 2010 1:51 PM
Subject: RE: Vic Forests
Adam,
The information came from you.
See email below:
Subject: RE: VicForests and AFS - Meeting from the 13th
Hello Alex
1
Sorry i was out by a week – we would be available from the 13th after 10:30am
Thank you for your quick response
We are fairly flexible on days after the 13th but would request that meetings are scheduled after 10:30 am
Please let me know dates that suit you
Today criminal action has been launched against VicForests for illegal logging activities
http://www.theage.com.au/environment/conservation/green-group-in-logging-case-bid-20100630zmu4.html
Kind Regards
Adam Menary
Regards,
_______________________________
Alex Ezrakhovich
SAI Global
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
Sent: Wednesday, 14 July 2010 1:48 PM
To: David Crow
Cc: Alex Ezrakhovich
Subject: RE: Vic Forests
Hello David Not sure where you got that information from we have not instigated the case There is however a case Kind Regards Adam Menary PO Box 519 Healesville Vic 3777 2
adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
distribution or reproduction of this message is strictly prohibited. From: David Crow [mailto:David.Crow@saiglobal.com]
Sent: Tuesday, 13 July 2010 9:52 PM
To: adam@myenvironment.org.au
Cc: Alex Ezrakhovich
Subject: Vic Forests
Adam,
Alex has spoken to me re your interest in meeting with us to discuss our client Vic Forests.
I have been advised that you have commenced an action against Vic Forests in the Magistrates Court and as a result
of that we will therefore be unable to meet with you.
Regards
_________________________________
David Crow
General Manager Australian Assurance
Assurance Services
SAI Global
19-25 Raglan Street
Locked Bag 90
South Melbourne VIC 3205
Phone: +61 3 9693 3550
Mobile: +61 413 444 633
Fax: +61 3 9696 1309
www.saiglobal.com
Email: david.crow@saiglobal.com
3
Victoria 3777
03 5962 3461
Appendix 7
From: sarah rees [mailto:sarah@myenvironment.org.au]
Sent: Monday, 4 October 2010 2:47 PM
To: info@forestrystandard.org.au
Cc: adam@myenvironment.org.au; Susan Williams; Vanessa Bleyer; Luke Chamberlain; Chris Taylor
Subject: SAI global at risk of negligent auditing - AFS linked with extinction
Dear Kay Watts,
Our organisation has been working on forest issues in relation to threatened species
management and water for over a decade. Of late we have attempted to make contact with
SAI Global to forward our research, and that of Australia's leading scientists, to advise of
threats to arboreal mammals and water quantity and quality resultant of poor forestry
practices. We have attempted to meet with SAI Global to raise a number of issues so as can
be considered in the context of certification. This has been ignored as you will see in the
attached emails. We wish to draw your attention to some new developments and the risk AFS
now faces in light of new findings.
Please read this weekends Age story to stimulate further thoughts on how the AFS is being
awarded to a company procuring logs from endangered species habitat and that this process is
leading to extinction.
http://www.theage.com.au/environment/hello-possum-youre-an-emblem-ofextinction-20101001-1614u.html
This article featuring in the Age newspaper provides strong scientific evidence of VicForests
Central Highlands wood source links to extinction. AFS is certifying forestry linked to
the extinction of Victoria's faunal emblem.
This article establishes that forestry is leading to the extinction of species. The article
focusses principally on Victoria's faunal emblem ; The Leadbeaters Possum.
The Leadbeaters Possum is a globally recognised endangered species, it is a; British
Zoological Society Edge species (No. 54), IUCN Red Listed species, federally listed EPBC
Act endangered species, FFG Act endangered species and can claim 27 years of long-term
monitoring to establish that ''Forestry is the key threatening process,'', stated by Eureka
prize winning scientist from the Australian National University Prof. David Lindenmayer.
Five sites surveyed recently by a scientific consultancy contained Leadbeaters
Possum habitat. Four of the five are now logged . One site actually contained a
Leadbeaters Possum monitoring site of the Australian National University.
Further to this matter, a report by government, stated that logging in green forests
and black forests would put endangered species at further risk. The Burned Area
Emergency Response (BAER) Team, containing of 60 scientists and specialists
from the USA and under the guidance of Australian government specialists, flew to
Victoria's Central Highlands to conduct assessments and establish remedial actions
to mitigate the impacts of the fires in the Central Highlands.
The following statement 'Critical Action Recommendations' resultant of the BAER
report were underscored but ignored by forestry agencies. As a consequence wood
flows have continued out of habitat that is considered 'critical' to endangered taxon.
The attached link establishes the logging in critical habitat. Further evidence of
endangered species logging and the logging of pre-1900 forests (unlawful) is under
investigation by the state government and a report on this matter is being finalised
- all of which is AFS certified.
http://www.myenvironment.net.au/index.php/me/Our-work/Forests/Forest-Resources/BAERlogging-overlay
CRITICAL ACTIONS:
D. Management Recommendations – Non-Specification Related
4. The loss of large hollow bearing trees has been listed as a threatening process in the
Flora and Fauna Guarantee Act (1988). As such, land managers are obliged to manage hollow
resources sustainably. The preservation of as many of these trees as possible is crucial to the
approximately 400 fauna species (Ambrose 1982) that depend on them, of which approximately
100 are listed as rare, threatened, or near-threatened in state or commonwealth endangered
species legislation. For many of these species the use of hollows is obligate; no other habitat
resource represents a feasible substitute (Gibbons and Lindenmayer 2002). Though there is an
economic need to salvage log areas impacted by the fires, extreme care should be exercised in
removing large hollow bearing trees from areas of the landscape. Salvage logging after the 1939
fires within the study area “contributed to a pronounced shortage of cavity trees for more than 40
species of vertebrates—a major biodiversity conservation problem that will take more than 200
years to rectify” (Lindenmayer et al. 1997 quoted in Lindenmayer and Noss 1996)
It is recommended that none be removed from fire affected areas known to contain Leadbeater’s
possum, powerful and sooty owls, and within Leadbeater’s possum reserves. The indirect effects
of the fires will result in decreased cover and prey abundance and increased competition and
predation. The mid-story canopy which provides habitat connectivity and allows arboreal
mammals to move through forests has been lost. These impacts in conjunction with decreased
numbers of hollow bearing trees per hectare in most forests types due to silviculture, firewood
collection, die backs, grazing, and clearing (Gibbons and Lindenmayer 2002), could lead to
significant negative effects. Further loss of a critical habitat component, such as hollow bearing
trees, will decrease the chances of survival and persistence of these species in many areas. In
general, salvage logging in less sensitive areas should be well planned to minimize decreases in
large hollow bearing tree density. Surveys prior to harvest should be conducted to identify large
hollow bearing trees to be left standing. The number of trees/ha should strictly follow
prescriptions in the Fire Salvage Harvesting Prescriptions (2008). During salvage operations
surveys should be conducted to ensure prescriptions are being followed and regulations are
enforced.
Given the extent of the three large fires in the past six years and the significant reduction in
available hollows amongst appropriate habitat/food resources and the subsequent threat this
presents to hollow dependant species, further consideration should be given to increasing the
number of large trees/Ha retained as part of fire salvage harvesting prescriptions. The reduction
of available log volumes must not be supplemented from other logging areas, rather the volumes
must be reduced to reflect the overall depletion of the timber resource and habitat resource.
Logging license volumes must be reviewed and if necessary reduced to reflect the decreased
availability of suitable saw logs as a result of the three large fires in the past six years.
Linking unburned patches and areas of low intensity fire should be made a high
priority to enable fauna dispersal and re-colonization. Threats to habitat corridors should also be
identified and mitigated in order to improve movement among habitat types and populations of
individuals. Identification of major wildlife corridors should be made based in priority order on,
unburned areas within the current reserve system (National Parks and Leadbeater’s Possum
Reserves), unburned areas of mountain and alpine ash, areas of low intensity fires, riparian
corridors, and areas with moderate to severe intensity vegetation mortality which link the
remaining green areas
Australian Paper, Gunns and Midway exports have been the principle recipients of
this wood supply.
Please see photo for a quick example of the log hauling of hollow bearing forest, taken in
October 2009.
We have a growing mountain of evidence from studies and stumps to verify that VicForest is
continuing to log hollow bearing and pre 1900 tree's despite recommendations.
The latest findings have also linked VicForests to the logging of water catchments to the
detriment of water quality in supply catchments to Melbourne and the Goulburn. The Board
of the National Health and Medical Research Council are receiving a report on this and we
will bring this to the AFS meeting.
This matter is of the utmost seriousness and requires immediate action by SAI Global, JASANZ and AFS.
Yours Kindly,
Sarah Rees
Executive Director
MyEnvironment Inc
sarah@myenvironment.org.au
Suite 3, 5 Church Street Healesville 3777
P 03 5962 3461
F 03 5962 1958
M 0438 368870
Always print on 100% post consumer waste, recycled paper.
Important: This message may contain confidential information intended only
for the use of the addressee named above. If you are not the intended
recipient of this message you are hereby notified that any use,
dissemination, distribution or reproduction of this message is strictly
prohibited.
Victoria 3777
03 5962 3461
Appendix 8
Adam Menary
From:
Sent:
To:
Cc:
Subject:
Monday, 4 October 2010 4:04 PM
'info@forestrystandard.org.au'
'Susan Williams'; 'Vanessa Bleyer'; 'Luke Chamberlain'; 'Chris Taylor'; 'sarah rees'
RE: Alleged Breaches by VicForests to AFS Certification
Dear Kayt The following table is a list of alleged breaches by VicForests in relation to the; 


Central Highlands Forest Management Plan Code of Forest Practice AFS certification These alleged breaches are currently under investigation by the Department of Sustainability and Environment. Please find details below with links to specific details of each alleged breach for your review. Updated 16‐Sep‐10 Date Contact person Alleged Breach # Details of information request or alleged breaches submitted 15/06/2010 Nathan Trushell 201 Breach 201 Stream Logging coupe 300‐901‐0008 15/06/2010 Nathan Trushell 202 Breach 202 Proposed logging of old growth 16/06/2010 Nathan Trushell 203 Breach 203 proposed logging of Leadbeaters habitat 16/06/2010 Nathan Trushell 204 Breach 204 Logging of pre 1900 tree 16/06/2010 Nathan Trushell 206 Breach 206 logging of pre 1900 tree 17/06/2010 Nathan Trushell 208 Alleged breach 208 landing operations and hauling in wet weather 17/06/2010 Nathan Trushell 209 Alleged breach 209 logging of pre 1900 tree 31/08/2010 Nathan Trushell 502 Alleged Breach 0502 Failure re Sustainability Charter Objective 2 15/09/2010 Nathan Trushell 207 Alleged Breach 0207 Logging of Leadbeaters Zone 1A habitat Regarding the Brown Mountain case could AFS Limited please provide MyEnvironment inc with a summary, in terms of how the AFS certification was breached by VicForests and what affect this will have on VicForets certification? Could AFS Limited please provide MyEnvironment Inc with a summary of what the affect on AFS certification would be, if it was shown that a company certified to AFS was found to be logging Endangered Leadbeaters possum habitat in several regions over several years? In the above table alleged breaches in the 2xx range are individual cases. Whereas, alleged breaches in the 5xx range are considered to have a higher risk profile and demonstrate that there is allegedly ongoing management prescription failures in relation to AFS. In relation to alleged breach 502 “We believe that based on these breaches the previous and current
certification of VicForests’ timber under the AFS is invalid and we request that AFS certification be
immediately withdrawn. We also request that no further certification be awarded until such time as
VicForests can demonstrate that its forest regeneration is “effective and timely” as required by the
standard.”
1
We look forward to your response on these issues at your earliest convenience. Regards Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
distribution or reproduction of this message is strictly prohibited. From: sarah rees [mailto:sarah@myenvironment.org.au]
Dear Kay Watts,
Our organisation has been working on forest issues in relation to threatened species management and water
for over a decade. Of late we have attempted to make contact with SAI Global to forward our research, and
that of Australia's leading scientists, to advise of threats to arboreal mammals and water quantity and quality
resultant of poor forestry practices. We have attempted to meet with SAI Global to raise a number of issues
so as can be considered in the context of certification. This has been ignored as you will see in the attached
emails. We wish to draw your attention to some new developments and the risk AFS now faces in light of
new findings.
Please read this weekends Age story to stimulate further thoughts on how the AFS is being awarded to a
company procuring logs from endangered species habitat and that this process is leading to extinction.
2
from the USA and under the guidance of Australian government specialists, flew
to Victoria's Central Highlands to conduct assessments and establish remedial
actions to mitigate the impacts of the fires in the Central Highlands.
The following statement 'Critical Action Recommendations' resultant of the BAER report were
underscored but ignored by forestry agencies. As a consequence wood flows have continued out
of habitat that is considered 'critical' to endangered taxon. The attached link establishes the
logging in critical habitat. Further evidence of endangered species logging and the logging of
pre-1900 forests (unlawful) is under investigation by the state government and a report on this
matter is being finalised - all of which is AFS certified.
http://www.myenvironment.net.au/index.php/me/Our-work/Forests/Forest-Resources/BAER-loggingoverlay
CRITICAL ACTIONS:
3
enforced.
Australian Paper, Gunns and Midway exports have been the principle recipients of this wood
supply.
4
Please see photo for a quick example of the log hauling of hollow bearing forest, taken in October 2009.
We have a growing mountain of evidence from studies and stumps to verify that VicForest is continuing to
log hollow bearing and pre 1900 tree's despite recommendations.
The latest findings have also linked VicForests to the logging of water catchments to the detriment of water
quality in supply catchments to Melbourne and the Goulburn. The Board of the National Health and
Medical Research Council are receiving a report on this and we will bring this to the AFS meeting.
This matter is of the utmost seriousness and requires immediate action by SAI Global, JAS-ANZ and AFS.
Yours Kindly,
Sarah Rees
Executive Director
MyEnvironment Inc
5
P 03 5962 3461
F 03 5962 1958
M 0438 368870
prohibited.
On 01/07/2010, at 7:38 PM, Alex Ezrakhovich wrote:
Dear Adam, I will contact you next week. Regards, _______________________________
Alex Ezrakhovich
General Manager - SAI Global Certification Services SAI Global
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
alex.ezrakhovich@saiglobal.com From: Adam Menary [mailto:adam@myenvironment.org.au]
Subject: RE: VicForests and AFS - Meeting from the 13th Hello Alex Sorry i was out by a week – we would be available from the 13th after 10:30am Thank you for your quick response We are fairly flexible on days after the 13th but would request that meetings are scheduled after 10:30 am Please let me know dates that suit you Today criminal action has been launched against VicForests for illegal logging activities http://www.theage.com.au/environment/conservation/green‐group‐in‐logging‐case‐bid‐20100630‐zmu4.html Kind Regards 6
Adam Menary <image001.png> PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience. 
Importance: High Dear Adam, Thank you for your email. I have sent it to appropriate staff in our Melbourne office and it will be treated as customer complaint. I am overseas now and will be happy to arrange meeting with you on my return – after the 6th of July. Please propose suitable date and communicate it to David Crow –General Manager Australian Operations.
Regards, _______________________________
Alex Ezrakhovich
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
Importance: High Dear Alex I have recently spoken with Sue Williams form JAS‐ANZ in relation to concerns that MyEnvironment Inc have in relation to the accreditation by VicForests to the AFS standard by SAI‐Global. We will be formally submitting these concerns to VicForersts and expect that they will be part of the next audit review at a whole of management level. I have previously sent the following to Sabrina Curber. I would appreciate a meeting to discuss our concerns with you in more detail. 7
Dear Sabrina We have been submitting breaches to VicForests in relation to the AFS certification as fast as we can write them up and will start on breaches for East Gipsland, and the “whole of VicForests” management approach this week. We have brought a number of serious on the ground issues to the attention of Nathan Trushell (Director of Compliance) and he and Peter Appleford (Director of Forests) have requested a tour. We have a scientist finishing off a report that we believe will show that they have just logged zone 1 A Leadbeaters habitat in April this year (Victorias endangered faunal emblem). Our primary concern at the moment is that the AFS certification has been given to VicForests and is giving VicForests and their customers the right to make claims that the wood is coming from sustainably managed native forests. We believe that we have a strong case that shows that they are failing all 7 objectives of their sustainability charter. As the auditor we were wondering what SAI‐Globals position is on the following: 1. Regional Forest Agreements (RFA) and Forest Management Plans Despite being legislated to be reviewed every 5 years, none of the RFA’s have been reviewed in Victoria at either the 5 or 10 year point – A review has now been scheduled for mid 2010 but does this mean that the legislation has been invalid for the last 10 years. The forest management plans across Victoria are the key documents for updating management practices for managing sustainability and despite the requirement for them to be regularly reviewed have never been updated and are now out of date by 2‐4 years. Can an AFS certification be issued under such conditions? 2. Sustainability Reporting The State of the forest report is the mechanism by which the sustainability performance is measured however 2/3 of the data is missing from the last report. The other mechanism is third party auditing which has not taken place for three years and the scope and representativeness of audits prior to this have been questioned. Given the lack of public transparency we are concerned at the adequacy of VicForests own “report of operations” however, this only shows progress towards achieving objectives not performance. What criteria is SAI‐Global using to evaluate the performance of sustainability for accreditation to the AFS ?
<image002.png> 3. The CAR reserve system The review or the CAR reserve is overdue and out of date especially following the bushfires again key legislation underpinning forestry and sustainability. Should this be considered in the AFS certification? 4. Regeneration and conversion If native forest is being clear felled and not regenerated then it is not a sustainable industry nor is it sustainable for biodiversity. The results from the Department of Sustainability and Environments Monitoring Annual Harvesting Performance 2007/2008 proves that logging in Victoria based on regeneration performance alone is unsustainable. Another aspect is that coupes that have laid fallow for over 3 years have limited capacity to regenerate with the biodiversity of the original native species. Fire breaks cut through national parks and state forest from 2007‐2010 have converted 600 km of forest into cleared land. This wood has been labelled with the AFS certification. This is a considerable component of the AFS certification and at what point does SAI‐Global consider non forest regeneration as land conversion? <image003.png> Further more accreditation to the AFS since 2007 seems to be in contradiction to the EIAP review of the MAHP report: <image004.png> 8
5. Economic sustainability The following captures have been taken from VicForests Annual report 2009 Economically VicForests
<image005.png> As an interested partie that works across the state of Victoria on forest issues particularly in relation to VicForests and forest certification we would like to be involved in the next audit to bring this issues to the attention of SAI‐
Global Could you please advise who we should speak with regarding this? Kind Regards Adam Menary <image001.png> PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience. 
Victoria 3777
03 5962 3461
Appendix 10
Adam Menary
From:
Sent:
To:
Cc:
Subject:
Monday, 4 October 2010 5:34 PM
'info@forestrystandard.org.au'
Nathan Trushell (nathan.trushell@vicforests.com.au); sarah rees
Inability to act as a stakeholder in AFS process
Dear Kayt Watts As stakeholders in the AFS process MyEnvironment Inc would like to conduct some pre logging surveys in the Central Highlands. As highlighted in my previous email to Nathan Trushell at VicForests MyEnvironment Inc have been requesting some basic coupe scheduling information from VicForests for over 3 months and to date we have not been provided with this information. Could you please provide MyEnvironment Inc with AFS Limited’s position on whether this lack of provision of basic information to allow MyEnvironment Inc to be meaningful stakeholders is in keeping with the requirements of the AFS certification? Please advise what we should do from here? Kind Regards Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.

Victoria 3777
03 5962 3461
Appendix 11
Adam Menary
From:
Sent:
To:
Cc:
Subject:
Wednesday, 13 October 2010 9:59 AM
'ceo@forestrystandard.org.au'
sarah rees; 'Vanessa Bleyer'
Inability to act as a stakeholder in AFS process
Dear Kayt Watts (CEO AFS Limited) As per my previous email this email was sent to you on the 4th of October could you please provide acknowledgement of receipt of this email and an indication of when you will respond the questions raised in this email? Adam Menary Dear Kayt Watts As stakeholders in the AFS process MyEnvironment Inc would like to conduct some pre logging surveys in the Central Highlands. As highlighted in my previous email to Nathan Trushell at VicForests MyEnvironment Inc have been requesting some basic coupe scheduling information from VicForests for over 3 months and to date we have not been provided with this information. Could you please provide MyEnvironment Inc with AFS Limited’s position on whether this lack of provision of basic information to allow MyEnvironment Inc to be meaningful stakeholders is in keeping with the requirements of the AFS certification? Please advise what we should do from here? Kind Regards Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
1
Victoria 3777
03 5962 3461
Appendix 12
Adam Menary
From:
Sent:
To:
Cc:
Subject:
Wednesday, 13 October 2010 9:56 AM
'ceo@forestrystandard.org.au'
'Susan Williams'; 'Vanessa Bleyer'; 'Luke Chamberlain'; 'Chris Taylor'; 'sarah rees'
RE: Alleged Breaches by VicForests to AFS Certification
Dear Kayt We have not received confirmation from AFS Limited that you have received the following email sent on the 4th of October 2010. Could you please send acknowledgement of the receipt of this email at your earliest convenience? Please advise a date when you will be able to respond to the questions raised in the email? Thank you Adam Menary ........ The following table is a list of alleged breaches by VicForests in relation to the; 


Central Highlands Forest Management Plan Code of Forest Practice AFS certification These alleged breaches are currently under investigation by the Department of Sustainability and Environment. Please find details below with links to specific details of each alleged breach for your review. Updated 16‐Sep‐10 Date Contact person Alleged Breach # Details of information request or alleged breaches submitted 15/06/2010 Nathan Trushell 201 Breach 201 Stream Logging coupe 300‐901‐0008 15/06/2010 Nathan Trushell 202 Breach 202 Proposed logging of old growth 16/06/2010 Nathan Trushell 203 Breach 203 proposed logging of Leadbeaters habitat 16/06/2010 Nathan Trushell 204 Breach 204 Logging of pre 1900 tree 16/06/2010 Nathan Trushell 206 Breach 206 logging of pre 1900 tree 17/06/2010 Nathan Trushell 208 Alleged breach 208 landing operations and hauling in wet weather 17/06/2010 Nathan Trushell 209 Alleged breach 209 logging of pre 1900 tree 31/08/2010 Nathan Trushell 502 Alleged Breach 0502 Failure re Sustainability Charter Objective 2 15/09/2010 Nathan Trushell 207 Alleged Breach 0207 Logging of Leadbeaters Zone 1A habitat Regarding the Brown Mountain case could AFS Limited please provide MyEnvironment inc with a summary, in terms of how the AFS certification was breached by VicForests and what affect this will have on VicForets certification? 1
Could AFS Limited please provide MyEnvironment Inc with a summary of what the affect on AFS certification would be, if it was shown that a company certified to AFS was found to be logging Endangered Leadbeaters possum habitat in several regions over several years? In the above table alleged breaches in the 2xx range are individual cases. Whereas, alleged breaches in the 5xx range are considered to have a higher risk profile and demonstrate that there is allegedly ongoing management prescription failures in relation to AFS. In relation to alleged breach 502 “We believe that based on these breaches the previous and current
certification of VicForests’ timber under the AFS is invalid and we request that AFS certification be
immediately withdrawn. We also request that no further certification be awarded until such time as
VicForests can demonstrate that its forest regeneration is “effective and timely” as required by the
standard.”
We look forward to your response on these issues at your earliest convenience. Regards Adam Menary PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.
distribution or reproduction of this message is strictly prohibited. From: sarah rees [mailto:sarah@myenvironment.org.au]
Dear Kay Watts,
Our organisation has been working on forest issues in relation to threatened species management and water
for over a decade. Of late we have attempted to make contact with SAI Global to forward our research, and
that of Australia's leading scientists, to advise of threats to arboreal mammals and water quantity and quality
resultant of poor forestry practices. We have attempted to meet with SAI Global to raise a number of issues
2
so as can be considered in the context of certification. This has been ignored as you will see in the attached
emails. We wish to draw your attention to some new developments and the risk AFS now faces in light of
new findings.
Please read this weekends Age story to stimulate further thoughts on how the AFS is being awarded to a
company procuring logs from endangered species habitat and that this process is leading to extinction.
from the USA and under the guidance of Australian government specialists, flew
to Victoria's Central Highlands to conduct assessments and establish remedial
actions to mitigate the impacts of the fires in the Central Highlands.
The following statement 'Critical Action Recommendations' resultant of the BAER report were
underscored but ignored by forestry agencies. As a consequence wood flows have continued out
of habitat that is considered 'critical' to endangered taxon. The attached link establishes the
logging in critical habitat. Further evidence of endangered species logging and the logging of
pre-1900 forests (unlawful) is under investigation by the state government and a report on this
matter is being finalised - all of which is AFS certified.
http://www.myenvironment.net.au/index.php/me/Our-work/Forests/Forest-Resources/BAER-loggingoverlay
CRITICAL ACTIONS:
3
enforced.
Australian Paper, Gunns and Midway exports have been the principle recipients of this wood
supply.
4
Please see photo for a quick example of the log hauling of hollow bearing forest, taken in October 2009.
We have a growing mountain of evidence from studies and stumps to verify that VicForest is continuing to
log hollow bearing and pre 1900 tree's despite recommendations.
The latest findings have also linked VicForests to the logging of water catchments to the detriment of water
quality in supply catchments to Melbourne and the Goulburn. The Board of the National Health and
Medical Research Council are receiving a report on this and we will bring this to the AFS meeting.
This matter is of the utmost seriousness and requires immediate action by SAI Global, JAS-ANZ and AFS.
Yours Kindly,
Sarah Rees
Executive Director
MyEnvironment Inc
P 03 5962 3461
5
F 03 5962 1958
M 0438 368870
prohibited.
On 01/07/2010, at 7:38 PM, Alex Ezrakhovich wrote:
Dear Adam, I will contact you next week. Regards, _______________________________
Alex Ezrakhovich
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
Subject: RE: VicForests and AFS - Meeting from the 13th Hello Alex Sorry i was out by a week – we would be available from the 13th after 10:30am Thank you for your quick response We are fairly flexible on days after the 13th but would request that meetings are scheduled after 10:30 am Please let me know dates that suit you Today criminal action has been launched against VicForests for illegal logging activities http://www.theage.com.au/environment/conservation/green‐group‐in‐logging‐case‐bid‐20100630‐zmu4.html Kind Regards Adam Menary 6
<image001.png> PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.  Please consider the environment before printing this email and if you must please use 100% post consumer waste recycled paper
Importance: High Dear Adam, Thank you for your email. I have sent it to appropriate staff in our Melbourne office and it will be treated as customer complaint. I am overseas now and will be happy to arrange meeting with you on my return – after the 6th of July. Please propose suitable date and communicate it to David Crow –General Manager Australian Operations.
Regards, _______________________________
Alex Ezrakhovich
Phone: + 61 2 8206 6970
Cell: + 61 413 440164
Fax: + 61 2 8206 6012
www.saiglobal.com
Importance: High Dear Alex I have recently spoken with Sue Williams form JAS‐ANZ in relation to concerns that MyEnvironment Inc have in relation to the accreditation by VicForests to the AFS standard by SAI‐Global. We will be formally submitting these concerns to VicForersts and expect that they will be part of the next audit review at a whole of management level. I have previously sent the following to Sabrina Curber. I would appreciate a meeting to discuss our concerns with you in more detail. Dear Sabrina 7
We have been submitting breaches to VicForests in relation to the AFS certification as fast as we can write them up and will start on breaches for East Gipsland, and the “whole of VicForests” management approach this week. We have brought a number of serious on the ground issues to the attention of Nathan Trushell (Director of Compliance) and he and Peter Appleford (Director of Forests) have requested a tour. We have a scientist finishing off a report that we believe will show that they have just logged zone 1 A Leadbeaters habitat in April this year (Victorias endangered faunal emblem). Our primary concern at the moment is that the AFS certification has been given to VicForests and is giving VicForests and their customers the right to make claims that the wood is coming from sustainably managed native forests. We believe that we have a strong case that shows that they are failing all 7 objectives of their sustainability charter. As the auditor we were wondering what SAI‐Globals position is on the following: 1. Regional Forest Agreements (RFA) and Forest Management Plans Despite being legislated to be reviewed every 5 years, none of the RFA’s have been reviewed in Victoria at either the 5 or 10 year point – A review has now been scheduled for mid 2010 but does this mean that the legislation has been invalid for the last 10 years. The forest management plans across Victoria are the key documents for updating management practices for managing sustainability and despite the requirement for them to be regularly reviewed have never been updated and are now out of date by 2‐4 years. Can an AFS certification be issued under such conditions? 2. Sustainability Reporting The State of the forest report is the mechanism by which the sustainability performance is measured however 2/3 of the data is missing from the last report. The other mechanism is third party auditing which has not taken place for three years and the scope and representativeness of audits prior to this have been questioned. Given the lack of public transparency we are concerned at the adequacy of VicForests own “report of operations” however, this only shows progress towards achieving objectives not performance. What criteria is SAI‐Global using to evaluate the performance of sustainability for accreditation to the AFS ?
<image002.png> 3. The CAR reserve system The review or the CAR reserve is overdue and out of date especially following the bushfires again key legislation underpinning forestry and sustainability. Should this be considered in the AFS certification? 4. Regeneration and conversion If native forest is being clear felled and not regenerated then it is not a sustainable industry nor is it sustainable for biodiversity. The results from the Department of Sustainability and Environments Monitoring Annual Harvesting Performance 2007/2008 proves that logging in Victoria based on regeneration performance alone is unsustainable. Another aspect is that coupes that have laid fallow for over 3 years have limited capacity to regenerate with the biodiversity of the original native species. Fire breaks cut through national parks and state forest from 2007‐2010 have converted 600 km of forest into cleared land. This wood has been labelled with the AFS certification. This is a considerable component of the AFS certification and at what point does SAI‐Global consider non forest regeneration as land conversion? <image003.png> Further more accreditation to the AFS since 2007 seems to be in contradiction to the EIAP review of the MAHP report: <image004.png> 5. Economic sustainability 8
The following captures have been taken from VicForests Annual report 2009 Economically VicForests
<image005.png> As an interested partie that works across the state of Victoria on forest issues particularly in relation to VicForests and forest certification we would like to be involved in the next audit to bring this issues to the attention of SAI‐
Global Could you please advise who we should speak with regarding this? Kind Regards Adam Menary <image001.png> PO Box 519 Healesville Vic 3777 adam@myenvironment.org.au 03 59622157 This email has been scanned by McAfee prior to being sent for your protection and convenience.  Please consider the environment before printing this email and if you must please use 100% post consumer waste recycled paper

PEFC complaint

Transcription

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