An independent observer of the Forest Stewartship Council

FSC Certified operations fast losing credibility in AustraliaTags: Australia, Plantations, Certifier conflict of interest, Corrective Action Requests, Rainforest Alliance SmartWood

This posting has been submitted by Anthony Amis, Friends of the Earth Melbourne, Australia.

In February 2004, Hancock Victorian Plantations received Australia's first FSC certification [certifier: SmartWood]. Many interested parties initially hoped that FSC would deliver on what it promised and we would see a marked improvement in Hancock's forest management practices. Those promises have not eventuated and in many ways Hancock's forest management is getting worse not better.

The Hancock certification involved almost 250,000 hectares of land throughout the State of Victoria, with about 70% being ex state owned plantations previously controlled by Victorian Plantation Corporation which Hancock gained 99 year logging rights from in 1998 and the remaining 30% being land that was controlled and leased by Australian Paper Plantations in Gippsland. Of the 250,000 hectares about 20,000 hectares was hardwood 'plantation', 130,000 hectares being radiata pine and the rest being native forest or custodial land.

The most contentious issues for Hancock were/are pesticide applications, particularly in plantations located in domestic water supply catchments (the rural city of Geelong had their water supply poisoned with hexazinone by Hancock for 18 months between December 2004 and June 2006 - with FSC certification), water quality issues, scale of clearfells, roading, management regimes for the Strzelecki Koala (Victoria's only endemic koala population) and cool temperate rainforest management in the Strzelecki Ranges in South East Victoria.

Initially most people involved in protecting forests in the Strzelecki Ranges, were cautious yet optimistic with FSC and the certifying body wanting to enter Australia for the first time, Smartwood. In the initial scoping, community members basically helped select a very good team including a forester, an ecologist, a soil expert, a social scientist and a roading engineer. Local community members were also interested in seeing if FSC could help bring about a rainforest reserve in the Strzeleckis.

The rainforest reserve known as "The Cores and Links" planned to link up most of the identified cool temperate rainforest in the Strzeleckis. The rainforest and its wet forest eucalypt buffers would total about 9,000ha. Hancock agreed to a two year moratorium of logging the Cores and Links in July 2004 and many thought that the FSC process helped facilitate the moratorium.

Rainforest in Victoria is particularly vulnerable to disturbance. Its biggest threat is fire, which if it occurs will see the rainforest completely wiped out to be succeeded by eucalypt forest. Because of its fragility rainforest is not allowed to be logged in Victoria.

Cool temperate rainforest also suffers from a disease known as Myrtle Wilt, which can enter Beech trees via wounds in the tree. If the disease gets a foothold in rainforest it can wipe out an entire rainforest stand. Rainforest is therefore in an extremely vulnerable position in Victoria. Logging activities in close proximity to rainforest can increase the risk of stirring up Myrtle Wilt spores, increasing the likelihood of disease and can increase risks associated with fire.

In State Forests, rainforest is basically guaranteed rainforest buffers of 60 metres. That is to say logging can occur in Eucalypt forests to within 60 metres of the rainforest ecotone. On private land however, which is what Hancock purchased, there is supposed to be a buffer, but no specific buffer width is specified under the Code of Forest Practice. Rainforest buffers have been at the forefront of forest issues in Victoria for more than 30 years.

The Strzelecki Cool Temperate Rainforest is recovering from past disturbances and is extremely vulnerable. It is located in gullies and drainage lines. In some instances in the past, eucalypt forests were planted next to rainforest leaving no buffer. Hancock is now logging these areas and despite being granted an FSC certificate in 2004, the company decided that their policy would be to leave only 20 metre buffers, usually consisting of Silver Wattle and Mountain Ash.

In the 2004 FSC audit, Smartwood wrote that 40 metre buffers might be inadequate and that these issues are of "importance and urgency". Hancock were requested by Smartwood to get this issue sorted out, via a Corrective Action Request (CAR), by completing a Rainforest Best Management Practice (BMP) plan by 1 March 2005.

By the time the 2005 audit occurred, Hancock had not completed their Rainforest BMP. In the meantime however, they continued to log large amounts of eucalypt buffers in the Morwell River East Branch, a regional site of rainforest significance, leaving only 20 metre 'buffers'. This infuriated conservationists who feared that Hancock were deliberatey stalling the process. The audit team rightfully suggested that a Major CAR be written that would either cease operations in all coupes that are adjacent to rainforest or put in place a minimum of two tree height (100 metre) buffers on all rainforest sites... This suggestion however was over-ridden by Smartwood, who instead granted a CAR giving Hancock more time until the end of 2005 to complete their rainforest BMP.

In the following months Hancock continued leaving 20 metres or less rainforest buffers on Morwell River East Branch and Rytons Junction in the Albert River. They also logged pine plantations leaving no buffers on the extremely rare Strzelecki Warm Temperate Rainforest at Macks Creek. Local campaigners also found Hancock logging inside the Cores and Links Reserve which under that time was supposed to be under a logging moratorium. All of this was done with FSC certification.

In October 2005 a review of the draft Hancock Rainforest BMP occurred by two respected rainforest experts. The fundamental conclusion of the two experts was that buffers in the draft BMP for both cool and warm temperate rainforest are inadequate. Before the the 2006 audit came around, June 2006, Hancock publicly announced their rainforest BMP, by leaving only 20 metre rainforest buffers despite their experts claiming such buffers were inadequate. After the 2006 audit, Smartwood again changed the CAR by granting Hancock another reprieve, in the form of another Major CAR which had to be completed by February 2007.

During this time Hancock continued on their merry way leaving 20 metre buffers (and less) on Smiths Creek, Morwell River East Branch and, worst of all, Morwell River. In June 2006, the State Government of Victoria in the lead up to the State Election decided that a solution to the Strzelecki crisis had to occur. In July 2006, Hancock had also stated that they intended logging College Creek inside the Cores and Links. The two year moratorium had ended.

After several meetings with the community, the government and Hancock, a formal new rainforest reserve was announced in October 2006 via a Heads of Agreement. However, logging was to occur in about 1,500ha of the new 9,000ha reserve due to Hancock having to meet contractual obligations to the Maryvale mill. This logging could take place well away from rainforests, so although the community was not happy , they ended up agreeing as a way to move the negotiations forward.

Hancock supplies the Maryvale mill with 300,000 cubic metres of hardwood per year until the year 2026. Unknown to the community, Hancock also argued that all contract shortfalls caused by not logging eucalpyts inside the Cores and Links (460,000 cubic metres) would have to be made up by logging their custodial land, native forest. This did not reflect the true intentions of the negotations, whereby the community had demanded that any logging within the Cores and Links would have to be reduced from the supposed shortfall, thereby reducing the shortfall significantly. For an FSC certified company to attempt such a 'con' is extemely unethical. The agreement also stated that 60 metre buffers on Morwell River rainforest and 100 meter buffers on Morwell River East Branch would eventuate.

In November 2006, Hancock started logging inside the Cores and Links reserve, starting with coupes in the Morwell River region before a proper process had been formalised. Local conservationists were astounded to see logging within 5 metres of rainforest species, despite being in breach of the recently signed Heads of Agreement. Hancock apparently wanted to make a 'statement' by carrying out the logging in such a manner. Hancock also claimed that because the rainforest hadn't been mapped they had no idea it was there and that the Heads of Agreement maps didn't show rainforest in that particular location. The maps of course were provided by Hancock, without community scrutiny. Is this the way an FSC certifed company should behave?

During the 2007 audit in February by Smartwood, it was made clear to the local community that Smartwood were starting to get rather agitated by the demands of the community in regards to rainforest. During the audit, community members felt that they were being audited and that their position, rasther than Hancock's required to be defended and substantiated. The audit was a most unpleasant experience and marked a new low point in relations between the community and Smartwood. The community is now fed up with FSC and Hancock, and feel that the only way that FSC could retain its credibility would be for Hancock to lose their certification.

To rub salt into our wounds, in July 2006 Smartwood announced that the biggest paper mill in the country, Maryvale (owned by PaperlinX), had received an FSC Chain of Custody Certification. Because about 60% of Maryvale's supply is sourced from Hancock, the mill qualifies for CoC. The environmental community was aghast. For the past 10 years Reflex copy paper had been under a boycott by 27 Australian based environmental NGO's because of its reliance on the native forests of the Central Highlands and Strzelecki Ranges. No environmental NGOs were consulted about this move by Smartwood and now ENGO's are having to face a barrage of television commercials stating that one of their biggest headaches, Reflex Copy Paper is now certified by the FSC. The CoC doesn't even include looking at any of the 600,000 cubic metres per year of native forest that the Maryville mill uses, the source of the ENGO frustration. This scenario is a complete disgrace and will severely undermine FSC's reputation throughout Australia.

Anthony Amis

More details of this case, including many photographic images of the problems outlined above, are avaialble here, and information on the problems with Australia's paper industry can be found here.


If people want more information on what PaperlinX is up to they should also look at this amazing site.


As mentioned in the article FSC has certified Reflex Copy Paper with absolutely no input from ENGO's and no discussion about the native forest sources that feed into the mill that makes Reflex.

There is a different and far more credible perspective to Anthony Amis’ rant against Hancock Victorian Plantations and Smartwood in the above article.

Amis has conducted a long-running personal campaign against Hancock on his Hancock watch web-site, which included years of criticism preceding Hancock becoming the first major Australian plantation company to be certified by the FSC in February 2004. That event alone clearly indicates that the auditors, Smartwood, found at that time that Hancock substantially met the criteria of the certification requirements.

Since then, Hancock has undergone annual audits including in February this year. I understand that complaints against Hancock are a part of this process, but that Hancock has been concerned that FSC/Smartwood have not always followed the agreed protocols for dealing with complaints.

As a complainant, Amis has usually been consulted by Smartwood during these audits.

In comments by Amis in the item ‘FSC back-tracking on pesticides; board gives into industry pressure?’(24/12/2006 archives on this site), Amis made the following statements:

‘Hancock are in a great deal of strife in Victoria with FSC.’
‘Rainforest definition particularly in the Strzlecki Ranges is their major problem’
(11 January 2007)

and again 15 January ‘Hancock are in strife with the FSC’.

It appears that Smartwood do not agree with Amis’ viewpoint. That may be because the Victorian Department of Sustainability and Environment have given ‘Best Management Practice’ status to the way in which Hancock manage the rainforest areas in the Strzleckis.

Amis’ criticisms of Hancock have been consistently and repetitively negative. He has had nothing positive to say about their operations. Thus it is not surprising that when Smartwood do not accept his view, he also attacks them. One obvious conclusion is that Smartwood may be tiring of hearing the same extreme, repetitive complaints.

Amis again uses exaggerated language in calling the Barwon Water episode a’ poisoning’ of the Geelong Water supply. That implies that human and animal health was severely threatened when low-level amounts of hexazinone leached into a stream. That is simply false. Levels of contamination did not exceed guideline values and dilution (from already low levels), natural degradation and standard water treatment eliminated any very slight risk.

For the record, I attended a meeting with Hancock people at their request with Barwon Water shortly after the initial detection. A number of pesticides were discussed, including those used, for example, by potato growers in the same catchment. I had no further involvement after that, but I understand that protocols were amicably decided on between Hancock and Barwon Water to minimise/eliminate any further similar occurrence.

In his comments of the 15th January, Amis averred that he did not provide misleading evidence to a Victorian Civil Administrative Tribunal hearing in January 2006, and states that ‘I wrote hexazinone when I should have stated another herbicide’. He does not name the ‘other herbicide’ he should have named. Why not? His typed submission to that hearing contains the evidence he gave about hexazinone! It is in BLACK AND WHITE - his claim is simply untrue. What I said is correct, and was witnessed by those present.

He also states, in relation to these VCAT hearings, that the ‘deepest pockets win’, implying that the plantation companies use financial muscle to get their own way.

The facts are that individual appellant fees for VCAT hearings are around $A50, deliberately set low to allow individuals and groups to mount appeals against (usually) different planning bodies.

The major costs are borne by the Victorian Government in providing VCAT (that is, taxpayers) and the planning bodies. For example, in the 3 cases in the south-west of Victoria (all resolved on merit in favour of the respective plantation companies), local government planning bodies picked up the cost of providing advocates and staff to attend these hearings (that is, ratepayers!). So far as the expert witnesses engaged by the plantation companies are concerned, costs pale in comparison to these taxpayer/ratepayer costs.

Appellant claims were often either trivial or vexatious. In the aforementioned cases, for example, one appellant stated that she would rather look at cows than trees (trivial). Another stated that ‘all the chemicals that the company would be using were known carcinogens’ (vexatious - the chemicals were not named and no evidence was provided). Expert witnesses engaged by the companies, including myself, have to answer claims like the latter.

If the appellants had mounted credible cases, the outcomes could have been different. Clearly, they were not able to find credible expert witnesses (including Amis).

I have made my criticisms of the FSC in regard to chemicals plain in the December comments, and I do not regard FSC as having much credibility.

Amis’ attack on the credibility of Smartwood/FSC would only have merit if his own credibility was not so obviously quite questionable.

Thank you,

Barry Tomkins


You do not do yourself credit by simply attacking Anthony Amis, rather than dealing with any of the serious issues he raises.

In his posting, he has presented a well-supported case, which cannot be described as a 'rant' (though possibly your response to it could be). The fact that he has long been a campaigner on these issues does not in itself discredit him - by that logic, one could also say that you are discredited by long being a campaigner against Anthony Amis! The moderators of FSC-Watch ask that you keep your comments to the issues raised in the posting, rather than using it as a platform for personal attacks.

Also, the fact that Hancock has been certified by SmartWood does not in itself count for very much. SmartWood has been challengned on a number of its FSC certificates, and eventually a number of them have had to be withdrawn, because it has been shown that the certified company was simply not compliant with the FSC's requirements.

If you ask SmartWood or the FSC for information on such previous cases, I am sure they will be able to provide it.



Your latest lunge at me fails to address concerns about rainforest buffers that Hancock is leaving on cool temperate rainforest in the Strzelecki Ranges. Could you please explain the following comment;

"In October 2005 a review of the draft Hancock Rainforest BMP occurred by two respected rainforest experts. The fundamental conclusion of the two experts was that buffers in the draft BMP for both cool and warm temperate rainforest are inadequate."

The experts wrote; "When a strict requirement for a precautionary approach is invoked, we consider buffer widths proposed in the BMP to be plainly inappropriate."

Why should FSC continue to endorse a company that is granting rainforest buffers that are not scientifically defensible?

As you also know atrazine has received a bad rap from people, particularly in Tasmania where overspray has been reported.

In a letter to the Sunday Age 17/12/04, you wrote;

"The alleged spraying of a Tasmanian farm with a "potentially harmful carcinogenic herbicide" by Gunns did not happen, proven by flight lines from the helicopter's records and the absence of vegetative death on the ground outside the area of the sprayed plantation.

"Atrazine, the herbicide used on surrounding plantations, is not a human carcinogen and after 40 years of use and extensive scientific studies has only been shown to be related to a particular cancer in human rats. The mechanism has been determined and cannot occur in humans".

Could you also share with readers your thoughts on this impressive website: http://atrazinelovers.com/
I am also particularly interested in your opinions on atrazine and endocrine disruption and its ecological impacts.

best wishes


I have only a few comments. Firstly, why doesn't Anthony Amis state who the two respected rainforest experts were? What is their affiliation? Who commissioned their report? An ENGO? Hancock? Govt? An independent consultancy group? These are basic questions, that perhaps should be asked by the (annonymous - I find that cowardly) fsc-watch writer.

I pointed out that the DSE BMP status indicated a different conclusion as to the management of rainforest by Hancock. I don't claim expertise in that area so did not comment further. Amis presumably knew of the DSE status - why not include it? It is no debate if only one side of an argument is presented. I will leave others with the necessary expertise to argue about rainforest buffers if they wish.

As to atrazine - I have pointed out time and again that forestry use of atrazine in Australia is minimal. The major use is in triazine-tolerant canola and sorghum. In the report written by Braden Jenkin and myself for the Forest & Wood Products R&D Corporation last year, we gave figures for the use of atrazine in Western Australia in 2004. Canola use was in excess of 600 tonnes, compared to forestry plantation use of about 7 tonnes. The data is fully referenced. A similar situation occurs in western Victoria where there are large areas of canola annually. The canola areas are sprayed, and there are numbers of streams crossing these areas. Much of the forestry use is as a dry granular product which releases atrazine slowly with rainfall.

I have also been over the claims of carcinogenicity and endocrine disruption in my expert witness statement in January last year, and elsewhere, as Amis well knows. The only evidence for carcinogenicity is from high doses fed to female Sprague-Dawley rats, some of which develop a specific mammarian cancer. The mechanism cannot occur in humans because we are physiologically quite different.

I have also pointed out that there is ongoing research into the claims of endocrine disruption. If or when these claims are substantiated, the responsible authorities will no doubt act. My own field based research is directed at developing alternative chemicals with a number of preferences, such as lower use rates, minimal non-target effects, low environmental and mammalian toxicity, preferably solid products for OH&S reasons etc. In one comment from the December 24th article, Amis correctly noted that such research is of necessity protracted. It also result in failures.

Let me illustrate. The chemical azafenidin was (and remains) the most effective herbicide of the many that I have put into trials. Its use rate was low. It was registered in 13 countries and a product was in the process of registration in Australia for sugar cane when the chemical company withdrew it globally, because the US EPA found a human health problem with a secondary metabolite (that is, a breakdown chemical of a breakdown chemical). Result - 4 years of research discarded. Fair enough too. It is now on the superseded list in the Pesticide Manual (British Crop Protection Council).

Another chemical - low use rate (100g/ha), very low toxicity, very specific target weeds, will not progress unless there are other much larger markets developed (unlikely). The forestry market here on its own is not large enough to support individual chemicals (fact).

No further comments from me.

Thank you,
Barry Tomkins

Barry, now your labelling me as a coward!!! In terms of rainforest, Hancock commissioned the report and the experts name can be found at the following website address via their executive summary. http://www.hancock.forests.org.au/docs/rainforest.htm#PROPOSED

If you can't be bothered looking up the site, the experts who did the report were David Cameron (Threatened Species and Communities Program, Department of Sustainability and Environment) and Terry Walsh (Centre for Excellence in Natural Resource Management, University of Western Australia). David Cameron is regarded by many as the leading expert in this field.

The DSE did sign off on a Strzelecki Rainforest BMP last year. The fellow who signed the document, was the ex Secretary of DSE and was certainly not a rainforest ecologist, more like a timber industry apologist. This is typical behaviour of a Senior Department Bureacracy that has for years suppressed and deliberately undermined rainforest definitions in Victoria.

The recommendations made in the Hancock commissioned peer review were not taken on board by Neilson, who probably signed off after being lobbied by Hancock, who were desperate for any kind of support to counter the arguments put forward by the community and FSC. It hasn't worked and has ultimately failed as it appears to be just another ruse so that Hancock doesn't have to implement the recommendations of the Cameron and Walsh report. More unethical behaviour by an FSC certified company and if Smartwood accept this sort of behaviour then their reputation will also suffer the consequences.

One could suggest that because Hancock pay Smartwood, Smartwood will be very reluctant to drop the certificate because it will impact on their bottom line. This economic situation has increased after the Maryvale FSC CoC by awarded by Smartwood. If Hancock lose their FSC certification, this will also mean that the Maryvale CoC will have to go because Hancock supply Maryvale. Smartwood would then lose two contracts and double their financial losses. This lack of independence and accountability is the real failing of the FSC system and it will tear FSC's credibility apart.

In terms of the website; http://atrazinelovers.com/ you haven't made any specific comments. I think I'll trust the judgement of the author of the website, Tyrone Hayes, rather than your industry biased bleatings.

best wishes


No, Anthony, I am not labelling you as a coward. That comment was directed at the person who signed off as FSC-watch above - I thought I made that clear.

For the record, Tyrone B. Hayes' research was discredited early on. I've been over that before.

We agree on two things - that research in the chemicals area is a slow process, and that the FSC lacks credibility, if for different reasons.

NO further comment.

Barry Tomkins

dear sir,
please see http://www.iceh.org/pdfs/SBLF/HayesBioscience.pdf. and then please explain to everyone how my laboratory's work (peer-reviewed in nature, pnas, ehp) was "discredited" by a group of industry-funded scientists, who in their first paper (Carr et al.) produced the same results we did, and in subsequent publications featured studies where 87% of their animals died and/or their controls were contaminated with atrazine.
thank you

Not only has Barry Tomkins so far refused on this website,to explain his claims that "Tyrone B. Hayes' research was discredited early on", in an expert witness statement presented by Mr Tomkins to the Victorian Civil and Administrative Tribunal in January 2006 on behalf of the plantation companies Great Southern Managers and Timbercorp, Tomkins stated; "Claims that atrazine (and by association simazine) causes hermaphrodism in frogs and fish are very doubtful." and "... the general consensus seems to be that environmental levels of atrazine are unlikely to be a cause of frog hermaphrodism."

Furthermore in a letter dated 31/5/05 to the Gellibrand River Clean Water Network Mr Tomkins stated; "Claims that atrazine, and by association other triazines such as simazine, cause hermaphrodism in frogs and fish have been discredited...The other scientists on the panel were disturbed by both the methodology and by the conclusions Hayes made, and insisted that the work be repeated. Hayes spat the dummy and left the panel. Subsequently his work has not been able to be repeated..."

Note that Hayes' Bioscience article "There Is No Denying This: Defusing the Confusion about Atrazine" was published in December 2004 a full year before Tomkins wrote his Expert Witness Statement and 6 months before he sent his signed letter on behalf of Midway Plantations to the Gellibrand group. As mentioned previously, Tomkins has also been active writing to newspapers in Australia countering community concerns about herbicides, in particular Atrazine.

Either Mr Tomkins was unaware of Hayes' Bioscience article or he deliberately has chosen not to raise it to members of the public and in front of the Victorian Civil and Administrative Tribunal. This suggests to me that Mr Tomkins is not in a position to be making expert claims about the impacts of Atrazine on frog hermaphrodism and one has to question his agenda.

The other point to raise in this forum is, despite the work done by Hayes and others pointing to the dangers of Atrazine, why is Atrazine still allowed to be used under the FSC system?



I had not intended to answer the latest (11 April) comments of Mr Amis. However, since a link to his comments appears on at least one other site, and he once again misrepresents my position, I will list some incontrovertible facts about the atrazine issue.

Firstly, atrazine is not used by the FSC- certified companies in Australia, including Timbercorp, Integrated Tree Cropping (ITC), Albany Plantation Forestry Co, or Hancock Victorian Plantations. The first three are Blue Gum companies and Hancock is mainly Radiata pine.

Hence so far as the FSC is concerned, there is no atrazine ‘issue’ here.

Many of the Blue Gum growers use simazine.
Timbercorp has a derogation from the FSC for simazine use.
ITC does not use simazine, and has not sought a derogation to the best of my knowledge.

Some non-FSC certified pine growers use atrazine – but not any of the Blue Gum growers.

Simazine is more soil fast than atrazine.

The report by Braden Jenkin and myself* demonstrated that the average use rate of simazine for weed control in eucalypts (including Blue Gum and Shining Gum) was 0.7 of the registered, maximum allowed use rate. This is because applications are either at a reduced rate or are applied only on a strip (planting row) basis. (*The use of chemical pesticides by the Australian plantation forest industry, September 2006, 183 pp. including appendices, found on www.fwprdc.org.au).

(Mr Amis to this date, has not acknowledged or made any comment regarding that report).

Simazine is only used in the first two years of eucalypt establishment, and not at all in the remaining 8 to 10 years of the rotation.

The main use for atrazine in Australia is for weed control in the growing of triazine-tolerant (TT) canola, with lesser similar use in sorghum. In the above report, Executive Summary page 7, we stated:

‘For canola cropping in Western Australia, it (atrazine) may be applied twice per crop at 1.0 kg a.i./ha. For 2005, the industry survey showed that the W.A. plantation industry used 7,444 kg a.i. of atrazine (7.444 tonnes). The W.A. canola industry for 2003-04 produced 318,002 ha of crops, to which an estimated 636,000 kg a.i. of atrazine (636 tonnes) may have been applied or greater than 80 times the amount used by the plantation forest industry in W.A.’

This information was thoroughly cross-referenced. The Canola Association of Australia Inc. states on their web page (www.canolaaustralia.com) that it

· Held the permit for the use of triazine herbicides on TT canola until registration was achieved and then assisted in the development of stewardship protocols.

In the USA, the estimated annual atrazine use is about 80 million pounds (approx. 35,000 tonnes) in corn and soybean primarily.

I stand by my comments regarding Tyrone B Hayes. The story is found by googling him – see ‘The Story of Syngenta & Tyrone Hayes at UC Berkeley: The Price of ---.

This lengthy article makes it quite clear that there were questions raised about his methodolgy, statistics included and conclusions. I stated in my earlier comments “For the record, Tyrone B. Hayes' research was discredited early on.’

I have also stated previously that there is ongoing research. Should that research eventually demonstrate conclusively that there is an environmental problem arising from the use of atrazine, the US EPA will be the initiator of any action. At this time neither the EPA nor the Australian Pesticides and Veterinary Medicines Authority find any conclusive evidence, for a chemical that has been in use for close to 50 years. Given that length of time, there should be a reasonable expectation that such a problem would have become apparent.

Mr Amis (above) says above regarding my expert witness statement at the January 2006 VCAT hearing:

‘This suggests to me that Mr Tomkins is not in a position to be making expert claims about the impacts of Atrazine on frog hermaphrodism and one has to question his agenda.??The other point to raise in this forum is, despite the work done by Hayes and others pointing to the dangers of Atrazine, why is Atrazine still allowed to be used under the FSC system??’

What the FSC situation will be after the present FSC review by the ‘Pesticides Expert Panel’ remains to be seen, but because the Australian FSC-certified companies do not use atrazine, Mr Amis’ question is irrelevant to Australia.

If I am ‘not in a position to be making expert claims etc’ then neither is Mr Amis! What hypocrisy - as an advisor to the objectors or as an ‘expert witness’ he has not been able to provide substantive evidence, and all three hearings have been decided in favour of the plantation companies. He appeared at the hearing referred to as an ‘expert witness’ and claims were made by objectors about atrazine, The objectors started at that hearing with the advantage that the local government body had refused a permit for parts of the sites; the plantation companies appealed successfully against that refusal.

Since atrazine was not one of the chemicals to be used in those proposed Blue Gum plantations, those claims were also irrelevant. In fact, the issue of herbicide use was found to be irrelevant because it did not constitute ‘works’ as defined under the State Government Act. I don’t have a problem with that, but Mr Amis clearly does.

The only ‘agenda’ I am running is to put forward factual information, and to refute the scaremongering and misinformation from Mr Amis and others.

The following is the extract of the relevant material from my expert witness statement (some 46 pages) at the VCAT hearing in January 2006. The two companies were the FSC-certified Timbercorp and another not FSC-certified that does not need to be named. I have also deleted the names of two people whose identification here would serve no useful purpose. Note again that Timbercorp has an FSC derogation to use simazine.

Start of extract
“Claims that atrazine (and by association simazine) causes hermaphrodism in frogs and fish are very doubtful. The claims were originally made by an American scientist, Professor Tyrone B. Hayes. The background to this claim is instructive. Professor Hayes was invited to be part of a panel of expert scientists, established by Syngenta Crop Protection to examine claims made about atrazine. He submitted a paper claiming research that he had carried out demonstrated an hermaphroditic effect in frogs. The other scientists on the panel were disturbed by both the methodology and by the conclusions Professor Hayes made, and insisted that the work be repeated. Professor Hayes demurred and left the panel. Subsequently his work has not been able to be repeated.

However, Dr (name deleted) at the APVMA has informed me that whilst the weight of evidence is against the Hayes claims, there is ongoing research, and he provided me with 6 papers relating to the claims. The conclusions are technical and indicate differences between frog species, but the general consensus seems to be that environmental levels of atrazine are unlikely to be a cause of frog hermaphrodism.

d) Simazine (and atrazine) has been in use for some 40 years. In fact, it is registered in Western Australia for use as an algicide in dams, tanks and troughs, and it has been used in swimming pools in other countries.

Atrazine is the major herbicide used for weed control in the growing of corn and sorghum in the USA. It has been largely but not completely proscribed in the European Union, even though a pan-European expert committee recommended that the prohibition be removed. I understand that this recommendation has never been adopted by the European Union for political reasons, and because of the public perception created by environmental non-government organizations (ENGO’s), and due to the possibility of human carcinogenicity prior to 1999*. The replacement herbicide in the EU is another triazine, terbuthylazine with the same mode of action (the inhibition of photosynthesis).

[*Note added, not part of extract: In 1999, the International Agency for Research on Cancer downgraded the triazines from class 2B, possible human carcinogen, to class 3, not classifiable as to human carcinogenicity (see IARC site, monographs vol 73)].

e) Whilst the following relates to atrazine rather than simazine, it is relevant particularly in regard to the acknowledgement given to the forestry sector’s knowledge of relevant legislation and compliance.

The Department of Primary Industry (Chemical Standards Branch) conducted surveys into atrazine use in Victoria from 2001 to 2003.

The following is part of a letter dated 10th March 2005 sent to me when I requested the forestry survey. I cannot quote from the survey without written permission, but I can quote from the accompanying letter, written by Mr (name deleted) at the Arthur Rylah Institute, Brown Street, Heidelberg 3084.

‘The Chemical Standards Branch of DPI in Victoria conducted surveys into the Forestry, Pasture seed and Triazine Tolerant Industries during 2001, 2002 and 2003. The aims of the surveys were to demonstrate that users of atrazine based chemical products in Victoria can manage potential chemical risks effectively as outlined in the recommendations from the APVMA review* on atrazine, and to establish a benchmark on the level of knowledge and adherence to legislative requirements by atrazine users in Victoria.

Results from the survey have revealed that the level of overall professionalism is a reasonable indicator of awareness of environmental concerns relating to atrazine use, adherence to label directions and legislative requirements for chemical use across Victoria.

The industry sector that was able to demonstrate the highest degree of knowledge regarding atrazine use and compliance with relevant legislation was the forestry industry. The survey revealed a high level of awareness of the Industry Code of Practice and the implementation of documented quality assurance programs such as ISO 9002 & 14000’. End].

The APVMA reviewed* atrazine extensively. This involved reviewing about 500 peer reviewed papers and other authoritative literature. Their conclusion was that there were no major identifiable health risks associated with the label compliance requirements. The review is found on their web-site (www.apvma.gov.au).” End of extract.

Mr Amis should be more careful about quoting other peoples’ material selectively.

Thank you – there will be no more from me, even if Mr Amis wants to have the last word, as usual.

Dr Barry Tomkins

Atrazine is probably the second most controversial herbicide used in Australian plantations. The most controversial was probably the widespread use of 2,4,5-T during the sixties and seventies. For instance 2,4,5-T mixed with diesel was aerially sprayed throughout Victorian state owned pine plantations between 1968 and 1978. One can only wonder at the widespread health and ecological concerns with the application of dioxin tainted 2,4,5-T on a myriad of land uses including plantations throughout the continent. Various governments around the country gradually came to their senses about the dangers of using 2,4,5-T. With atrazine, however the message is taking a little longer to filter through, particularly to users of the herbicide, who have a vested interest in its continued use.

Atrazine may not be used in Australia by FSC certified companies,
but that doesn't mean that it can't be used. Companies still using
Atrazine may wish to be certified by FSC and FSC would probably
welcome them on board. Atrazine is not a prohibited chemical under
the FSC system and Australian plantation companies have a history of
misusing the herbicide. It could be argued that forestry interests have only stopped using Atrazine only after significant problems have occurred which have impacted on the public relations image of the particular government or company concerned. When Syngenta wanted to discontinue registration of Atrazine for a number of uses including forestry in the early nineties, the move was opposed by public and private forestry interests in Australia. Meanwhile incidents including overspray and pollution of drinking water which have put innocent parties (ie the public and environment)at risk, have continued.

The widespread use of atrazine in canola crops is a very serious issue, however the location of most canola crops, particularly in Victoria means that such atrazine applications are not occurring in domestic water supplies, but rather in catchments supplying non-potable water. This does not mean that Canola based Atrazine applications are not having an ecological impact on species such as frogs, but the controversy about pollution of domestic water supplies can be sidestepped by the canola industry, while poorly located plantations in domestic water supplies will continue to dog the plantation industry, even if Atrazine is not used. Therefore it is the location of the plantations that is a major factor in the plantation industry continuing to suffer a poor corporate reputation.

Poorly sited and managed plantations will inherently cause more attention and problems than those that are sited in less controversial locations. Generally speaking in Victoria (not Tasmania), the newer bluegum plantations have tended to be located outside domestic water supplies, whereas a large percentage of older pine plantations are located within domestic water supplies. It is true that FSC companies operating in Victoria do not use Atrazine, but Simazine and Hexazinone are of concern particularly in domestic water supplies where FSC and non FSC companies operate. Upper catchments are targeted by tree growers because of better rainfall.

Controversy about the use of Atrazine in plantations continued throughout the 1990’s, particularly in the communities of Lorinna and Derby in northern Tasmania after spraying by Forestry Tasmania. The contamination of Derby's water supply in 1994 was a particularly damaging incident in regards to Atrazine's image in Tasmania and as a result Forestry Tasmania stopped using Atrazine in 1995. Private forestry interests however continued to use Atrazine in Tasmania. As late as 2004 residents in Tasmania reported water contamination from Atrazine by timber giant Gunns Ltd and Simazine was detected in Tasmanian water supplies in 2005. Atrazine and Hexazinone were also detected in two Tasmanian streams as late as March 2007.

Another major PR disaster for Atrazine and plantations was the leaching of Atrazine and Hexazinone into the Warren Reservoir in Adelaide after spraying in pine plantations by Forestry South Australia in 1997. The public was not informed about this incident until September 1998, with Atrazine being detected throughout the year. Diluted amounts of Atrazine had leached from Warren Reservoir into the Barossa and Little Para Reservoir's which supply drinking water to approximately 50,000 people in Adelaide. Atrazine levels of 150ug/L were recorded in streams feeding into the Warren Reservoir!
Because of this debacle, which was big news in Adelaide, Forestry South Australia ceased using Atrazine.

Atrazine use in plantations in South Eastern New South Wales has
also raised concerns with the Canberra Times reporting a land owner stating in 2004; "Atrazine has contaminated most of the rivers and streams that flow into the Snowy. We have seen massive fish kills and in some cases, everything in the river has died,". The second mostly commonly detected pesticide in northern and central New South Wales rivers and streams was Atrazine, a herbicide commonly used in canola, sorghum and sugar cane cultivation, fruit orchards and in forestry. Atrazine has also been detected in groundwater at locations throughout Australia and been reported recently draining from agricultural activities in northern Victoria.

Plantation interests have rightfully deserved to be criticised about their use of Atrazine and other pesticides, however agricultural interests also need to significantly improve their on ground application of pesticides, particularly in sensitive locations. There is no argument that agricultural interests use far more pesticides than forestry interests in Australia, however the forest industry has not been an innocent party in this debate. The fact that the forest industry have received a disproportionate amount of criticism in regards to their pesticide operations in comparison to agriculture, is sign enough that something is not quite right with the plantation industry in this country.

Once again I have hesitated in pointing out the misinformation provided in Mr Amis’ latest comments, because I don’t want to waste my time and I have twice tried to close off further comment. Mr Amis insists on having the last word, but at least concedes that atrazine is not used by the Australian FSC-certified plantation companies. (I don’t suscribe to there being an ‘issue’ with atrazine – see above).

Mr Amis states:

‘The widespread use of atrazine in canola crops is a very serious issue, however the location of most canola crops, particularly in Victoria means that such atrazine applications are not occurring in domestic water supplies, but rather in catchments supplying non-potable water. This does not mean that Canola based Atrazine applications are not having an ecological impact on species such as frogs, but the controversy about pollution of domestic water supplies can be sidestepped by the canola industry--’.

Where, then, do the numbers of small towns across the Western District of Victoria, where there are tens of thousands of hectares of canola grown annually, get their potable water? These towns were established in the 19th century where there was permanent water! Because of the 10 year drought, some may be augmenting their supply with bores, but they still rely on stream diversion into storage basins for their reticulated water supplies (streams such as the Woady Yallock, Mt Emu & Fiery Creeks, the Hopkins, Surrey, Glenelg and Wannon rivers etc). If they do use bore water, is there then not an issue in Mr Amis’ mind about the possible leaching of atrazine into groundwater?

Mt Amis previously asserted in his above comments that atrazine use is a major issue because of claimed hermaphrodism in frogs and endocrine disruption. Consider the following:

About 1 million hectares of canola are grown annually in Australia. Label use rates for atrazine in canola are 0.5 to 1 kg a.i./ha (a.i. = active ingredient) at planting and 1 to 2 kg a.i./ha about 6 weeks after planting. On the sandy soils in Western Australia rates are usually 1 kg + 1kg a.i./ha in the 2 applications. Rates of the second application may be higher on heavier textured soils in Victoria and elsewhere.

Thus at least 2,000 tonnes a.i. of atrazine is applied annually in the growing of canola.

The estimated plantation use – based on industry surveys and modeling, is about 30 - 35 tonnes p.a. Total Australian use is possibly about 3,000 tonnes including use in canola, sorghum, sugar cane and other lesser uses.

Forestry plantation use of atrazine is thus about 1% of the total, in line with the data in the report by Braden Jenkin and myself referred to earlier (www.fwprdc.org.au) that showed plantation use of all forestry pesticides to be 0.7% of the total Australian market regulated by the APVMA. Even if we exclude the animal health products (which includes licicides, nematicides, miticides and flukacides) and only take into account the broadacre, horticultural, environmental, industrial and domestic pesticide total, plantations still only account for about 1% of the annual expenditure on pesticides. The FSC certified area is about 600,000 ha of Australia’s plantation area of 1.817 million ha (latest National Plantation Inventory data, see www.nafi.com.au).

That is the appropriate perspective – pesticide expenditure in FSC-certified plantations is about 0.23% of the Australian market including animal health products or 0.33% of the market excluding that.

The pine plantation area is 1 million ha, predominantly Radiata pine but it includes an increasing area of Maritime pine being grown on an 80 year rotation on drier sites in Western Australia and New South Wales, and tropical pines (eg Slash pine) grown, like Radiata pine, on about a 30 year rotation in Queensland.

Thus about 30,000 ha is harvested (for a sawlog final crop) and re-established annually. This is distributed across vast areas including the SW of Western Australia, the SE of South Australia and SW of Victoria, the Otway and Strzlecki Ranges in the SW and SE of Victoria respectively, the Central Highlands and NE of Victoria, Tasmania, the Southern Tablelands, Green Hills and Oberon areas of NSW, the Australian Capital Territory, and the tropical pines of Queensland.

In any one area, therefore, only a few hundred to a few thousand ha are being harvested and re-established annually. The same pattern is emerging with the Blue Gum/eucalypt plantations still being established and which are just beginning to be harvested (on 10-15 year rotations). Atrazine is usually not used on the second or later rotation pine sites unless there is an absence of woody weed, and there are no routine herbicide/pesticide applications after the first two years of the establishment phase. Thus for about 28 years in Radiata pine and about 8-12 years in eucalypt, there are no routine pesticide treatments. Treatments are only on an as needed basis. For example, our report showed that insecticide expenditure into plantations was just 1% of the total plantation pesticide expenditure!

As I have said previously, why does the FSC bother about chemical and fertilizer use in plantations? Such use is trivial, and in this country highly regulated. I believe the same is true in the other CANZUS countries where some 50 plus different organizations have taken issue with the FSC over its chemicals policy and chemicals use criteria. The FSC has still not acknowledged or provided any information on its web-site about the latest review by the Pesticides Expert Panel; the last entries under Pesticides Review are dated Deecmber 2005.

Thank you.

Dr Barry Tomkins

Barry’s latest contribution is a mighty weak attempt to smokescreen plantation companies from due scrutiny over their use and misuse of pesticides.

His comments about the source of drinking water in south west Victoria are appalling in their inaccuracies and attempt to foist all blame on farmers growing canola.

Approximately 120,000 people live in south west Victoria (if you exclude the city of Ballarat).The majority of people living in the south west source their drinking water from a few main sources.

By far the largest source of drinking water for 50,000 people, is the Otway Ranges. Approximately 40,000 people are serviced by the Gellibrand River in the Otways. There are no canola crops in the Gellibrand but there are several thousand hectares of plantations, owned mainly by Midways. Midway has provoked controversy over their plantation management including the use of pesticides such as Simazine. FSC certified company, Hancock Victorian Plantations only have a couple of hundred hectares in the Gellibrand catchment. The town of Colac, 10,000 people, also sources water from a closed catchment in the Gellibrand catchment above Olongolah Reservoir. Therefore about 33% of residents in the south west source drinking water where plantations are a major issue in terms of water quality. See map;

The second largest source of drinking water are the deep confined aquifers, such as the Dilwyn, which supply about 14,000 people (more if you include Portland District) with drinking water to towns such as Portland and Heywood. The Dilwyn recharges near the lower Glenelg and Crawford Rivers. Most of these recharge areas are native forest and a small portion of the recharge areas have plantations on them.

Headwater streams flowing from the Grampians National Park also supply a number of towns, most notably Hamilton (9000 people) with drinking water. Even small towns in proximity to canola cropping such as Willaura (300 people) and Lake Bolac (230 people) source their drinking water from a small forested catchment flowing from the Grampians, Masons Creek. No canola grown in the upper Masons creek either.

Konong Wootong Reservoir catchment supplies drinking water to Casterton and Coleraine (3000 people). Its catchment is largely grazing, not canola cropping. Larger centres such as Ararat (7000 people) and Beaufort (1000 people) source their drinking water from forested catchments near Mount Cole, Langhi Ghiran etc. No canola in those water supplies either.

Numerous towns such as Cobden and Timboon are located away from canola country and smaller towns such as Mortlake, Penshurt, Koriot may rely on groundwater whose small recharge areas are also unlikely to be impacted by canola.

I estimate about <5% (probably much less) of the population of the south west may possibly source their drinking water from sources impacted by canola. These may be very small communities or isolated houses who may pump directly from streams with canola growing in close proximity or upstream. However 33% of the regions population have plantations located in their drinking water catchment ie the Otway Ranges. Canola’s real threat to humans will be through spray drift, possibly getting into house tank or well water.

That being said the canola industry cannot claim to be sustainable when they use very high amounts of dangerous pesticides, including atrazine, which has the ability at very low doses 0.1ppb to turn on enzymes (aromastase), which converts testosterone into estrogen in frogs, chemically castrating exposed male frogs. These frog hormones are chemically identical to human hormones meaning that humans may also be affected at equally low doses. Atrazine needs to be banned now. If it’s so safe perhaps Barry can inform us why Atrazine has been banned in Europe and why the plantation industry in Australia has kept supporting its use?

Nothing that Mr Amis has to say above has anything at all to do with the FSC. Midway are not FSC-certified (AFS/PEFC instead). He does not dispute the atrazine use by the canola industry, but the numbers I gave at least forced a retreat from the apologist line he was taking on atrazine use in canola. As to Europe's banning of atrazine, I have noted before that the replacement herbicide in Europe is another triazine, terbuthylazine, the preferred triazine used by the New Zealand plantation forest industry.

If there was any proof that the ue of atrazine is environmentally harmful and harmful to human health in the way alleged by Mr Amis, it is far more likely to be found particularly in the corn and soybean growing areas of the US, where it has been in use for nigh on 50 years, and the canola areas in Australia (not just western Victoria), than in the pine plantation areas here.

Mr Amis neither disputes nor acknowledges the US EPA or the APVMA reviews of atrazine that I have noted previously. When, or in the unlikely event if, those bodies conclude differently, it will be on the basis of conclusive, comprehensive evidence, not on the scare tactics of Mr Amis or others.

Mr Amis does not dispute my numbers for atrazine use in plantations in Australia, nor in canola use, nor of the percentage of Australian pesticide expenditure that goes into plantations. He does not acknowledge nor criticize the report by Braden Jenkin and myself, that puts a proper perspective on the plantation industry development here, and makes many comparisons with other agricultural pursuits.

This debate is getting tiresome. I will leave Mr Amis to his tunnel vision.


The glaring hole in the study of forestry pesticides that you and Braden did last year on behalf of the FWPRDC, was the use of regional usage patterns. This diluted the real impact of plantations which are often located in upper catchments, including domestic water supply catchments. It is the location of plantations which is one of the main reason why the plantation industry often cops a bagging in the media and it is this reason why Hancock and FSC have also been placed under criticism by myself and others. By casting such a wide brush, the intricacies of catchment based plantation locations was totally avoided in your FWPRDC report. Was this a deliberate oversight?

If a truer picture of plantation pesticides in Australia (including plantations certified by FSC)was to be undertaken, the Regional Usage Patterns you used would need to be replaced with Catchment Usage Patterns, with specific emphasis on where water supply offtakes are located in those catchments. (Groundwater usage patterns could also be included).

You could also compare impacts of plantation pesticides and agricultural pesticides downstream of water supply offtakes and upstream of water supply offtakes.

This would be an interesting comparison and would give a totally different picture to the one you reported in the FWPRDC report. As I pointed out yesterday, 33% of people living in the south west of Victoria are impacted by plantations in their water supply catchments, with probably much less than 5% impacted by canola in their drinking water supplies. The image you tried to portray was not an accurate one and only attempted to deliberately cloud this fact. This does your credibility no favours.

The issue of plantation locations in regard to water supplies in Tasmania would be even more 'entertaining'. In many catchments you may find that the largest user of pesticides would be the plantation industry, not the agricultural industry.

I'm know that in some water supply catchments agricultural practices will be the major concern, but it is my contention that the plantation industry would also be a much bigger player in water supply catchments, than many people realise, particularly the older plantations established prior to 1990. This in turn has ramifications for FSC as they have already certified Hancock's operations in Victoria. A very large % of Hancock's plantations lie in domestic water supplies a fact that Friends of the Earth has been concerned with for some years.

In terms of tunnel vision, I think you need to have a look in the mirror.

Mr Amis always avoids the 'bottom line'. That, simply, is that there is NO EVIDENCE of short or long term effects on mammalian (including human) or environmental health of the use of pesticides in plantations. The chemicals biodegrade within a few days to months to a year; as I noted the areas harvested and re-established annually are small within any single area (and small in relation to catchment areas); the toxicology data is well researched for all of the chemicals used; they have been adapted from other agricultural uses; the expenditure in Australia for plantation pesticides is $A18 +/_ 3 million p.a. of a total Australian expenditure of $A2.4-2.5 billion p.a. or 0.7%, and new plantations are almost all on ex-agricultural land (which may have received previous pesticide and fertilizer applications). The FSC component is as I noted earlier.

As to the methodology of the Jenkin/Tomkins report, Mr Amis betrays his lack of comprehension of business. Companies are entitled to retain confidential information; we avoided any possible conflict by zoning and amalgamating information. The result was that we captured information covering 92% of the plantation area established in 2003-04, all on a voluntary basis.

Plantations account for 1% of the intensively managed land in Australia (see Summary report, www.fwprdc.org.au) (and much less if pastoral rangeland is included). The FSC component is about 0.3%.

The other aspect that should be noted is that development of plantations plays a role in the sequestration of carbon - a very topical subject.

Final comment; there is nothing to 'solve' in this pointless continuation.

We should await with interest the FSC's approach to the Pesticides Expert Panel report.


Barry Tomkins

Mr Barry Tomkins claims "the toxicology data is well researched for all of the chemicals used.."

Not so at all. I have been following the issue of pesticide toxicology and contamination of water (in particular) for some time now. See the archives at:

The pesticide industry is notorious for its unreliable, even deliberately skewed testing procedures when it comes to the environmental fate and toxicology of these chemicals. Look at the history of atrazine. Industry funded research involved contaminating both test subjects and 'control' subjects to the same chemical. This happened also with studies on agent orange.

With respect to Roundup and Glyphosate see:

Here's an extract"

"So what can we conclude from the concentration data presented by Thompson et al. (2006)? First, the data selected by Thompson et al. (2006) includes several studies that have unknown sampling details and have not been subject to the quality control provided by peerreviewed journals. Second, the data include well water and stream samples that are irrelevant to tadpoles. Third, and perhaps most disconcerting, when studies have taken multiple samples over time, Thompson et al. (2006) present the reader with the lowest concentrations following degradation. Fourth, they exclude well-known studies that have observed considerably higher concentrations. Collectively, the indisputable consequence of Thompson et al.’s (2006) failure to cite relevant data, even data coming out of their own research, is to bias the assessment and paint a picture of very low environmental concentrations. The plain fact is that ponds and wetlands that are over-sprayed with Roundup achieve considerably higher concentrations (1.1–5.2 mg a.e./L) than suggested by Thompson et al. (2006). These concentrations are quite similar to many estimated worst-case scenarios (1.4–2.9 mg a.e./L) and demonstrate that the 3 mg a.e./L used by Relyea (2005a) was a reasonable concentration to begin testing the effects of Roundup on tadpoles. Moreover, using only one-third as much Roundup (1 mg a.e./L) still causes up to 71% mortality (Relyea et al. 2005)...

Prior to 2005, members of a single collaborative research group, often in collaboration with Monsanto, have been involved in all of the risk assessments of Roundup ..with a few notable exceptions. ...

There is a growing movement for other laboratories to independently assess the impacts of Roundup (Howe et al. 2004, Relyea 2004b, 2005a, b, c, Relyea et al. 2005) and we need many more laboratories to conduct Roundup experiments to develop more accurate and relevant risk assessments. In doing so, we can replace unsubstantiated attacks with actual data and arrive at the truth.

Tomkins said: "The chemicals biodegrade within a few days to months to a year.."

Then you need to explain why the community of Lorinna's water supply remained contaminated by Atrazine three and a half years after spraying took place!

See: 'The damage done' Australian Financial Review, July 2003. Or ask the Lorinna residents.

You may also wish to look at the Australian State of the Environment report that makes it clear that the biodegradation of pesticides somewhat slows when chemicals find their way into our groundwater. This means that groundwater sources will continue to feed toxic pesticides into our rivers and streams for as long as 100 years after contamination.

In addition to this, the colder the climate the longer it takes for man-made toxins to break down.

Tomkins said: "there is NO EVIDENCE of short or long term effects on mammalian (including human) or environmental health of the use of pesticides in plantations..."

Another false statement. There's tons of evidence!

See the Scammell Report at:

A toxin was isolated from the river water, but never identified (DPIW, February 2005, ). It was claimed it was naturally occurring and therefore no problem. However, the Australian Drinking water guidelines don’t discriminate between natural and man made. A toxin is a toxin regardless of where it comes from (blue green algae, faecal contamination, herbicide, pesticide, etc).

The reason those tests were done was because people (like Dr Bleaney) had already hypothesised that the water was poisonous. Why? Becuase she was observing symptoms of toxicity amongst her human patients in St Helens in North East Tasmania.

Her hypothesis was supported. The water WAS found to be toxic. The alternate hypotheses of the Tasmanian government departments have never been substantiated with data. At this stage that leaves Dr Bleaney's evidence in the winning scientific position and the Tasmanian department of health etc in the dubious legal position of ignoring the evidence that is on the table.

Tomkins claims: "Plantations account for 1% of the intensively managed land in Australia.."

In the Burnie area of North West Tasmania plantations must surely now comprise about - even over - 70% of the entire municipality. Gunns Ltd was reported to have owned 49% in 1999 with a massive land grab by that corporation following in the years thereafter. (Funded by the taxpayer through the Howard Government's 'Managed Investment Schemes' (MIS). Other corporations use the land for intensive tree farming as well. Forest Enterprises, Forestry Tasmania, Rayonier...

A similar situation occurs in the Waratah-Wynyard municipality and in districts of North East Tasmania etc.

It is simply a tactic of deception to fail to mention the consolidation and conversion of whole districts into gigantic monocultures encompassing hundreds of kilometres such as is the case in Tassie.

Tomkins claims: "development of plantations plays a role in the sequestration of carbon - a very topical subject.

We can follow the CO2 trail pretty easily:

Travel to and cut down and burn native forests and/or farmhouses and farming infrastructure.
(Anyone done the calculations of CO2 used to erect the original farms?)

Burn the napalm that is used to start the fire.

Roast the soil and the (often) hundreds of years of humus stored on the forest floor.
["Globally, soils contain four times as much carbon as the atmosphere, and half of the soil carbon is in the form of humus"]

Release more CO2 in the soil by tilling in preparation for planting.

Plant mega-scale single-species plantations. (How much CO2 is produced in the production, transportation and sale of these trees?)

Twelve years later chop plantation trees down. Burn half of the biomass (and the soil) again.

Transport by truck to a woodchip mill.

Use lots of CO2-producing energy to chip the trunks.

Transport the woodchips overseas or over to the other side of the state and pulp them using more CO2-producing fuel.

Transport the paper pulp overseas to make paper and cardboard.

Transport the paper across the globe for sale to industry and consumers.

What does industry and the consumer do to the paper products once they are used? (Paper nappies, kitchen towels, tissues, newspapers, packaging, magazines, books...)

** Most paper pulp is actually used in packaging by industry.

And after all that, cross your fingers and hope that global warming doesn't result in these industrial 'forests'emitting CO2 as they grow!

They (plantations) do emit volatile organic compounds that combine with nitrous oxides in the air (from forestry burnoffs, no doubt) to increase ozone in the lower atmosphere. Ozone is very damaging to human lungs.

As Leunig said: "Gee it's good to read about the end of the world in a nicely designed newspaper."

More on Tomkins claims:

"why does the FSC bother about chemical and fertilizer use in plantations? Such use is trivial, and in this country highly regulated. . ."

No, these chemicals are not subject to a form of regulation that would actually PROTECT human health and the environment.

See: http://www.geocities.com/rosserbj/Pesticide_Abuse_In_Tasmania.html

And on the Tomkins claim that "new plantations are almost all on ex-agricultural land (which may have received previous pesticide and fertilizer applications)."

Crap. Most plantations in Tasmania are on land previously covered with native forest. As for most of the rest I can assure you that the farmers did not apply pesticides on their grazing paddocks except for patches around the fenceline and other isolated and small areas where it was done by hand. This is not comparable with the current practice of aerial spraying entire regions (let alone entire farms).

We have just been visited in Australia by UCLA Professor Dr Tyrone Hayes. (see; www.atrazinelovers.com) Hayes is extremely concerned about the role of the herbicide atrazine in the chemical castration of male frogs and its impact on the wider environment. Atrazine at levels of 0.1 parts per billion inhibits the production testosterone and induces estrogen, resulting in chemical castration and feminisation. This problem has also been detected in other animals including mammals. Hayes also suggests that such hormone 'manipulation' can lead to an increase in the risk of prostate cancer in men and breast cancer in women. The Australian Drinking Water Guideline for Atrazine is 40 parts per billion, 400 times over the level required for chemical castration. The herbicide simazine also impacts in the same way as Atrazine.

Simazine is a prohibited substance under FSC criteria yet Atrazine is not. Why?

Hancock Victoria Plantations, Australia: SmartWood continues to discredit FSC | FSC-Watch
FSC certified company, Hancock, caught on film converting forest to plantations in the Strzezlicki Ranges, Australia | FSC-Watch
FSC Watch: FSC certified company, Hancock, caught on film converting forest to plantations in the Strzezlicki Ranges, Australia
A new video about the Strzezlicki Ranges in Victoria, Australia reveals that FSC is failing to uphold its own standards, allowing destructive logging and conversion of native forest to exotic plantations.
FSC Watch: Hancock Victoria Plantations, Australia: SmartWood continues to discredit FSC
We have been asked to publish the following article, but Anthony Amis of Friends of the Earth Melbourne, Australia. It highlights some now very familiar themes: failure of SmartWo...

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