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Pulpwood Supply

IIS for Bell Bay Pulp Mill Project

12/05/06

(Addressing IIS Guideline Sections 4.2.1 – 4.2.14)

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Table of ContentsSummary 3

4.2.1 General Description of Forestry Operations and Statutory Basis 44.2.1.1 Background to Forest Operations in Tasmania 44.2.1.1(A) Regional Forest Agreement 44.2.1.1(B) Statutory Framework for Conduct of Forest Operations 84.2.1.1(C) System and Forest Management Certification 104.2.1.2 Statutory Regulation of Different Sources of Pulpwood 124.2.1.2(A) Gunns Owned or Managed Wood Supply 124.2.1.2(B) Forestry Tasmania Wood Supply 134.2.1.2(C) Private Property Wood Supply 14

4.2.2 Feedstock from Outside the RFA 15

4.2.3 Supply of Pulpwood Addressing Objectives of the RFA 16

4.2.4 Intensification of Forestry Operations 184.2.4.1 Introduction 184.2.4.2 No Intensification of Forestry Operations in Tasmania 184.2.4.3 No relevant impacts to be assessed and/or mitigated 21

4.2.5 Potential Tasmanian RFA Expiry 224.2.5.1 Potential RFA expiry 224.2.5.2 Minimal impacts if RFA expires 22

4.2.6 Likely Supply Zones for Sourcing Mill Resource 234.2.6.1 Resource Modelling Process 234.2.6.1.1 Introduction 234.2.6.1.2 Forest Modelling Process 234.2.6.1.3 Verification of Forest Modelling 244.2.6.2 Input Data: Sources of Pulpwood in Tasmania 254.2.6.2(A) Gunns Owned or Managed Forests 254.2.6.2(B) Private Property Resource 264.2.6.2(C) State Forest Resource 284.2.6.2(D) Sawmill Residues 284.2.6.3 Total Projected Pulpwood Availability within Tasmania 304.2.6.4 Anticipated Source of Pulpwood for the Pulpmill 324.2.6.4(A) Anticipated Strategy 324.2.6.4(B) Plantation Preference Strategy 344.2.6.4(C) Comparatives between Anticipated and Plantation Strategies 36

4.2.7 Details of Imports of Pulpwood from non-Tasmanian Sources 38

4.2.8 Type and Species of Pulpwood Required for the Project 39

4.2.9 Quantity of Pulpwood required for the Project 40

4.2.10 Indication of the Proportion of younger to older wood 41

4.2.11 Arrangements in place to secure sufficient supply of resource 42

4.2.12 Variation of security through the project life 44

4.2.13 Maintenance of a sustainable yield 454.2.13(A) Gunns Owned or Managed Resource 454.2.13(B) Forestry Tasmania Resource 454.2.13(C) Private Property Resource 45

4.2.14 Quantity of Pulpwood currently exported to be redirected 47

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Summary

Section 4.2 of the Scope Guidelines requires the IIS to include information about thepulpwood supply to the pulp mill. This Chapter of the IIS provides the information required bysection 4.2 of the Scope Guidelines.

Gunns currently anticipates that the pulp mill will process about 3.2 to 4.0 million GMt ofpulpwood per year (used to produce 820,000 to 1,100,000 air dryed tonnes [adt] of pulp).This amount is less than Gunns’ average exports over the past 5 years of 4.7 million GMtper annum.

The pulp mill project is a downstream processing initiative and will not involve any changesto forest access or additional intensification of forestry operations. It is based upon divertingresource that would otherwise have been exported in chip form to the pulp mill for value-added processing.

A mixture of wood from native forests, pine and eucalypt plantations will be used. No RFAdefined old growth pulpwood will be used in the mill. It is likely that wood will be sourcedfrom Forestry Tasmania, private forest owners, and Gunns’ Owned or Managed land.Forestry Tasmania is a Government Business Enterprise wholly owned by the TasmanianGovernment.

Most of the logs will be processed into woodchips at Gunns’ existing Tamar woodchip exportfacility. The Tamar woodchip export facility will need to be upgraded to accommodate theincreased volume of log processing.

The wood supply for the mill will be secured from forest managed in accordance with theRFA (for so long as that Agreement or any reviewed, extended or replacement remains inforce) and the Forest Practices Act 1985 (or any amending or replacement Act that regulatesthe forest industry in Tasmania).

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Section 4.2.1 – General Description of Forestry Operations and Statutory Basis

This section provides a background to the operating framework for forest operations withinTasmania, along with an outline of the statutory basis for operations (on both public andprivate land) supplying pulpwood to the proposed mill. It also provides an overview of Gunns’certified environmental management and forest operation systems.

4.2.1.1 - Background to Forest Operations in Tasmania

Forest operations in Tasmania are governed by a number of legislative and policyinstruments, and are overseen by a number of key government and non-governmentagencies. In addition, both Gunns and Forestry Tasmania conduct their forest operations inaccordance with respective environmental and forest management systems.

The key components of this operating framework for supply of forest products to theproposed mill are:

o the Tasmanian Regional Forest Agreement (including amendments and theSupplementary Agreement to the Regional Forest Agreement); and

o the Forest Practices Act 1985 and the Forestry Act 1920

Pulpwood supply for the proposed mill will be sourced from forest managed in accordancewith the Tasmanian Regional Forest Agreement (for so long as that Agreement or anyrenewed, extended or replacement Agreement remains in force – see Section 4.2.5), theTasmanian Forest Practices Act 1985 (or any amending or replacement Act that regulatesthe forest industry in Tasmania) and the resultant Forest Practices Code, and other relevantlegislation relating to Forest Management as contained in Appendix 4.2.1.

Gunns and Forestry Tasmania’s forest and environmental management systems aremanaged to both the Australian Forestry Standard [AS4708(int)] and InternationalOrganisation for Standardisation’s ISO 14001 [AS/NZS ISO 14001].

These elements are explained further detailed in the following;

A) Regional Forest Agreement

The Tasmanian Regional Forest Agreement was signed by the Commonwealth andTasmanian Governments in 1997. An agreement was made to vary the RFA on 19 July2001, and a supplementary Tasmanian Regional Forest Agreement was made on 13 May2005. These agreements are collectively referred to as RFA in this section of the IIS.

The RFA establishes mechanisms for the management and use of Tasmanian forests (bothpublic and private) through achieving a balance between effective conservation, forestmanagement and forest industry practices. A review of the performance of the RFA mustoccur every five years, and it will expire after 20 years unless Tasmania and theCommonwealth agree to renew the RFA. The RFA includes a renewal procedure which mustcommence five years before its anticipated expiry in 2017.

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The Tasmanian RFA was a mechanism for fulfilling the goals of the National Forest PolicyStatement 1992 (NFPS), a national strategy endorsed by the Commonwealth and all Stateand Territory Governments. The RFA provided a framework to deliver the followingobjectives (as detailed in Clause 19 of the Agreement);

1. Developing and implementing ecologically sustainable forest management (ESFM)within Tasmania.

• The establishment of fully integrated and strategic forest management systemscapable of responding to new information.

• The maintenance of a Permanent Native Forest Estate to maintain thesustainability of total estate conservation and productive values.

• Based upon a continuous improvement approach including research elementsand regular performance reviews of the ecological sustainable forestmanagement framework.

2. Establishing a Comprehensive, Adequate and Representative (CAR) Reserve System.

3. Facilitating the development of an internationally competitive wood production and woodproducts industry.

• Provide for certainty of resource access to the forest industry.• Development of a sustainable yield approach for management of public forests

within Tasmania to guarantee resource availability into the future.• Active encouragement of the development of downstream processing within

Tasmania such that the preferred market for growers is within the State.• The implementation of new intensive forest management initiatives, including

plantation development, to balance changes in forest inventory resulting from theimplementation of conservation initiatives promoted through the Agreement.

4. Promoting the conservation and management of the Private Forest Estate.

Detail on elements resulting from delivering the objectives of the RFA is included below;

CAR Reserve System – public landClause 24 of the RFA imposes an obligation on the State of Tasmania to legislate for apublic land classification to create a comprehensive, adequate and representative reservesystem (CAR Reserve System), and to manage the CAR Reserve System in accordancewith conservation objectives listed in the RFA. The RFA lists the reserve classifications forthe CAR Reserve System and Attachment 7 details the objectives of each classification. It iswithin these areas that the RFA contemplates no forestry activities are to take place.Forestry activities are only permitted on State Forest which is not within the CAR ReserveSystem, the only exception being for clearly defined and regulated infrastructuredevelopment.

The categorisation of land within the CAR Reserve System has been based upon the JANISReserve Criteria, which are defined in the RFA and referred to in this IIS as “CAR Values”.

This categorisation of land included detailed scientific assessment of biological, social andcultural values in both public and private forests within Tasmania at a bioregional level. Theassessments produced;

• Classification and distribution of 50 different native forest communities, along with theirconservation status and significance.

• Distribution of old growth forests by forest community and their conservation status.• Distribution of threatened plant and animal species and their likely habitats.• Areas of indigenous or historical heritage value.

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The Supplementary Agreement signed in 2005 commits the parties to augment the CARReserve System by adding 141,000ha of public land to the CAR Reserve System.Theseadditions are to include Old Growth forest, bringing the total area of Old Growth forestreserved on public land to 977,000ha. The Supplementary Agreement sets out proceduresand timelines for these commitments to be achieved.

The CAR Reserve System in Tasmania includes Formal and Informal Reserves createdunder the Nature Conservation Act 2002, the Forestry Act 1920 and the Crown Lands Act1976.

The National Parks and Reserves Management Act 2002, Forestry Act 1920 and CrownLands Act 1976 require management plans to be prepared for all reserved land. Themanagement plans describe the purpose of the land reservation, its values and uses andrestrictions on use of land.

Further restrictions on the use of reserved lands for forestry and commercial activities, suchas the cutting down of trees, are contained in the National Parks and Reserves ManagementAct.

Private landThe RFA contains commitments to conserve and manage the Private Forest Estate,including the encouragement of voluntary participation by landowners to protect certainvalues listed in Attachment 8 to the RFA.

Under the Private Forest Reserve Program, the Tasmanian government (through DPIWE)has negotiated with private landowners to protect CAR values on private land. Under thisProgram, landowners have been provided with assistance and funding to manage forests ofconservation value, and in some instances land has been purchased by the State. However,the Program has mostly focussed upon negotiating covenants and management agreementswith landowners to bring privately owned forests into the CAR Reserve System.

Although the Private Forest Reserve Program will cease by June 2006, the AustralianGovernment is establishing, in cooperation with Tasmania, a market based program toprotect and manage up to 45,600ha of private forested land.

Permanent Native Forest EstateUnder the RFA, Tasmania agreed to adopt the policy framework in Attachment 9 of the RFAin order to design and maintain an extensive and Permanent Native Forest Estate. In sodoing, Tasmania committed to maintaining the Permanent Native Forest Estate to retentionthresholds at a State, bioregional and forest community level. At a State level, thecommitment is to retain a minimum of 95% of the 1996 native forest estate.

The Forest Practices Authority is required under the Forest Practices Act to monitor andreport on harvesting and reafforestation activity in relation to the maintenance of thePermanent Forest estate. In its 2004-2005 Annual Report, the Authority reported thatTasmania’s native forest estate had been maintained at a level equivalent to 96.9% of thenative forest area, in excess of the threshold level. Where forest communities were at orapproaching the threshold levels, the Authority reported that it had taken various actionsincluding the imposition of interim moratoriums on the clearing of rare, endangered orvulnerable forest communities [Source: Annual Report on Forest Practices 2004-2005, Part1.8 and Appendix 4].

The Permanent Forest Native Estate Policy is implemented through the provisions of theForest Practices Act.

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Timber productionThe Tasmanian and Australian Governments committed to the objective of ecologicallysustainable forest management (ESFM). To achieve this objective, Tasmania committeditself to the ongoing development and implementation of its Forest Management Systems,which include the Forest Practices Act and the Forest Practices Code.

With respect to the Forest Management System, Tasmania also signalled its intention to:o ensure timber harvesting plans specify, where relevant, best-practice reforestation

standards and provide for ongoing monitoring; ando where threatened species are identified in an area for which Forest Practices Plan

approval is sought by private landowners, the plan must include appropriatemanagement prescriptions to those species.

The Tasmanian and Australian Governments also committed to enhance the future growthand development of Tasmania’s industries associated with forests and timber products. Toachieve this objective, intensive forest management initiatives were included in the RFA forthe purpose of providing from State Forest a minimum of 300,000 cubic metres per annum ofhigh quality eucalypt sawlog/veneer log and 10,000 cubic metres per annum of blackwoodsawlogs. In the Supplementary Agreement, Tasmania agreed to deliver, withCommonwealth financial support, an integrated program of existing plantation productivityimprovement and development, new plantation establishment, and enhanced native forestthinning programs designed to maintain these targets on State Forest.

Employment and Industry DevelopmentIn the RFA, the Tasmanian and Australian Governments recognise the contribution of forest-based industries to the Tasmanian economy, and agree to co-operate in implementing aseries of actions which are listed in clause 74 and Attachment 12 of the RFA.

These actions included:

• active encouragement of the development of downstream processing in Tasmania suchthat the preferred market for growers is within the State;

• a range of new and enhanced initiatives designed to encourage investment, plantationdevelopment, downstream processing, value-adding, industry development andemployment growth in Tasmania’s forest-based industries; and

• the implementation of new intensive forest management initiatives, including eucalyptand black wood plantations, and native forest thinning, to balance changes in forestinventory resulting from the RFA, and expand that inventory.

For more information about how forestry operations and supply of pulpwood for theproposed mill will address the objectives and provisions of the RFA, see section 4.2.3.

The RFA has been a catalyst for the implementation of its key outcomes (Objectives 1-4) vialegislation. This resultant legislative framework is outlined in Part B – Statutory Frameworkfor Conduct of Forest Operations.

B) Statutory Framework for Conduct of Forest Operations

As referenced in Part A – Regional Forestry Agreement, the RFA provided for the legislativeframework to enact ecologically sustainable forest management (ESFM) practices withinTasmania. This framework is comprised of the following key elements;

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o Forest Practices Act 1985. This Act establishes the Forest Practices Authority, whichhas primary responsibility for oversight and implementation of the Act, and providesfor the appointment of forest practices officers (including a chief forest practicesofficer). It also establishes a Forest Practices Advisory Council, which providesspecialist advice and assistance to the Authority;

o Forest Practices Code, which is issued by the Forest Practices Authority undersection 30 of the Forest Practices Act. The Code must prescribe the manner in whichforestry operations shall be conducted so as to provide reasonable protection to theenvironment;

o Regional Forest Agreement (Land Classification Act) 1998, which was enacted togive effect to Tasmania’s commitments in the RFA to expand the CAR ReserveSystem;

o Private Forests Act 1994, which establishes Private Forests Tasmania to promote thedevelopment of private forests in Tasmania;

o Forestry Act 1920, which establishes Forestry Tasmania and provides for thededication of State Forests and Forest Reserves. Forestry operations undertaken onState Forests and/or undertaken by Forestry Tasmania must comply with the ForestPractices Act and the Code.

Further details on each of the above statutory elements are listed below. Additional contextto legislation directing the implementation of ESFM in Tasmania is set out in Appendix 4.2.1.

Forest Practices ActThe Forest Practices Authority established by this Act is part of Tasmania’s forest practicessystem. Schedule 7 to this Act provides that the objective of this system is to achievesustainable management of Crown and private forests with due care for the environment andheritage values, while delivering certain outcomes listed in that Schedule including self-regulation, forest planning, forest practices plans and the Forest Practices Code,consultation and education.

Other key features include:o the Authority’s power to issue, after consultation with Private Forests Tasmania and a

public exhibition process, the Forest Practices Code;o the process for creating private timber reserves on which forest operations may

occur. This is a public process, which includes third party objections and appeals tothe Forest Practices Tribunal. The establishment of forests, and the growing orharvesting of timber, on private forest reserves must comply with the Forest PracticesCode;

o the process for certifying, and independently verifying that forest operations conformwith, Forest Practices Plans.

Forest Practices CodeThe Forest Practices Code is issued by the Forest Practices Authority after consultation withPrivate Forests Tasmania, and undergoing a public notification and comment process. It isthe key regulatory instrument by which Tasmania ensures forest practices protect theenvironment and heritage values.

The current Forest Practices Code was issued in 2000, and provides a practical set ofguidelines and standards for the protection of environmental values, with a particular focuson:

o soils and geomorphology;o visual landscape;o water quality and flow;o flora, fauna and genetic resources; and

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o cultural heritage.

The Code is supported by various manuals and technical instructions endorsed from time totime by the Forest Practices Authority after consultation with the Forest Practices AdvisoryCouncil.

Forest Practices PlansCentral to ESFM is the requirement to prepare and submit Forest Practices Plans (FPPs) tothe Forest Practices Authority for certification. FPPs must be prepared for all roadconstruction and quarrying required to provide access for forestry operations, forestharvesting and forest establishment (both native forest and plantation) operations.

FPPs must be in accordance with the Forest Practices Code and specify various mattersprescribed by the Forest Practices Act, including the environmental values occurring withinthe plan area and the prescriptions that will be applied to protect those values.

It is an offence (aside from exemptions as regulated under the Forest Practices Act 1985relating to small areas or volumes) to carry out any of the following activities without acertified FPP:

o Establish forests;o Harvest timber;o Clear trees;o Construct roads or conduct quarrying operations in connection with any of the above

activities.

Failure to comply with a certified FPP is an offence, and the Authority has broad powers torevoke a FPP for any reason it considers sufficient.

Forest Practices Officers, who are trained and accredited by the Forest Practices Authority,prepare and approve Forest Practices Plans. Input into plan preparation is obtained fromspecialists employed by the industry and the Forest Practices Authority. The process forpreparing and implementing FPPs includes:

1) Assessment of the natural and cultural values of the coupe - All areas whereforest operations are to be conducted are assessed for natural and culturalvalues, including fauna, flora, cultural heritage, geomorphology, visualmanagement, soil and water.

2) Operational Planning – Aspects such as road locations and associatedengineering plans are determined, along with coupe timber inventories andharvest strategies. Boundaries are marked in the field to ensure that theharvest area (and reservation areas) is clearly delineated.

3) Plan Review and Approvals – On completion of peer review, FPPs arecertified by Forest Practices Planning Officers, as delegates of the ForestPractices Authority.

4) Operations – Management systems and procedures are used to ensureproper process is followed during forest operations.

5) Monitoring Compliance and Continuous Improvement – The forest industryconducts internal audits regularly to ensure that forest operations areoccurring in accordance with the FPP, and the holder of a FPP must providea compliance report to the Forest Practices Authority within 30 days after thecompletion of each discrete operational phase of the authorised forest

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practice. In addition, the Forest Practices Authority annually audits a sample(about 15% - Source: Annual Report on Forest Practices 2004-05, section1.7.1) of Forest Practices Plans to ensure that forestry practices comply withcertified FPPs.

C) System and Forest Management Certification

To ensure effective implementation of the legislative framework described in Parts A and Band to ensure best practice and continuous improvement in sustainable forest management,both Gunns Limited and Forestry Tasmania maintain certification to both ISO 14001 and theAustralian Forestry Standard.

Supply of forest products from Gunns processing facilities adheres to a Chain of CustodyStandard. The Australian Forestry Standard and the Chain of Custody Standard areelements of The Australian Forest Certification System, which is internationally recognisedby the Programme for the Endorsement of Forest Certification Schemes (PEFC).

These elements of system and forest management certification are further detailed below.

EMS CertificationBoth Gunns’ forestry division and Forestry Tasmania maintain certified environmentalmanagement systems (EMS) to AS/NZS ISO14001 (Environmental Management Systems –Specifications and guidance for use). International Organisation for Standardisation’sISO14001 is a globally respected reference in relation to Environmental ManagementSystem implementation and performance.

Gunns Forestry Divisions’ EMS (encompassing its wood fibre processing mills, harvesting,native forest and plantation activities across all land tenures) was certified to ISO14001 in1998. A more detailed description of Gunns’ EMS is provided as an appendice to this IIS.Gunns plans to extend EMS certification across its pulpmill processing operations.

Forestry Tasmania’s EMS applies to all of its operations on State Forest including nativeforest and plantation areas.

Australian Forestry StandardThe Australian Forestry Standard [AS4708(Int)] is the national benchmark for independentlyverifying environmental, economic and social sustainability in forest management. Theobjective of the Australian Forestry Standard is to provide forest managers and owners witheconomic, social, environment and cultural criteria and requirements that support thesustainable management of forests for wood production. Forest managers must demonstrateboth system and performance adherence to these criteria, which are summarised in Figure4.2.1.

Gunns’ certification under the Australian Forestry Standard (certification No. 00001-2003-AFS-SYD-JAS-ANZ) was achieved in 2003 and applies to 249,916 hectares of native forestand plantations (as at 31st December, 2005). Certification credentials in relation to GunnsLimited relate to management of Company freehold lands and private property underCompany management (native forests, hardwood and softwood plantations).

Forestry Tasmania’s certification (certification No. FMS 200001) applies to State Forest areaunder its management control, including native forest and plantations, which have acumulative total of 1.4 million hectares.

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Figure 4.2.1 – Sustainable Forest Management context under the Australian Forestry Standard[Source – Gunns Limited Australian Forestry Standard Manual 2005]

As part of an integrated management system approach, Gunns maintains detailedGeographic Information System (GIS) databases to ensure an integrated basis forenvironmentally, socially and economically sustainable management of forests.

Programme for Endorsement of Forest Certification Schemes (PEFC)The Programme for the Endorsement of Forest Certification Schemes (PEFC) is anindependent, non-government international forest certification scheme which promotessustainably managed forests through independent third party certification. The PEFC hasendorsed an Australian Forest Certification System, which consists of:

o the Australian Forestry Standard (AS4708);o the Chain of Custody Standard (AS4707); ando JAS-ANZ Accreditation Programmes (outlining accreditation criteria for bodies

seeking accreditation for the Australian Forest Certification System).

PEFC is the world’s largest sustainability recognition framework.

Chain of Custody StandardGunns’ operations are also certified under AS4707 (Int) [Chain of custody for certified woodand forest products] for all of its chip, timber and veneer processing sites within Tasmania.This Standard is the national benchmark for verification to guarantee a trace back systemfrom the finished product to the forest. It sets out minimum criteria and requirements forChain of Custody certification for wood and forest products originating from a defined forestarea that has been certified to the Australian Forestry Standard or sourced from other forestsmanaged under schemes recognised as substantively equivalent to the Australian ForestryStandard.

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Adherence to this Standard ensures products sold by Gunns Limited have originated fromsustainably managed AFS and PEFC certified forests. It is proposed that the Pulp Mill willseek to obtain Chain of Custody certification, such that pulp produced will be sold as AFSand PEFC certified pulp.

Auditing and Data ManagementGunns’ forestry operations have been independently audited and certified by JAS-ANZaccredited bodies to conform with AS/NZS ISO 14001, the Australian Forestry Standard, theChain of Custody Standard to ensure ongoing compliance and continuous improvement.

4.2.1.2 - Statutory Regulation of Different Sources of Pulpwood

A mixture of wood from native forests, pine and eucalypt plantations will be used asfeedstock for the mill. The quantity of plantation wood is likely to increase over time as theplantation estate in Tasmania matures and becomes available for harvesting.

Wood will be sourced from forests and plantations which are grown and maintained on arange of different forms of land tenure including crown land and State Forests managed byForestry Tasmania, private forest owners, and land either owned or managed by Gunns.

Further detail on each of these resource categories is described below;

A. Gunns Owned or Managed Wood Supply

Gunns manages timber and harvesting operations from a variety of sources. The timberis grown on land either owned (188,686ha as at December 31, 2005) or leased ,jointventured or managed under a Forest Practices Plan (61,230 as at December 31, 2005)by Gunns (or one of its related companies).

A.1 Ownership

Of the 188,686ha of freehold land owned by Gunns, approximately 75,000 ha. areplantations, 40,000 ha. are managed native forest, 38,000 ha. are informal conservationreserves, and the balance is made up of inaccessible and non-commercial land.

Pursuant to its leases with landowners, Gunns manages and controls the plantationwood grown on 36,921ha (as at December 31, 2005) of land leased and joint venturedby Gunns. The plantation wood is either wholly owned by Gunns, in joint ventures withthird parties, or by investors in Managed Investment Schemes.

A.2 Plantation timber

All plantation wood is planned for harvest through a range of thinnings and clear fellwhen it reaches maturity, which occurs between a range of 10 – 25 yrs from when thetrees are planted.

A.3 Native forest

Native forest is managed on a sustainable yield basis over a notional 60 – 80 yearrotation, and is mostly managed on selective harvest regimes.

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A.4 Pulp Mill Supply

Timber harvested from plantations and native forests on land owned or leased byGunns, either as sole tenant or as a joint venture party, will be a significant source oftimber supply to the pulp mill. These harvesting operations will:

o continue to comply with the Forest Practices Act 1985, or any replacement oramending Act, and the Forest Practices Code (as varied or revised from time totime). Importantly, this means that any forestry operations must be undertaken inaccordance with a certified FPP; and

o be undertaken in accordance with Gunns’ independently certified environmental,forest and chain of custody management systems.

B. Forestry Tasmania Wood Supply

Forestry Tasmania is the name given to the Forestry Corporation, a statutorycorporation established by the Forestry Act 1920. The Forestry Act 1920 requiresForestry Tasmania to make available for the veneer and sawmilling industries, fromState Forest each year, a minimum of 300,000 cubic metres of high quality eucalyptsawlog. The sustainable high quality eucalypt sawlog supply from Tasmanian StateForest is reviewed every 5 years as required by the RFA. The review is published.

Pulpwood is an arising from the production of sawlogs. From this strategic woodsupply modelling, and market demand, wood production targets are set. A ThreeYear Wood Production Plan is published, listing areas available for harvest, whichtakes account a number of Forestry Tasmania’s key SFM tools, including:

o Sustainable Forest Management Policy;o Permanent Native Forest Estate Guidelines;o Rainforest Policy;o Management Decision Classification System;o Strategic Threatened Species Management Agreements;o District Forest Management Plans.

Forestry Tasmania supplies plantation and native hardwood to Gunns under variouscontractual arrangements. Wood supplied by Forestry Tasmania is sourced fromState Forests, and harvesting operations are either controlled by Gunns or ForestryTasmania under and in accordance with Forestry Tasmania’s Three Year WoodProduction Plan. Timber harvested from State Forests will be a significant source oftimber supply to the pulp mill, pursuant to existing and future contractualarrangements between Gunns and Forestry Tasmania. These harvesting operationswill:

o continue to comply with the Forest Practices Act 1985, or any replacement oramending Act, and the Forest Practices Code (as varied or revised from timeto time). Importantly, this means that any forestry operations must beundertaken in accordance with a certified FPP;

o where carried out by Forestry Tasmania, conform with Forestry Tasmania’sindependently certified EMS and forest management systems; and

o where carried out by Gunns, be undertaken in accordance with Gunns’independently certified environmental, forest and chain of custodymanagement systems.

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C. Private Property Wood Supply

Gunns employs specialist staff who negotiate and secure a supply of wood from third partylandowners, including private timber reserves declared under the Forest Practices Act. Thiswood supply is a mixture of plantation and native forest, with the proportion of wood sourcedfrom plantations continuously increasing. The harvesting operations on private land areusually controlled or supervised by Gunns.

Because of the speculative nature of negotiating and purchasing a supply of wood from thirdparty landowners, the average planning horizon for third party private wood supply is lessthan 12 months.

Privately owned forests and plantations will be an important source of wood supply for thepulp mill. Importantly, harvesting operations on private land for supply to the pulp mill will:

o continue to comply with the Forest Practices Act 1985, or any replacement oramending Act, and the Forest Practices Code. Importantly, this means that anyforestry operations on privately owned land must be undertaken in accordance with acertified FPP; and

o where harvesting operations are carried out by Gunns, those operations will beundertaken in accordance with Gunns’ independently certified environmental, forestand chain of custody management systems. Even where Gunns does not carry outthe harvesting operations itself, it will still be able to track the source of the timberfrom its chain of custody systems.

o be undertaken in accordance with a statutory Wood Production Plan, as required bythe Forest Practices Act 1985.

Further detail in relation to the indications of quantities of pulpwood from these sources iscontained in Section 4.2.6 – Likely Supply Zones for Sourcing Mill Resource.

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Section 4.2.2 – Feedstock from outside the RFA

No feedstock for the mill will be sourced from Tasmania outside of the Tasmanian RegionalForest Agreement (as amended) framework.

The Scope Guidelines require the IIS to provide details of any feedstock for the pulp millintended to be sourced “outside” of the RFA (as amended). From the perspective ofharvesting timber, this requires the IIS to identify:

o any native forests within the CAR Reserve System within which a wood supply forthe pulp mill is proposed to be sourced; and

o any wood supply that is proposed or is likely to be established, maintained andharvested in non-conformity with Tasmania’s Forest Management Systems, whichinclude the Forest Practices Act and the Forest Practices Code.

It is illegal to undertake any of these activities. There are also a range of penalties forbreaching the Forest Practices Act, including fines and the revocation of FPPs.None of theseactivities are proposed to be undertaken for the purpose of supplying timber to the pulp mill.

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Section 4.2.3 – Supply of Pulpwood addressing objectives of the RFA

As addressed in Sections 4.1.2 and 4.2.2, all supply of pulpwood to the mill will operatewithin the Tasmanian legislative framework that has been enhanced consequent to the RFA,and hence will address the objectives of the RFA.

Specifically, and in relation to the objectives 1-4 of the RFA as detailed in Section 4.2.1.1,supply of pulpwood for the proposed mill, and the investment in the proposed mill, willaddress objectives:

1) Developing and Implementing Ecologically Sustainable Forest Management (ESFM)

Wood supply for the mill will operate under the legislative framework described by, andenhanced consequent to, the RFA to meet the objectives of the RFA for delivery of ESFM.Tasmania’s commitment to developing and implementing ESFM has mainly been achievedthrough its Forest Management Systems. The cornerstones of these Forest ManagementSystems are the Forest Practices Act and the Forest Practices Code.

Tasmania also agreed to develop and implement EMSs in accordance with the principles inAttachment 5 of the RFA to a standard comparable to ISO 14,001. As discussed in Section4.2.1.2, Forestry Tasmania has an EMS that has been accredited under AS/NZS ISO 14,001and the Australian Forestry Standard. Continuous improvement concepts of ecologicallysustainable forest management will be supported via both Gunns and Forestry Tasmaniacommitments to sustainable forest management, currently guided by certification underISO14001 and the Australian Forestry Standard.

As explained at sections 4.2.2 and 4.2.3, timber feedstock for the pulp mill will be sourcedfrom native forests and plantations on private and public land and will comply with the ForestPractices Act, the Forest Practices Code, and any other laws or regulations that from time totime apply to the establishment, maintenance and harvesting of timber in Tasmania.

The supply of timber as feedstock to the pulp mill will therefore not affect or prevent theimplementation of this RFA objective.

2) Establishing a CAR Reserve System

Tasmania has established the CAR Reserve System, through legislation and executiveactions, by protecting conservation values on public and private land under the NatureConservation Act 2002, the Forestry Act 1920, the Crown Lands Act 1976 and the ForestPractices Act 1985.

The Private Forest Reserve Program was established under the RFA to improve thevoluntary protection of privately owned high conservation value forest. About 30,000ha ofprivate land has been secured to date under this program. Under the terms of theSupplementary RFA signed in May 2005 the program will cease by 30 June 2006 and bereplaced by a market based program, the Forest Conservation Fund, managed by theAustralian Government to protect up to 45,600ha of private forested land.

As explained at sections 4.2.2 and 4.2.3, timber feedstock for the pulp mill will be sourcedfrom native forests and plantations on private and public land where timber harvesting

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operations can lawfully be carried out. No timber for the pulp mill will be harvested illegallyfrom CAR Reserves.


3) Facilitating the development of an internationally competitive industry

Gunns’ investment in the pulp mill will support this objective of the RFA by enabling thedownstream and value-added processing of timber into high grade pulp, a key wood productfor which there is a significant Australian and international demand.

The project entails the redirection of currently exported resource (as per Section 4.2.14) tothe mill for value adding within Tasmania (producing social and economic benefits asdetailed in Section 8 – Economic Analysis of Proposed Pulp Mill).

Stimulating investment such as the proposed mill is meeting significant objectives of theRFA. The Federal and State Governments have provided a framework for stimulation ofinvestments through the RFA, and this proposed mill is an example of industry responding tothis framework by delivering downstream processing and employment opportunities.


4) Promoting the conservation and management of the Private Forest Estate

In addition to this RFA objective, clause 74 also provides for “the active encouragement ofthe development of downstream processing in Tasmania such that the preferred market forgrowers is within the State”.

The proposed mill will provide added security to private forest growers and managers, andensure that the preferred Australian market for private forests is within Tasmania. Theharvesting of pulpwood from private lands will also provide opportunities for bettermanagement of the Private Forest Estate, for example, the development of propertymanagement plans and the identification and protection of significant values as part of theplanning process.

As explained at section 4.2.1.2, a significant source of timber feedstock for the pulp mill willbe private forests either owned by third parties or owned or leased by Gunns. This timber willbe harvested in accordance with the Forest Practices Act, the Forest Practices Code andany relevant certified FPP. Where harvested by Gunns, these harvesting operations will alsobe conducted in accordance with Gunns’ independently certified environmental, forest andchain of custody management systems.

The supply of timber as feedstock to the pulp mill from private lands will provideopportunities for promoting the conservation and management of the Private Forest Estate,thereby supporting the implementation of this RFA objective.

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Section 4.2.4 – Intensification of Forestry Operations

This section provides details of any intensification of forestry operations in Tasmania(including of native forest and the establishment of plantations on agricultural land(hardwood or softwood) and silvicultural practices) for the supply of pulpwood of all types (forthe life of the mill), the likely environmental, social, economic and community issues andeffects of any such intensification, and how those effects will be addressed.

4.2.4.1 Introduction

All wood for the pulp mill will be sourced from wood that would otherwise have beenexported as woodchips. The proposed pulp mill is a downstream processing initiative, basedupon diverting forest resource which would otherwise have been exported in chip form to thepulp mill for value-adding processing into high grade pulp. The pulp mill is not dependent onchanges to the manner in which forestry activities are carried out, nor will it intensify timberproduction or forest operations within Tasmania.

Resource projections as contained in this Section are a function of Gunns Pulpmill ResourceModelling. Refer to Section 4.2.6 for detail in relation to modelling methodology, outputs andvalidation relating to this study. Gunns Pulpmill Resource Modelling has analysed, subject torelevant assumptions as indicated in Section 4.2.6, the total resource “potentially available toGunns”. This terminology includes resource from all tenure and supply types that Gunns hasmodelled to potentially be available to it into the future, subject to landowner intent andcommercial arrangements. It is not a reflection of the total Tasmanian Pulpwood Resource,but rather the component of that total resource, based on Gunns Resource Modelling andinherent assumptions, that Gunns considers will be available to it for pulpwood processing orwoodchip export into the future.

4.2.4.2 No intensification of forestry operations in Tasmania

Pulpwood volumes

Native forests presently available for lawful harvesting and timber production activities will bea potential source of timber feedstock for the pulp mill. However, the analysis presented inthis section demonstrates that demand for timber as feedstock to the pulp mill will notincrease the area of native forest to be made available for timber harvesting.

Furthermore, the current trend to develop hardwood and softwood plantations on privateland are expected to continue, with no increase in intensification required as a result of thepulpmill.

Figure 4.2.4.1 reveals that over the past five years, Gunns has exported an average of 4.7GMt (log equivalent) per annum of woodchips from Tasmania.

It is estimated that the pulp mill will process about 3.2 to 4.0 million GMt (log equivalent) ofpulpwood per year. This is less than Gunns’ average woodchip exports over the past fiveyears, and substantially less than the 5.3 to 6.7 GMt per annum of pulpwood that is forecastto be available to Gunns annually over the life of the mill. Further information about thederivation of future resource volumes is contained in Section 4.2.6.

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As demonstrated by Figure 4.2.4.1, the availability of timber sourced from plantations isforecast to increase over time as the existing plantation estate matures. The anticipated mixof plantation and native wood supply to the pulp mill is described in Section 4.2.6.

Pulpwood from native forest

The available pulpwood resource from native forest within Tasmania is predicted to reducesignificantly over the life of the project (Gunns Pulpwood Resource Modelling – Section4.2.6). As demonstrated in Figure 4.2.4.1, available native forest resource to Gunns isexpected to reduce from current levels of ~4 million GMt to ~2 million GMt over the life of theproject. Based on Gunns Pulpwood Resource Modelling (refer Section 4.2.6), the relativecontribution of native forest wood to the mill is predicted to reduce significantly over the lifeof the project, from an initial 80% contribution to a 20% contribution.

On this basis, the level of timber production from native forests is not expected to intensify,nor are the areas of native forest available for timber production expected to increase, as aresult of the pulp mill.

Figure 4.2.4.1 – 30yr Actual and Predicted Review of Gunns Statewide Pulpwood Resource [Source:Gunns Pulpmill Resource Modelling – refer Section 4.2.6]

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Pulpwood from plantations

As demonstrated in Figure 4.2.4.1, available plantation forest resource to Gunns is expectedto increase from current levels of ~1 million GMt to ~4 million GMt over the life of the project.The relative contribution of plantation wood to the mill under an anticipated strategy ispredicted to increase significantly over the life of the project, from an initial 20% contributionto an 80% contribution.

Note that achievement of 100% plantation wood supply to the mill is theoretically possible asdemonstrated in approximately 2017, and has been modelled as required by the IISguidelines and is further explored within Section 4.2.13 and in the Transport analysis for theIIS. This scenario is not necessarily an anticipated strategy, with the ultimate weighting of

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the resource mix dependant on the availability and cost of projected resource categories intothe future along with the commercial aspects of the sale of pulp.

In terms of the intensification of the establishment of plantations in Tasmania to supply thisincreasing plantation supply to the mill, no additional intensification outside of the currentGunns Owned or Managed planting levels is envisaged or required as a result of the pulpmill development.

As demonstrated in Figure 4.2.4.2, Gunns’ plantation estate (on land owned or managed byGunns) has grown at a rate of approximately 10,000ha per year for the past five years. Theresource analysis undertaken for the purpose of the pulp mill was based upon a total Gunnsplantation estate of 150,000ha being achieved in approximately 10 years time (consistentwith Gunns previous and current business strategy for a 150,000ha plantation estate withinTasmania).

Based on these predictions and the planned growth of Gunns’ plantation estate, the currenttrend to develop hardwood and softwood plantations are expected to continue, with noincrease in intensification required as a result of the pulpmill. The necessary growth inplantation development in Tasmania to underpin potential resource for the pulp mill is lessthan the inherent growth already occurring within the industry.

Figure 4.2.4.2 – Gunns Owned or Managed Plantation Estate, Actual and Forecast Growth [Source: GunnsPulpmill Resource Modelling : refer Section 4.2.6]

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The growth of plantations in Tasmania is consistent with the framework provided for by theRFA. This framework has been designed to achieve (as detailed in Clause 74 of the RFA)the implementation of intensive forest management initiatives, including plantationdevelopment, in order to balance changes in forest inventory resulting from the native forestconservation initiatives brought about by the Agreement.

It should also be noted that expansion in the plantation estate is occurring throughoutAustralia, consistent with frameworks brought about via the National Forest Policy

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Statement, Regional Forest Agreements, and the Plantations 2020 Vision. Plantationstimulation via these frameworks have been initiated and aimed at addressing the nationaltrade imbalance in forest products through investment in export oriented processing of theresource.

In relation to conversion of native forest to plantations, as referenced in Section 4.2.1.1, thePermanent Native Forest Estate Policy within Tasmania provides a framework to ensuresignificant conservation values are protected from conversion activities. Any expansion inthe plantation estate is occurring within the framework that is implemented through theForest Practices system.

Conversion of native forests to plantations is limited within Tasmania as prescribed underthe Permanent Native Forest Estate Policy, recently updated under the Supplementary RFA(Community Forest Agreement) to ensure that Tasmania retains a minimum of 95% of thearea of native forest mapped in the RFA.

Of particular relevance to the social and community impacts of plantation development is arecent report “Socio-Economic impact of plantation forestry” researched by Jacki Schirmerfrom the Australian National University. This study has reviewed the socio-economic impactsof plantation development, with the theme of conclusions positive towards the coexistence ofplantation industries and rural communities.

4.2.4.3 No relevant impacts to be assessed and/or mitigated

As there will not be any significant change in the extent or nature of current levels of forestryoperations in Tasmania, there are no relevant environmental, social, economical andcommunity impacts to be assessed and/or mitigated.

The pulp mill project is a downstream processing initiative and is not based on any requiredchanges to forest access or intensification. It is based upon diverting resource which wouldotherwise have been exported in chip form to the pulp mill for further processing [furtherdetail on volumes of export redirection is contained within Section 4.2.14].

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Section 4.2.5 – Potential Tasmanian RFA Expiry

Given that the project life of the mill extends to 2039, and the RFA potentially expires in2017, this section sets out the principles, codes and practices which will be considered,incorporated and applied in undertaking forestry operations for the supply of pulpwood of alltypes and age classes on a sustainable yield basis between 2017 and 2039 if the RFAexpires.

4.2.5.1 Potential RFA expiry

The Tasmanian RFA remains in force until 8 November 2017, subject to its terms. The RFAprovides for the Australian and Tasmanian Governments to agree to extending its durationduring the third Five Yearly Review due in 2012 (see clauses 7 and 45 of the RFA).However, if the Australian and Tasmanian Governments cannot agree to extend the RFA, itwill expire in 2017.

4.2.5.2 Minimal impacts if RFA expires

Since the RFA came into force in 1997, a number of key statutory amendments have beenenacted and policy changes have been made in Tasmania to ensure that the Tasmanialegislative framework implements the RFA.

The RFA includes commitments for legislative and management system change to maintainand improve ecologically sustainable forest management, along with structural adjustmentsto assist in achieving these objectives. These commitments have now been given effectthrough the Tasmanian legislative and policy framework, and related management systems,for the conduct of forestry operations, and the protection of forests on private and public landwhich have demonstrated CAR Reserve values. This framework has been described ingreater detail at section 4.2.1.

Even in the unlikely event that the RFA is not renewed beyond 2017, Tasmania’senvironment protection, forestry and national parks and reserve legislation will continue tohave legal effect (until amended or revoked by the Tasmanian Parliament). All timbersourced from plantations and native forests for the pulp mill will comply with applicable laws,policies and codes which regulate the establishment, maintenance and harvesting of timber,whether before or after 2017 and regardless of whether or not the RFA is in force.

In addition, regardless of the regulatory framework that is in place after 2017, Gunns iscommitted to maintaining best practices and continuous improvement in sustainable forestmanagement, and to maintaining certification to AS/NZS ISO14001, the Australian ForestryStandard, and the Chain of Custody Standard (or the successors or future equivalents ofthose Standards).

On this basis, the principles and codes of practice which will be considered, incorporatedand applied in undertaking forestry operations for the supply of pulpwood to the mill into thefuture are as detailed in Section 4.2.1.1 Parts B and C.

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Section 4.2.6 – Likely Supply Zones for Sourcing Mill Resource

This section provides information about the likely supply zones (public and private sources)in Tasmania from which pulpwood of any type (native forest, hardwood and softwoodplantations) will be obtained over the projected life of the mill; and sets out the locations ofnative forests and plantations which are or are likely to be covered by relevant wood supplyagreements.

This section considers four key issues:

o the modelling process undertaken to determine resource availability (section 4.2.6.1);o the sources of pulpwood availability within Tasmania – input data for Gunns

Pulpwood Resource Modelling (section 4.2.6.2);o the total predicted pulpwood availability within Tasmania over the life of the pulp mill

(section 4.2.6.3); ando the anticipated source of timber for the pulp mill (section 4.2.6.4).

Information about existing or potential wood supply agreements are set out in Section4.2.11.

4.2.6.1 - Resource Modelling Process

4.2.6.1.1 - Introduction

Gunns Limited has conducted resource modelling to forecast total pulpwood availability(predicted to be available to Gunns) within Tasmania over the life of the project. A range ofresource input data and assumptions have been used to conduct this resource modelling, asdetailed through this Section.

Gunns Resource Management (and subsequent processing of that resource) currentlyoccurs within three operational catchments; the North-West (woodchip processingoperations at Hampshire – south of Ridgley), the North-East (woodchip processingoperations at Tamar), and the South-East (woodchip processing operations at Triabunna).Subsequent detail in this Section will refer to pulpwood resource origin from these notionalregions, which are geographically located as per Figure 4.2.6.6.

Outputs from the resource modelling process undertaken by Gunns is referenced throughthis Section and IIS as “Gunns Pulpwood Resource Modelling”. Gunns Pulpwood ResourceModelling has included all pulpwood supply types, specifically native forests, and hardwoodand softwood plantations.

4.2.6.1.2 - Forest Modelling Process

The Woodstock Forest Modelling System (computer software developed by Remsoft Inc.)has been used by Gunns as a strategic planning tool to model wood flows from the forecastforest resource (available to Gunns) within Tasmania

This planning tool has modelled wood flows from resource supply categories to Gunnspulpwood processing sites around Tasmania (Hampshire, Tamar and Triabunna).

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A range of input data on each of these resource supply categories including forest inventory,Geographic Information System (GIS) resource location information, and projected woodflowvariables has been used to determine resource availability geographically over the life of theproject.

Derivation of input data to facilitate the modelling process is described further in Section4.2.6.2.

Figure 4.2.6.1 – Notional Resource Management Catchments [Source: Gunns GeographicInformation Systems]

Note that, due to the long-term nature of the project (till 2039) and the applicability of makingprojections on future available forest resource over this time period, outputs of the modellingprocess contained within this Pulpwood Supply Chapter have referenced differing timeranges for forward projections. The assumption should be made that no fundamental changeis occurring in relation to output data post the referenced time range through to 2039.

4.2.6.1.3 - Verification of Forest Modelling

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Jaakko Poyry Consulting have conducted an independent review of the forest modellingprocesses undertaken by Gunns Limited which included assessment of resource availabilityassumptions, Gunns Limited Geographic Information Systems (GIS) and resourcemanagement systems, Gunns Limited inventory and forest growth assumptions, and qualityand cost information relating to the transport of the available resource.

This study has validated the data outputs originating from Gunns Pulpwood ResourceModelling used in this Chapter of the IIS.

4.2.6.2 - Input Data : Sources of Pulpwood in Tasmania

Sources of pulpwood in Tasmania available to Gunns, and available as resource for thepulpmill, can be categorised into the following four categories;

A. Gunns Owned or Managed resourceB. Private Property resourceC. Crown resource managed by Forestry TasmaniaD. Sawmill Residues

Background on each of these resource supply types across Tasmania, and derivation ofinput data to be used in Gunns Pulpwood Resource Modelling is now discussed in moredetail;

A. Gunns Owned or Managed Forests

As discussed in Section 4.2.1, the areas of forests owned or managed by Gunns occupy avariety of land tenure arrangements including Gunns own freehold, other private freeholdland and State Forest land.

As at December 31st 2005, Gunns owned 188,686 ha of freehold land in Tasmania and inaddition manages approximately 61,230 ha of private and crown land, for a total of249,916ha under Company ownership and management. Gunns forest management isundertaken in three geographic regions of the State based around existing woodchip mills atHampshire, Bell Bay and Triabunna. Gunns Owned or Managed Forest resource location isdemonstrated in Figure 4.2.6.2.

Of the above mentioned land holding at December 31st 2005, 111,117ha are managed ashardwood/softwood plantations, 70,459ha are managed as productive native forests, withthe balance consisting of areas managed for reservation for social and environmentalvalues, inaccessible or non-commercial areas, or infrastructure needs.

Gunns maintains an extensive Geographic Information System (GIS) in order to manage itsOwned or Managed Resource. This GIS is a digital mapping system that allows the spatial(ie. location) capture of data and associated attributes for that spatial feature.

Attribute data relating to the Gunns Owned or Managed Resource has been extracted fromthis GIS to allow forest modelling to occur. Based on growth assumptions inherent within theGIS, modelling entails simulation of growth, harvest, and regrowth of the resource in order topredict potential pulpwood outputs into the future.

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Figure 4.2.6.2 – Gunns Owned or Managed Resource Location as at December 31, 2005 [Source:Gunns Geographic Information Systems]

Into the future, Gunns expects to continue to acquire land for conducting forestry operations,as per its current business strategy, with an intention of increasing the owned or managedplantation estate to around the 150,000ha (softwood and hardwood plantations). This willsustain resource requirements into the future, and is consistent with the inherent decline innative forest resource harvest levels over this time period [as determined via GunnsPulpwood Resource Modelling].

Expectations of this plantation estate have been built into model input assumptions forGunns Owned or Managed Resource.

As indicated in Section 4.2.4, it should be noted that no intensification of forestry operationsare required or envisaged as a result of the pulp mill.

B. Private Property Resource

Private forests are an important source of wood supply to Gunns existing facilities and willremain so into the future. As detailed in Section 4.2.1, Gunns currently sources bothplantation and native forest pulpwood resource from across Tasmania to its processing sites,paying a market royalty for this pulpwood.

Private Forests Tasmania has supplied base woodflow and area data (as demonstrated inFigure 4.2.6.3) on the private forest resource (both plantation and native forest) for usewithin the Gunns Pulpwood Resource Modelling. This base data has been formulated by

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Private Forests Tasmania from air photo analyses, GIS analysis, landowner intent surveys,previous experience and yield analyses. Indications of the potential statewide Tasmanianhardwood resource are contained in Figure 4.2.6.4 – note that Figure 4.2.6.2 excludesexpected woodflows from Gunns Owned or Managed sources.

Figure 4.2.6.3 – Privately Owned Resource Location [Source: Private Forests Tasmania]

Figure 4.2.6.4 – Tasmanian Private Hardwood Log Supply Estimates [Source: Private ForestsTasmania – excluding expected woodflows from Gunns Owned or Managed Sources]

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C. State Forest Resource

Forestry Tasmania is a Government Business Enterprise (GBE) with a board of directors.The GBE manages around 1.5 million hectares of public land (Figure 4.2.6.5) of whicharound 1 million hectares of natural forests are available for multiple use, including woodproduction.

Within the State Forest resource as at June 30, 2005 there are around 100,000ha ofplantations on State Forest, made up of 54,000ha of softwood and 45,000has of hardwood(including Joint Ventures and Forestry Rights).

As detailed in Section 4.2.1, Forestry Tasmania currently supplies both plantation and nativeforest pulpwood resource to Gunns under various contractual arrangements. Thesustainability of wood supply from State Forest is outlined in regular reviews published byForestry Tasmania, most recently in 2005 (Towards a New Silviculture in Tasmanian PublicOldgrowth Forests: Final Advice to the Tasmanian Government, April 2005).

Forestry Tasmania has provided a schedule of future volume predictions that will beavailable to the Pulp Mill project (and Gunns export chip businesses) under a proposed 20-year agreement. This agreement is expected to be finalised in the first half of 2006. Thisprojected data has been used within the Gunns Pulpwood Resource Modelling.

D. Sawmill Residues

Gunns currently obtains chips from sawmill residues from its own sawmills and other mills inTasmania. Currently this augments the supply of Gunns export pulpwood but a componentof this statewide supply is planned to be redirected to the proposed pulp mill.

Currently on a statewide basis Gunns export chip sites process ~350,000 green metrictonnes of sawmill residues per annum. This resource has been projected into the future, withdetail in relation to the specifics of the anticipated supply to the mill outlined in Section 4.2.9.

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Figure 4.2.6.5 – Public Land Classification and State Forests after the Supplementary RFA May 2005[Source : Community Forest Agreement 2005]

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4.2.6.3 - Total Projected Pulpwood Availability within Tasmania

Previously stated modelling techniques, along with input data and assumptions on theresource categories described in Parts A-D of Part 4.2.6.2, has been utilised to project thetotal Tasmanian resource predicted to be available to Gunns to confirm wood availability andeconomics of the project. This process is referred to as Gunns Pulpwood ResourceModelling.

Gunns Pulpwood Resource Modelling has projected a total available resource over the life ofthe project in the order of ~5 to 7 million GMT (log equivalent).

This total Tasmanian pulpwood resource is demonstrated in Figure 4.2.6.6, along with ahistorical actual reflection of previous Gunns sales volumes (in log equivalent GMt).

Figure 4.2.6.6 – Gunns Business Volumes Actual and Forecasts by Resource Ownership [Source:Gunns Pulpwood Resource Modelling and Sales Data]

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pulpmill requirement 3.2-4.0 million GMt

The projected annual supply capacity of the collective resource available to Gunns withineach notional forest management region is illustrated in Figure 4.2.6.7.

As demonstrated, the projected available pulpwood resource in North-Eastern Tasmania(the existing catchment for the current Gunns export woodchip facilities at Bell Bay) couldalmost satisfy pulp mill requirements into the future.

A number of strategies in relation to resource supply have been employed by Gunns Limitedto determine the projected feasibility of the pulp mill. These scenarios have employedprevious mentioned modelling techniques to determine anticipated combinations of resourcesupply from the available Tasmanian resource to the pulp mill and Gunns export chipfacilities around Tasmania.Figure 4.2.6.7 – Projected Tasmanian Pulpwood Availability to Gunns by Region [Source: GunnsPulpwood Resource Modelling]

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Also analysed (with implications also being specifically represented in Section xxx-Transport) is a plantation only strategy. As reflected in Figure 4.2.6.8, on the basis of themodelled Tasmanian resource available to Gunns it is theoretically possible (fromapproximately 2017) to feed the mill with 100 % plantation wood. This scenario is notnecessarily an anticipated strategy, but is further explored in Section 4.2.13 and is modelledwithin the transport section of the IIS.

Figure 4.2.6.8 – Projected Tasmanian Pulpwood Availability by Type

The ultimate weighting of the resource mix will depend on the availability and cost ofprojected resource categories into the future. It is planned to annually monitor and

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optimise the wood intake regularly dependant on the quality, quantity and cost ofwood from various sources and the commercial aspects of the sale of pulp.

Hence, the specific scenario that is further explored within this section (4.2.6.4) is ananticipated strategy for redirection of available Tasmanian Gunns resource to the pulp mill,based on assumptions reflecting the current financial and operating framework. Details of aplantation only strategy are also provided.

4.2.6.4 - Anticipated Source of Pulpwood for the Pulpmill

This section discusses the origin of pulpwood feedstock for the pulp mill, which have beenmodelled on the basis of two scenarios – Gunns’ preferred scenario of sourcing timber fromplantations and native forests, and an alternative scenario of sourcing timber fromplantations only.

A - Anticipated Strategy

Gunns’ anticipated strategy is to source a mix of timber feedstock from plantations andnative forests, on private and public land.

The total supply requirements of the pulpmill range from ~3.2 million green metric tonnes ofpulpwood at startup to ~4.0 million green metric tonnes over the project life.

Indications of the likely sources of pulpwood resource to supply the mill including publicsources (Crown resource from Forestry Tasmania) and private sources (Gunns managedresource and Private Property resource), along with sawmill residues, are detailed in Figure4.2.6.9. Demonstration of the anticipated variance of these source contributions specific tothe pulp mill over for the period 2008 through 2032 (ie. 25 years) is provided.

Figure 4.2.6.9 – Anticipated Pulp Mill Resource Volumes by Source [Source: Gunns PulpwoodResource Modelling]

Figure 4.2.6.10 depicts the relative contribution of wood from each forest managementregion within Tasmania to the pulp mill, by reference to native forest and plantation, over a

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25 year time period. This Figure indicates that ~70% of total pulpwood supply to the mill isanticipated to originate from native forests in the North-Eastern region when the pulp millcommences operations, but about 10 years later this will reduce to less than ~20%.As the plantation estate within Tasmania matures, over the same period the relativecontribution of North-Eastern Plantation will increase from 20% to 50%.

Figure 4.2.6.10 – Anticipated Contribution to Total Pulp Mill Supply by Regional Supply [Source:Gunns Pulpwood Resource Modelling]

As a further perspective of the contribution of plantation and native forest supply in aregional context over the life of the project, an average annual contribution (averaged overthe 25 year time period 2008-2032) is demonstrated in Figure 4.2.6.11.

Figure 4.2.6.11 – Total 25 year Anticipated Analysis by Regional Supply [Source: Gunns PulpwoodResource Modelling]

Hence, likely supply to the mill over a 25 year period will consist of ~65% plantationresource. Further, it is anticipated that, over a 25 year time span, ~75% of the resource

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requirements (plantation and native forest) for the mill will be sourced from the North-Easterncatchment of Tasmania.

To enable transport modelling to occur, resource supply availability has been further brokendown within regions to a total of 35 notional ‘catchments’ within Tasmania. Supply fromthese 35 catchments is further analysed in Chapter xxx – Transport xxx.

B - Plantation Preference Strategy

Outputs as described within this section relate to a Plantation Preference Strategy (ie. theramp up to 100% plantation input to the mill as soon as sufficient Tasmanian plantationresource is available) utilising any projected plantation resource available to Gunns fromacross Tasmania. This strategy is explored to give an indication of the possibility andimplications of the supply of plantation pulpwood for the project.

Note that under a plantation strategy there is insufficient plantation availability withinTasmania during the initial stages of the project to source sufficient quantities of plantationwood to enable total supply to the mill. Under a Plantation Preference strategy, plantationsupply ramps up to ~80% after 5 years, and ~100% after 10 years of the projectcommencement.

Indications of the likely sources of pulpwood resource under a Plantation Only Strategy tosupply the mill including public sources (Crown resource from Forestry Tasmania) andprivate sources (Gunns managed resource and Private Property resource), along withsawmill residues, are detailed in Figure 4.2.6.12. Demonstration of the variance of thesesource contributions specific to the pulp mill over the period 2008 through 2032 (ie. 25 years)is provided.

Figure 4.2.6.12 – Plantation Preference Pulp Mill Resource Volumes by Source [Source: GunnsPulpwood Resource Modelling]

In terms of the relative contribution from each forest management region within Tasmaniaunder a Plantation Only Strategy (and by native forest and plantation), Figure 4.2.6.13

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demonstrates how these supply categories contribute to total supply over a 25 year timeperiod. For example, it is anticipated that ~65% of total pulpwood resource supply to the mill

Figure 4.2.6.13 – Plantation Strategy Contribution to Total Pulp Mill Supply by Regional Supply[Source: Gunns Pulpwood Resource Modelling]

will originate from North-Eastern region Native Forests at the commencement of the pulpmill, however this will have dropped to ~0% approximately 5 years after projectcommencement, consistent with the maturation and preference of the plantation estatewithin Tasmania under this strategy.

Note that by 2017 under a plantation preference strategy it is predicted that the mill couldoperate with 100% plantation pulpwood resource supply, but to achieve this there is a heavyreliance on sourcing of resource from outside of the North-East catchment, with resultanttransport cost and environmental impacts. Implications of this supply on the transportnetwork are further analysed in the Transport analysis in this IIS.

As a further perspective of the contribution of plantation and native forest supply from aregional perspective over the life of the project under a Plantation Only Strategy, an averageannual contribution (averaged over the 25 year time period 2008-2032) is demonstrated inFigure 4.2.6.14.

Figure 4.2.6.14 – Total 25 year Plantation Only Strategy Analysis by Regional Supply

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Hence, likely supply to the mill over a 25 year project life under a plantation preferencestrategy will consist of ~84% plantation resource. Further, it is anticipated that, over a 25year time span, ~56% of the resource requirements (plantation and native forest) for the millwill be sourced from the North-East catchment of Tasmania.

To enable transport modelling to occur, resource supply availability has been further brokendown within regions to a total of 35 notional ‘catchments’ within Tasmania. Supply fromthese 35 catchments is further analysed in the Transport analysis in this IIS.

C - Comparatives between Anticipated and Plantation Preference Strategies

Figure 4.2.6.15 is provided as a comparison of resource supply zone implications andcontributions of native forest and plantation supply to the proposed mill under the anticipatedand plantation preference strategies presented.

Figure 4.2.6.15 – Comparison of Anticipated and Plantation Strategies (25 year supply)

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Resource Details Anticipated Strategy Plantation Strategy

North-East Native 30% 12%North-East Plantation 45% 44%North-West Native 0% 0%North-West Plantation 14% 28%South-East Native 6% 4%South-East Plantation 5% 12%

Native Forest Summary 36% 16%Plantation Summary 64% 84%

North-East Summary 75% 56%North-West Summary 14% 28%South-East Summary 11% 16%

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The ultimate weighting of the resource mix will depend on commercial aspects such as theavailability and cost of projected resource categories into the future and export markets forwoodchips and pulpwood. Gunns will annually monitor and optimise the wood intake acrossits Tasmanian pulpwood processing sites regularly dependant on the quality, quantity andcost of the wood from various sources and locations.

It is envisaged the total Tasmanian pulpwood resource (as predicted to be available toGunns and detailed in 4.2.6.1) will be processed, either at an export chip facility or thepulpmill. Analysis as presented in Sections 4.2.6.3(A) and 4.2.6.3(B) is simply looking to givean indication of which of that available resource is projected for downstream processing viathe pulpmill, with the residual resource planned for processing and exporting as woodchipsfrom existing processing facilities.

It should be noted that further Sections within this Pulpwood Supply Chapter 4.2 relate tooutputs from the “Anticipated Strategy” as described and detailed in Section 4.2.6.3(A).

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Section 4.2.7 – Details of Imports of Pulpwood from non-Tasmanian sources

Gunns does not plan to source any timber for the pulp mill from interstate or internationalsources, nor can this ever be envisaged.

All anticipated supply for the mill is of a Tasmanian origin and as reflected in correspondingSections of 4.2, particularly 4.2.6.

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Section 4.2.8 – Type and Species of Pulpwood required for the project

The tree species that are proposed to be utilised as feedstock for the pulp mill are expectedto comprise of all current merchantable native forest species within Tasmania (as containedin Appendix xxx), Eucalyptus nitens (Shining Gum), Eucalyptus globulus (Tasmanian BlueGum), and Pinus radiata (Monterey Pine).

The anticipated contribution of these species over a 25 year time span 2008-2032 isdepicted in Figure 4.2.8.1.

Figure 4.2.8.1 – Likely Contribution over time of Pulpwood Species to Pulpmill [Source: GunnsPulpmill Resource Modelling]

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Plantation Eucalypt Species

Plantation Pine Species

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Section 4.2.9 – Quantity of Pulpwood required for the Project

This section sets out the quantity of pulpwood (including the ratios of softwood andhardwood) required for the project.

The annual quantity of pulplog intake required over the 25 year time span 2008-2032(measured in green metric tonnes per annum), along with the intake of sawmill residues(reflected as log equivalent green metric tonnes for comparative purposes) is shown inFigure 4.2.9.1.

Pulplog intake is estimated to vary between ~3.0 million tonnes and ~3.75 million tonnesduring the 25 year time span, whilst sawmill residue supply to the mill is anticipated to varybetween ~0.2 and 0.25 million tonnes. Total intake of pulpwood and residues to the mill (forpulp production) is hence anticipated to be in the range of 3.2 to 4.0 million green metrictonnes per annum (log equivalent tonnes).

Figure 4.2.9.1 – Quantity of Wood Product Supply for Pulp Production [Source: Gunns PulpwoodResource Modelling]

The forecasts of relative use softwood and hardwood species in the pulp mill are analysed insection 4.2.8 and depicted in Figure 4.2.8.1

Contributions of softwood plantations are anticipated to vary between 0-10% [0 toapproximately 400,000 tonnes], hardwood plantations between 20-70% [approximately600,000 tonnes to 2.8 million tonnes(ie. total plantations between 20-80%), and nativeforests between 20-80% [approximately 600,000 tonnes to 2.8 million tonnes] over the life ofthe project.

The considerable shift from native forests towards plantations over the life of the projectreflects the inherent maturation of the Tasmanian plantation resource. This will be occurringover the first 10 years or so of the project with a predicted plateau of the sustainable harvestyield from the plantation estate occurring in approximately 2018.

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Section 4.2.10 – Indication of the proportion of young to older wood

This section provides a broad indication of the proportion of young and old wood which islikely to form the feedstock for the pulpmill.

Plantation sources for the mill will likely be harvested at less than 30 years of age, whilstnative forest resource will be harvested at greater than 30 years of age. No RFA defined oldgrowth pulpwood will be used within the mill. Native forest wood harvesting into the futurewill trend towards younger harvest ages as the proportions of regrowth wood harvestingincrease. Accordingly, ratios and proportions of supply presented in previous sections 4.2.8and 4.2.9 are directly relevant as an indication of younger to older wood.

Engineering aspects of mill design have utilised resource age and pulp yield information(and the changing nature of those variables over the project life) in determination of all milloutputs in corresponding sections of this IIS.

As explained in Section ## of the IIS, Gunns will ensure that variations in wood age will notcause it to breach the Environmental Emission Limit Guidelines.

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Section 4.2.11 – Arrangements in place to secure sufficient supply of resource

As detailed in previous sections, in terms of quantity the pulp mill will process ~3.2 to 4.0million Green Metric Tonnes (GMt) of pulpwood per year. As demonstrated in Figure4.2.11.1, this is substantially less than the 5.3 to 6.7 million GMt of pulpwood forecast to beavailable to Gunns in Tasmania annually over the life of the mill, and the 4.5 to 5.0 GMtprocessed by Gunns annually over the past three years.

Figure 4.2.11.1 – Gunns Available Pulpwood Volumes Actual and Predicted by Supply Category[Source: Gunns Pulpwood Resource Modelling]

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As detailed in Section 4.2.1.1, the sources of pulpwood are Gunns owned or managedforests, sawmill residues, public forest resource supplied by Forestry Tasmania, and privateproperty resource.

As demonstrated in Figure 4.2.11.1, Gunns will over time potentially own or control a largecomponent of the wood supply to the pulp mill and will have two other major sources(Forestry Tasmania and Private Property) to make up the difference.

Gunns employs systematic inventory and audit procedures of its forest estate (as detailed inSection 4.2.1.1, forest management practices of Gunns are certified to the AustralianForestry Standard) to assess and model the standing volume in its native forest andplantation forest resource under management. Yield analysis is conducted of harvestedresource to further calibrate forest resource information. There is little or no inherent risk inGunns Owned or Managed Resource yielding a large component of the resource to the pulpmill.

Supply of private property resource as detailed in Section 4.2.1.1 is carried out by Gunnsstaff who are dedicated to the task of securing private native forests and plantations, with thesupply of plantations projected to increase into the future. Private Forests Tasmaniaconducts a five-yearly Resource Review data to predict private forest resource availability

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into the future. This data includes a provision for landowner intent and environmentaldiscounts.

Arrangements for supply of the private forest resource will continue on an as needs basis,with previous experience and future predictions of resource availability identifying noindication of difficulty in a secure supply of pulpwood (both hardwood and softwood) to beavailable to the pulpmill over the project life.

As detailed in Section 4.2.1, Gunns have been provided with initial volume estimates as partof an intended long-term supply agreement with Forestry Tasmania from the Public forestresource. Projections on future resource availability, and the long term sustainable yieldprovisions on public forests (further analysed under Section 4.2.13) demonstrate a securesupply of potentially available pulpwood resource from Public forests within Tasmania.

As the wood requirement for the pulp mill is significantly less than the total harvest inTasmania any unforeseen reductions in wood availability from a particular source meansthat it is likely another source will be found for pulpmill supply with a resultant reduction inwood processed for export chips.

Planning and sourcing the harvest and delivery of 3.2. to 4.0 million GMt of pulpwood for themill on an annual basis will be a logistical exercise for Gunns. Currently Gunns has beenprocessing 4.5 to 5.0 million GMt of pulpwood per year through three separate export ports.This project will entail the redirection of a component of this resource to the pulp mill forfurther processing.

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Section 4.2.12 – Variation of security through the project life

As previously discussed, the extent to which the pulp mill is expected to rely upon timberprovided by private landowners and Forestry Tasmania is predicted to decrease during thelife of the project.

On this basis, and given that no constraints on the supply of timber from private landownersand Forestry Tasmania are predicted (section 4.2.11), there are no expected variances insecurity of pulpwood resource over the life of the pulp mill.

Furthermore, and as discussed at Sections 4.2.1and 4.2.5, the Regional Forest Agreementand Tasmanian regulatory framework has established a regime which encourages intensiveforest management initiatives including:

o the forecast expansion of timber plantations, which is encouraged by the nationalpolicy “Plantations for Australia: The 2020 Vision” and the RFA (clause 74 andAttachment 12), and facilitated by Private Forests Tasmania;

o the expansion of the level of intensive management of hardwood plantations onpublic land;

o achieving sustainable yield targets for forests.

This framework provided for by the Tasmanian Regional Forest Agreement has establishedsecurity into the future of available pulpwood resource for the project.

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Section 4.2.13 – Maintenance of a sustainable yield

This section provides information about how the supply of pulpwood to the mill will bemaintained on a sustainable yield basis, in line with the sustainability indicators provided forunder the RFA.

A) Gunns Owned or Managed Resource

Gunns owned or managed resource is managed on a sustainable yield basis via applicationof a range of principles. Gunns Sustainable Management Policy (as found in Appendix xxx)confirms the Company principles in relation to Sustainable Forest Management. Thisincludes elements in relation to Productive Capacity with specific provisions for managementof Gunns resource on a sustainable yield basis. These processes are independently auditedwithin Gunns against the Australian Forestry Standard.

Compliance with the Forest Practices Act 1985 ensures elements in relation to regenerationmust be addressed post harvesting to ensure future resource availability in perpetuity.

Future Gunns Owned or Managed resource volumes as predicted by Gunns PulpwoodResource Modelling have been conducted on the basis of a ‘non declining yield’. Indetermination of future resource volumes and coupe scheduling, this modelling constraintensures that annual yield from the estate must rise each year.

B) Forestry Tasmania (Public) Resource

As detailed in Section 4.2.1.1, the Tasmanian Regional Forest Agreement provided for thedevelopment within Tasmania of a sustainable yield approach for the management of publicforests in order to guarantee resource availability into the future. This sustainable yield,based around a minimum annual supply from State Forest of 300,000 cubic metres of highquality eucalypt sawlog and veneer log is reviewed and reported by Forestry Tasmaniaevery five years to ensure a sustainable resource supply from public forests in perpetuity.Pulpwood supply, as an arising from this sustainable supply of sawlogs, varies over time.

Further detail on the sustainable yield of the Public resource can be made by reference to“Forestry Tasmania’s Sustainable High Quality Eucalypt Supply from Tasmanian StateForest, 2002” , “Final Advice to Tasmanian Government on Alternatives to ClearfallSilviculture on Public Land, 2005”, and ”Annual Forestry Tasmania SFM Reports”.

Compliance with the Forest Practices Act 1985 ensures elements in relation to regenerationmust be addressed post harvesting to ensure future resource availability in perpetuity.

C) Private Property Resource

Private Forests Tasmania conducts five-yearly reviews of the Private Forest Resource andreport estimates of future yield to help determine government policy to promote sustainableresource supply from Private Forests.

Compliance with the Forest Practices Act 1985 ensures elements in relation to regenerationmust be addressed post harvesting to facilitate future resource availability in perpetuity.

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At a broader level, it will be in Gunns commercial interests to ensure a long-term sustainableyield for pulpwood supply from all sources to the mill to ensure the project operates inperpetuity as a going concern.

Demonstration of projected resource volumes (along with calculations and assumptions) ona sustainable yield basis is reflected within Section 4.2.6, which also includes commentaryon an ‘all plantation’ strategy for supply to the mill.

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Section 4.2.14 – Quantity of pulpwood currently exported to be redirected

As detailed in previous sections within this chapter, this project entails the redirection of ~3.2to 4.0 million Green Metric Tonnes per annum to supply of pulpwood in the mill. This supplyis redirected from currently exported pulpwood as demonstrated in Figure 4.2.14.1.

Figure 4.2.14.1 – Gunns Available Pulpwood Volumes Actual and Predicted by Supply Category[Source: Gunns Pulpwood Resource Modelling]

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Appendix 4.2.1Main Legislation directing the implementation of sustainable

forest management in Tasmania

Agency Main Legislation PurposeForestry Tasmania Forestry Act 1920 Empower Forestry Tasmania with responsibility

for exclusive control and management of forestproducts and forest operations for State forest.

Forest Practices Authority Forest Practices Act 1985 Establishes the Forest Practices Code and ForestPractices System to provide for the sustainablemanagement of forest values on any land subjectto forest operations. Provides for theestablishment of Private Timber Reserves onprivate land to provide security of long termforestry use for landowners.

Department of PrimaryIndustries, Water andEnvironment

National Parks andReserves Management Act2002

Implement the reserve framework withinTasmania as set out under the Tasmanian RFA andthe CAR Reserve System, and restrict the use ofreserves for forestry or commercial activities.


EnvironmentalManagement and PollutionControl Act 1994

Establishes duty of care on everyone to prevent orminimise environmental harm.Defines potentially harmful activities requiringassessment and approval.Identifies notification requirements forenvironmental incidents.


Nature Conservation Act2002

Promotes conservation purposes in relation to theuse or development of land generally, and carriesor arranges for the carrying out of, research andother activities that appear to the Secretary to bedesirable in connection with the administration ofthis Act or the conservation of the fauna, flora orgeological diversity of Tasmania.


Land Use Planning andApproval Act 1993

Provides for land use planning and approvalsexpect for forest practices specially regulated bythe Forest Practices Act 1985.


Threatened SpeciesProtection Act 1995

To provide for the conservation and managementof scheduled threatened species of flora andfauna.

Department of Tourism,Parks, Heritage and the Arts

Aboriginal Relics Act 1975 To provide for the identification and protection ofall Aboriginal relics (sites).

Office of Aboriginal Affairs,Department of Premier andCabinet

Aboriginal Lands Act 1995 To promote reconciliation with the TasmanianAboriginal community by granting to Aboriginalpeople certain parcels of land of historic orcultural significance.

Department of Tourism,Parks, Heritage and the Arts

Historic Cultural HeritageAct 1995

To identify, assess and protect historic (postsettlement) cultural heritage.


Weed Management Act2000

Requires landowner to destroy, prevent breedingof, control, eradicate or reduce spread ofdesignated declared weeds depending on therequirement for listed weed species.


Agricultural and VeterinaryChemicals (Control of Use)Act 1995

Prevents restricted chemicals being used withouta permit, being registered under the AgVet Codeand having approved labelling in accordance withthe code.

Department of Infrastructure,Energy and Resources(Workplace StandardsTasmania)

Workplace Health andSafety Act 1995, WorkplaceHealth and SafetyRegulations 1998

Provides for the health and safety of personsemployed, engaged or affected by industry.

Department of Health andHuman Services (TasmaniaFire Service)

Fire Service Act 1979 Provides for the control and use of fire in theurban and rural environment.

For access to any of the legislation above, the following Internet address should be used:www.thelaw.tas.gov.au

pulpwood supply - svc028.wic009tp.server-web.com

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