Regulatory Impact Statement: National Approach to Firewood Collection and Use in Australia
The draft National Approach was released for public comment from 18 December 2000 to 31 March 2001. The ANZECC Firewood Taskforce heard presentations from key stakeholders at a meeting held in Canberra on 13 February 2001. Presentations were made by private landowners, firewood merchants and representatives from Australian Forest Growers, Australian Conservation Foundation, Conservation Council - South East Region and Canberra, Victorian National Parks Association, rural welfare organisations, NSW State Forests and the Australian Home Heating Association.
These stakeholders offered conflicting views about the need for a regulatory approach. Forestry interests believe the draft National Approach focused too heavily on regulatory and prescriptive measures, while conservation groups believe the draft National Approach relied too heavily on voluntary measures and wanted more radical regulatory and market intervention. The firewood merchants who gave presentations were in favour of greater regulation and saw it as a way of exercising more control over less scrupulous, itinerant, operators.
Stakeholders exhibited a similar dichotomy of views concerning sourcing firewood from native forest and from the residue of logging operations in native forests.
Other matters raised in stakeholder presentations included:
- the lack of data on the impacts of firewood collection to target policy interventions;
- potential impacts on rural Australians on low incomes who rely on collecting firewood as a free or low cost source of heating;
- risks for landowners who establish plantations exclusively for firewood - including economic viability and the potential for a future ban on wood heaters; and
- willingness of consumers to purchase more common Eucalypt species such as stringybark rather than demand threatened woodland species such as box, ironbark and mallee.
In addition to the stakeholder presentations, 90 written submissions were received prior to the closing date for submissions - and a further 8 submissions after this date.
Major policy issues raised during the consultation process included:
- use of native forests and forestry residues for firewood;
- whether additional regulation of the firewood industry is warranted;
- socioeconomic impacts;
- the Charter of Environmental Care for Firewood Merchants:
- lack of consultation on its preparation; and
- whether it should be voluntary or mandatory;
- lack of sufficient data, especially the regional scale, on the impacts of firewood collection to target policy interventions.
The main issues raised in public consultations are summarised in Table 5. The 7 most popular issues were:
- Regulation of firewood collection
- Farm forestry/plantations
- Sustainable harvest of firewood
- Education strategy
- Information base
- Utilisation of waste timber after harvesting
- Air quality/health issues
The approach adopted in relation to each of these issues is discussed below:
Major Policy Issues
Use of native forests and forestry residues for firewood: Amendments to proposed actions in Strategy 5 of the revised National Approach encourage sustainable management of private native vegetation for firewood and increased use of residues from forestry operations as firewood. While conservation groups oppose use of residues from native forestry operations as firewood, under established Commonwealth and state government policy Regional Forest Agreements (RFA) ensure that forestry operations in RFA regions are managed sustainably. It has been clearly articulated that RFA regions contain specific areas set aside for production forestry, including production of firewood. Amendments to Strategy 5 of the revised National Approach are in line with the Commonwealth's commitment to the RFA process and recognise the potential of native forest residue to supply a significant proportion of firewood for domestic use. Advice from State Forests of NSW indicates an estimated 400,000 tonnes of native forestry residues could be made available from their native forestry operations for firewood. This represents a significant proportion of the estimated 1.4 million tonnes of firewood consumed each year in NSW and cannot be reasonably ignored in a national policy on firewood.
A proviso that sourcing increased quantities of firewood from native forest residues will not result in additional areas of forest being harvested was included in Strategy 5. This measure was included to overcome the concern of conservation groups that an increased market for residues has potential to drive forestry logging activities into areas which would otherwise be uneconomic to harvest.
Regulation: Adoption of a provisional, voluntary, Charter of Environmental Care for Firewood Merchants (known as the draft Voluntary Code of Practice for Firewood Merchants in the final version of the National Approach to Firewood Collection and Use in Australia endorsed by ANZECC) is recommended in the revised National Approach. Any additional controls on firewood collection or the operations of merchants would be implemented by States and Territories through their Action Plans. This is discussed in further detail below.
No significant changes were made to Strategy 4, which deals with regulatory actions. However, the objective and discussion in Strategy 4 of the revised National Approach have been amended to clarify that proposed actions refer to increasing the effectiveness and enforcement of existing regulatory instruments dealing with protection of native vegetation and threatened species. Any new regulations would most likely have significant resource implications and, on the basis of submissions, would be strongly resisted in rural areas. This strategy seeks to ensure that existing codes of forest practice (established to ensure forestry operations are sustainable) are applied to commercial firewood collection on public and private land.
Socioeconomic impacts: Assessment of the socioeconomic impacts of proposed regulatory and market mechanisms at the national level is not feasible because of the way the National Approach has been designed and will be implemented. The National Approach proposes a framework or toolkit of actions for governments to encourage a more ecologically sustainable firewood industry, which contributes to the protection of remnant woodland vegetation and threatened woodland species. Socioeconomic assessment will be possible and more relevant following the preparation of State Action Plans, as these plans will include specific measures to be adopted in individual jurisdictions. The provisional Charter of Environmental Care for Firewood Merchants (known as the draft Voluntary Code of Practice for Firewood Merchants in the final version of the National Approach to Firewood Collection and Use in Australia endorsed by ANZECC) in Strategy 3 of the revised National Approach is discussed below.
The revised National Approach recognises the need to minimise potential impacts on rural communities where there is a lack of alternative forms of heating. The revised National Approach also recognises that people on low incomes rely heavily on firewood for their heating and on selling firewood for cash income.
To address these issues, the revised National Approach:
- includes an additional Action in Strategy 5 - 'Encourage greater use of waste wood from road widening, urban subdivisions, local council activities and building operations and environmental weeds as firewood'. Encouraging more effective use of waste timber has the potential to provide a source of free or low cost firewood to people who currently rely on collected firewood as their main source of heating.
- clarifies that the intention is not to ban the use or collection of firewood, but rather to move the firewood industry to a more sustainable basis; and
- recommends educational material to advise people how to minimise environmental impacts of using and burning firewood. Tips in brochures include:
- 'Leave some dead wood behind - standing or fallen - it provides habitat for birds and animals - don't deprive them of a home.
- ask your wood merchant whether they can supply a mixed load of hardwoods (eg. more than one type). This will help to reduce the pressure on woodland species that aren't regenerating.
- use plantation timber instead of native forest or woodland timber. This will help conserve declining forests and woodlands.
- if you own a property - try to plant as much as you take. That way you will create your own renewable source of wood;
- recycle - use old fence posts and off-cuts. If you live in an urban area keep an eye out for trees that have been cut down by your council or neighbours and seek their agreement to take it. Once seasoned this is an excellent source of cheap wood.'
Charter of Environmental Care (known as the draft Voluntary Code of Practice for Firewood Merchants in the final version of the National Approach to Firewood Collection and Use in Australia endorsed by ANZECC): Conservation groups claim that a voluntary Code of Practice for Firewood Merchants implemented in the ACT from October 1999 - April 2001 in the ACT put complying firewood merchants at a competitive disadvantage. No evidence was provided to support this claim. Conservation groups also argue that mandatory controls on firewood merchants would best ensure protection for remnant woodlands and their dependant fauna species.
On the basis of comments received during the public consultation period, larger firewood merchants were not opposed to a mandatory code, seeing this as a way of bringing recalcitrant itinerant traders into line and possibly gaining greater market share. However, it is not clear this view is representative of the broader industry.
For the reasons discussed above and concern that moving too quickly to mandatory controls could impose transition costs and burdens on industry without sufficient justification, a voluntary Charter is proposed in the revised National Approach. The provisional Charter of Environmental Care for Firewood Merchants is proposed as a voluntary measure.
Consultation and review measures on the provisional Charter proposed in the revised National Approach have been adopted to address concerns of major stakeholders about a perceived lack of consultation on its preparation and debate about whether it should be voluntary or mandatory. The revised National Approach includes provision for ANZECC to consider mandatory adoption of the Charter after three years, if a review shows the voluntary Charter to be ineffective. The revised National Approach recognises the need for further consultation, especially with the firewood industry, in order to refine the Charter. Amendments to the voluntary, provisional, Charter arising out of public consultation will be reported to the ANZECC meeting in December 2001 and considered for endorsement.
Lack of information to base policy: The revised National Approach recognises that while scientific evidence is not complete, there is sufficient evidence to indicate that firewood collection does present a threat of serious environmental damage. In line with the precautionary principle, the lack of full scientific certainty is not used as a reason for postponing measures to prevent further environmental degradation. Strategy 1 proposes collecting data to help target regional scale approaches. In line with the recommendations of the draft National Approach, the Commonwealth, though the Bushcare and Farm Forestry Programs, is currently funding several projects to address information gaps. A further round of research proposals on firewood will be considered in July.
Increased regulation of firewood collection: discussed above.
Farm forestry/plantations: There was widespread support for promoting multipurpose /firewood plantations in mid-low rainfall areas such as the Murray Darling Basin, however some concern was expressed by landowners and private forest growers about the potential risks for landowners of establishing firewood / multipurpose plantations. These risks included: uncertainty about the status of the Kyoto Protocol and carbon credits, difficulty competing with firewood sourced at little or no cost as a bi-product of land clearing, the potential for firewood demand to reduce with the introduction of alternative forms of heating and the need for a harvest guarantee. Several submissions mentioned the need for incentives to encourage both plantations and sustainable management of native vegetation.
To address these issues, strategy 5 was rewritten to include more extensive discussion of marketing and economic considerations of plantations and to promote the establishment of multipurpose plantations to provide firewood and a range of other environmental services eg combat salinity, sequester carbon and improve biodiversity habitat. These measures also serve to align the revised National Approach more closely with major Government policy initiatives on salinity and water quality and greenhouse gas abatement. The proposed action in Strategy 5 to 'target incentives for conservation and sustainable management of private native vegetation subject to firewood collection' addressees comments concerning the need for incentives.
Sustainable harvest of firewood: There was widespread support for the objective of making the firewood industry more sustainable and a consistent view that more use should be made of waste wood as firewood. Strategy 5 of the revised National Approach includes an additional action 'encourage greater use of waste wood from road widening, urban subdivisions, local council activities and building operations and environmental weeds as firewood'.
Education strategy: There was widespread support for Strategy 2- to educate collectors and consumers of firewood about the impacts of unsustainable firewood collection. Strategy 2 has not been significantly amended in the revised National Approach.
Information base: discussed above.
Utilisation of waste timber after harvesting: discussed above.
Air Quality and health issues: Several submissions expressed concern that the draft National Approach did not adequately address air quality and health issues. Strategy 6 of the revised National Approach was amended to clarify that the purpose is to reduce demand for firewood from woodland species through improving the efficiency of firewood use in woodheaters and facilitating the use of alternative fuel sources, while ensuring that air quality is not compromised. A range of existing Government programs and policies already address air quality and woodsmoke issues.
|Issues||Number of submissions issue mentioned|
|Increased regulation of firewood collection||34|
|Sustainable harvest of firewood||27|
|Utilisation of waste timber after harvesting||18|
|Air quality/health issues||16|
|Code of practice||16|
|Financial impact on consumers||14|
|Firewood harvest as a threatening process||11|
|Fallen dead timber a fire hazard||10|
|Alternative firewood species||7|
|ACT code of practice||6|
|Consumer information for wood heaters||6|
|Retention of natural hollow||6|
|Clearing existing forest.||5|
|Cultural, artistic and social end uses of wood||5|
|Firewood harvest from public land||5|
|Firewood collection mimics natural processes||4|
|Logs have Life||4|
|Full costs of production||3|
|Fallen dead timber a safety hazard||2|
|Firewood cutting in Northern Australia||1|
|Trees as a threat to grassy communities||1|
The proposed National Approach to Firewood Collection and Use in Australia provides State and Territory governments with a range of strategies they can adopt to address the harmful impacts of firewood collection on native woodlands and fauna habitat. While the analysis in this RIS identifies the types of impacts associated with the adoption or adherence to the general approaches suggested, the actual impacts on stakeholders will depend on what elements of the National Approach that are adopted by each of the States and Territories, and how those elements are implemented. If the revised National Approach is endorsed by ANZECC in June 2001, all jurisdictions will be requested to prepare implementation plans to be considered by ANZECC in December 2001. This will provide an opportunity for review of proposed implementation measures by Commonwealth, State and Territory environment Ministers and agencies.
ANZECC will also play an important role in annual reviews of the implementation of the National Approach and any ongoing activities of the ANZECC Firewood Taskforce. The revised National Approach includes provision for ANZECC to consider mandatory adoption of the Charter after three years, if a review shows the voluntary Charter to be ineffective. To coincide with this review, an evaluation to examine the impacts of the National Approach and consider any additional measures to ensure that the objectives of the National Strategy are achieved is proposed for 2004.