BULLETIN       Last update 16th Nov, 1999

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SA Govt Review Panel, Bundle-Tagging Proposal     

Industry Submission                       Discussion Paper

Industry Submission - SA Govt Review Panel, Bundle-Tagging Proposal                                        Back         

Discussion Paper - SA Govt Review Panel, Bundle-Tagging Proposal                                    Copy of Letter to Industry Members                                      Back

COPY OF LETTER TO INDUSTRY MEMBERS                   Back   

The BCCG has been approached for an industry response to the Final Draft Report of the National Competition Policy Legislation Review in South Australia, which recommends (among other things) the introduction of a brush bundle tagging and cutter licensing system in South Australia. See attached extracts from the Report.

A BCCG submission is required to be lodged with the Review Panel by the 10th November and feedback from industry members to BCCG will be required by 4th November at the latest to allow time for preparation of the response.

This is not the first time bundle tagging has been proposed in SA. About five years ago a similar initiative was met by concerted opposition from the brush fencing industry in this State and shelved.

Regards,

Hague Showell,   Coordinator: Aust. Brush Contractors Cooperative Group and Proprietor: Adelaide Brush (SA)

Preparation and distribution of this Newsletter is funded by Adelaide Brush                         Back 

 

EXTRACTS FROM THE FINAL DRAFT REPORT OF THE NATIONAL COMPETITION POLICY LEGISLATION REVIEW IN SOUTH AUSTRALIA                                                          Back   

Covering Letter to BCCG

 

 

Draft Review Report Cover

 

Extract from p43 of the Draft Review Concerning Tagging Proposal

 

 

THE PROBLEMS DRIVING THE NEED FOR CHANGE                                         Back

The World - our World - is a World under threat!  A small but rich pearl, a paradise floating in a vast black ocean of nothingness.  A World that is being ravaged by the needy excesses of the incumbent overpopulation of humans in what amounts to a brief instant of evolutional time.

In Australia the issues of land clearance and soil salinisation over vast areas of the country and ground and surface water usage/replenishment/quality issues will remain running sores for the better part of the next century and could provide a poisoned legacy for our children and those who follow. We need to be both responsive and responsible, sensitive and sensible in balancing our current resource needs against future needs.

It is not surprising, therefore, that the Government instrumentality's responsible for environmental management are doing their best to preserve the existing stands of native vegetation on both Crown and private lands and it would be criminal neglect if they did not try to do so.

The other perspective of course, is that as individuals and as a community we all need to earn a living and 'go forward', for to stand still is tantamount to going backward and none of us likes that option at all. Each new commercial venture in itself can be seen to be beneficial for the individual in order to go 'forward', however, the environment has its limits on the sheer number of individuals that may go 'forward' at one time.

Controls over industries involved in the 'taking' of flora and fauna are social means used to control and balance the 'forward' pressures against the need for environmental sustainability. Controls such as tagging and permit systems are used to restrict the quantities taken and to monitor areas from which they are taken and to enable management plans to be periodically effected.

I for one, would not like to be part of the permanent destruction or further degradation of our natural resources and believe that upon reflection, that all of us in the industry would like to ensure that we are part of a sustainable and eco-friendly human activity.

One of the gravest problems is that we do not have hard data on the usage and 'taking' of broombush, either in SA or in Australia as a whole. Government doesn't have accurate information on quantities/condition of remaining stands or quantities taken annually and not all contractors; cutters or landowners are willing to provide information either.

In citing the need for a tagging system for broombush harvesting, the sole argument used by the Govt Review Panel is quote "The amount of vegetation illegally harvested is reputed to be high relative to that legally harvested. Failure to adhere to the regulatory regime (sic. current permit system) is anti-competitive in that those who do comply are at a competitive disadvantage in relevant markets."

In asking one DEHA officer what reason he might have to believe that the amount of illegal harvesting activity had increased, his response was, that "applications for permits over the past few years had declined" and the presumption from that was that more illegal harvesting was taking place.

The phrase 'reputed to be high' used in the Report context above is not what I would call a strong basis for the proposed change, nor anecdotal evidence based on declining permit applications.

However, one must agree that a system does need to be put in place, to cut out the illegal activity that does occur (both on private property and in reserves). Perhaps more importantly, it is needed to provide a statistical basis for monitoring brush-harvesting activities from the wild.

To better understand the nature of the problem, let us now look at the best ballpark figures and status of the industry.

 

WHAT IS THE SIZE OF THE BRUSH INDUSTRY?                        Back

Today in Australia, there are around 80 brush fencing contractors with a combined annual brush fencing turnover of some $14m and producing around 140km of fencing per annum and 4 panel manufacturers producing about 40km of panels per annum. Around 50 cutters supply about 420,000 bundles per annum from native stands to the whole Australian industry. No brush is presently harvested from plantations! The brush industry is relatively small, with the value of broom harvested annually in the whole of Australia including SA around $4.2m (around $1.2m harvested in SA).

It is estimated that around 1300km of brush fencing has been erected in Australia over the past 20 years. Around 20km of existing fencing ranging in age from 15 to 35 years is restored each year.

Machine packed panels have been increasing in popularity in all States except SA (which is still primarily a traditional, hand packed market) and two years ago export of panels to Auckland, NZ commenced. The market to that country has grown from zero two years ago, with around 9km of modular fencing panels erected there per annum at present.

Earlier this year the first consignment of brush panels was sea freighted to the USA and displays were air freighted to the Marin County Home Show in June. The initiative is currently on hold, however, while shipping mold and distributor problems are addressed.

Fire damage (arson) has proved a nuisance in recent years, primarily in Adelaide, but has not stopped the popularity and growth of the brush fencing industry.

Brush supplies cut from native stands are adequate for the current level of demand, but with the growth of overseas export and the Sydney, Melbourne and Perth markets, it is likely that there will be a sustained shortage within 3 to 5 years. i.e. assuming no changes in Government policies in NSW regarding Western District Crown Leases, or to the SA permit system. If heritage areas in SA and VIC Crown Lands were made available, then a longer time frame may be evident but if NSW Crown Lands sources were restricted, there would be a shortage at present. WA and VIC banned the cutting of brush on their respective Crown Lands several years ago.

 

WHAT DOES THE FUTURE HOLD FOR THE BRUSH INDUSTRY?                     Back

Brush is a renewable resource, naturally occurring over vast areas of Australia and correctly managed, offers a low environmental impact fencing material, which theoretically could be harvested indefinitely (subject to soil fertility, soil salinity issues and climatic change).

Brush fencing is a natural material competing in a world of plastics and steel. It does not require hi-tech open cut mining to obtain the raw materials needed, or manufacturing complexes to refine and contrary to popular belief does not even require land clearance (as for say cereal crops) i.e. it is coppiced/trimmed and re-grows and can be re-harvested every 7 to 12 years dependent upon location. When broom-bush is cut completely or rolled, optimal and prolific re-growth and re-shooting occurs from the substantial ligno-tuber root systems of mature plants.

With professional marketing and product development, brush fencing in both modular and traditional hand packed form has a tremendous future... It is estimated that demand for brush will more than double over the next 10 to 15 years and subject to supply/price, it is likely that by the year 2010, around 1m bundles pa will be needed to service the industry.

It is envisaged that in 20 years time there will be a flourishing Australian industry exporting modular systems worldwide, with local markets utilizing high quality traditional hand packing as well as the modular systems. In that scenario it is imperative that plantation brush should eventually provide the bulk of industry requirements, coexisting with supply from well managed native stands.

Current plantation techniques are in a process of evolution and commercial viability is marginal under current regulatory and supply/demand regimes. Progress is excellent, however, and grower interest is high, with much having been learned over the past 10 years in trial plantations around South Australia. It is envisaged that plantation brush supplies will come on stream in significant quantities in around 10 years and it is likely that the development of true to type seed and other techniques over the next few years will ensure viability even under the current price structures.

Plantation brush is especially suited to use in machine packed panels (shorter brush can be used), but could well service the hand packed market with the current initiatives to improve the shape and form of the stems and plants.

 

HOW WILL PLANTATION BRUSH AFFECT ILLEGAL CUTTING                               Back

If all broom used by the industry could be plantation grown, would there still be a problem with illegal cutting? Yes is the likely answer, as broom cut illegally from native stands would not have any production costs other than harvesting and transport costs.

Likewise, legally cut brush from native stands would have lower production costs than plantation brush, unless the economies of large scale plantations (i.e. machine harvesting into bins, on-site manufacture into panels, lower freight costs), outweighed the inefficiencies of cutting from the wild (additional freight costs, manual cutting costs, bundling and man-handling out of the scrub etc).

The conclusion to be drawn is that plantation brush in itself will not solve the problem of illegal cutting.

 

OPTIONS FOR BETTER INDUSTRY MANAGEMENT?                                         Back

OK, we have a problem, some illegal cutting does occur, but no-one really knows (or can quantify) the extent, or determine how much damage it really does, given that broom regrows!  Irrespective, the industry does not condone the practice and it would be desirable to prevent illegal cutting on both private land and in the reserves.

What options are there for improved management?

In an ideal world we might have a map showing all stands of brush in Australia and status/availability to the industry or classification for conservation etc. Rangers would be camped out to protect the areas designated for conservation and armed guards would protect the industry usable stands from poachers.

In the real world the industry and community resources allowable for regulation of this resource for what is a fairly small industry are next to none and regulation needs to be simple and cost-effective.

Options enabling the tracking of brush usage and availability and curtailing of illegal harvesting, include bundle tagging and licensing systems as broadly described below.  What they would cost and whether the industry can afford the measures is another question.  If you have any other ideas please advise and I will post them here.

 

BUNDLE TAGGING & LICENSING PER REVIEW PANEL PROPOSAL                  Back

A typical tagging system might embody the following under a DEHA Management Plan and Quotas for each of a number of defined Land Management Regions;

a) Licensed Cutters (pay a license fee) and then purchase tags (subject to DEHA quotas for the land management region).

b) Cutters apply colour-coded, sealed tags to each bundle at point of cutting. Sealed tags purchased for say 30c each and different colours to represent different locations and sources e.g. plantation brush one colour, KI another, Eyre Peninsula another etc. Tags managed by DEHA and tag numbers issued each year for each area, dependent upon management plan and quotas for the year.

c) Sealed tags removed at work face and retained by contractor for period subject to regulation.

d) Unlicensed Cutters, illegal cutting and Contractors buying untagged broom, subject to fines.

 

PROBLEMS WITH THE PROPOSED BUNDLE TAGGING SYSTEMS??                                                                                                                                           Back

a)     What would stop an illegal cutter in SA from selling his brush to Melbourne or Sydney markets? Without a National tagging system, the cutter would need to be caught either in the act of cutting or transporting brush which is little different than the current system and would require policing in the bush as at present. Currently many Sydney and Melbourne based contractors are finding it impossible to get brush from NSW sources and enquiries to the BCCG are increasing regarding contact details for SA based cutters and supplies.

b)     If tagging were used for brush harvested in SA how would the bundles of NSW brush, which currently comes into SA in semi-trailer loads, be identified? One person spoken to at NSW State Forests commented that he thought a tagging system would create more problems than it would solve. He indicated that they did not have a significant problem with illegal cutting with their current licensing in NSW (Forest Products License) and weight based royalty system.

c)     How would the tagging system work in relation to brush cut loose into bins at mechanically harvested plantations (for use in an onsite panel machine) or brush cut legally and then processed into panels at the cutting site?

d)     If tagging were used, what about governments using the system for royalty/revenue raising purposes? The GST will impose an additional 10% slug on brush fencing because no material inputs are subject to the current sales tax. Bundle prices ex NSW are now fetching $13/bundle due to the present shortage. Can the industry afford further price rises due to a tagging system?

e)     What constitutes a bundle for tagging purposes? A 10kg single string bundle, a 20 or 25 or 30kg two string bundle? If bundle weights were to be checked, would dry, green or wet weights apply (enormous variations in weight are apparent for the same bundle under these different conditions).

f)     The Govt. Review Panel has indicated that a system similar to that used for kangaroo tagging is proposed. With the kangaroo tagging and licensing system an annual Management Plan is undertaken to allow harvest quotas to be determined for the 31 land management regions and the commensurate number of tags released for each area. The basis for the Management Plan is a comprehensive survey and data from a number of sources including aerial survey. Is it practical to determine a Management Plan and quotas for broombush in the same manner as for kangaroos, bearing in mind that the value of the broombush industry is only a fraction of the value of the kangaroo industry?

It would appear that a bundle tagging system is impractical for many or all of the above reasons and is not supported by the brush industry.

 

 

LICENSING OF CUTTERS & USERS IN SA                                                 Back

Another suggestion (instead of bundle tagging) has been for the licensing of SA cutters and contractors as follows;

a)     License all brush cutters and brush users (contractors and panel manufacturers) and slap a hefty fine on persons caught cutting or using brush without a license. Confiscate vehicles and equipment used by an illegal cutter or user (as for abalone fishing etc). 'Operator licenses' to be held by all cutter employees etc

b)     As a requirement for obtaining a cutter's license, have all cutters attend a one day education 'course' on the mallee environment (flora and fauna and land use conflicts and problems i.e. the do's and don'ts of cutting with respect to minimizing the environmental impact).

c)     Have cutters 'log in' to the DEHA ranger notifying each time they move on to a new patch or cease cutting, i.e. so that the ranger knows where the relatively small number of cutters are geographically located at any one time and what permits they are cutting under.

d)     When cutters advise they are moving to a new patch, cutters to provide the ranger with details of the number of bundles cut at the last patch/permit number.

e)     All brush shipments to be accompanied by paperwork showing the cutter name, permit number, consignee/user name and number of bundles.

f)     All users of brush in SA to be licensed by DEHA and to maintain records of all shipments received and provide an annual return, with copies of all paperwork.

A licensing system would probably not be favored by many in the industry but would certainly be more practical than a bundle tagging system and would not cost a lot to implement and manage. More importantly it would provide crosschecked usage data (from cutters and users) and would also identify the volumes of brush coming from interstate.

All of the above is for discussion purposes within the brush industry and does not represent a BCCG position. Your feedback please!

Queries please give me a call.

Hague Showell,   Coordinator, Australian Brush Contractors Cooperative Group

                                    Proprietor, Adelaide Brush (SA)