Rethink on genus exchange regulations

September 5, 2016

FSA Executive Director Michael Peter reports that after a 16-year long battle, the Department of Water and Sanitation (DWS) has finally agreed to suspend the draft Genus Exchange regulations.

Michael said that DWS had intended to use the regulations to force timber growers to apply for a licence – or an amendment to a licence – when switching genera, and more importantly, insist on a 30% reduction in plantation area, when switching from pine to eucalyptus.

FSA had for many years contested these requirements on a number of grounds:
• That DWS had agreed with FSA in 2000, to allow genus exchange without a reduction in area
• That there was no legal mechanism in the NWA to enable DWS to insist on a new authorisation for genera exchanges
• That the hydrological models being used by DWS appeared to be inaccurate for the level at which DWS intended using them i.e. at the level of a timber compartment
• That before any reduction could be insisted upon by DWS, they would have to first determine whether any increase in water use through genus exchange would not be offset by any of the following factors:
•• The voluntary withdrawal of 80 000ha by industry
•• The excessive water use estimates which DWS had used for plantations in the post-1972 permit era
•• The over-allocation and under-utilisation of water by other water users in a particular catchment where genus exchange was taking place (as this was the norm where verification and validation of water use has been done by DWS)
•• All of these issues had been agreed with DWS as needing to be addressed before DWS could proceed with the genus exchange regulations.

In the meantime FSA contracted Dr Mark Gush of the CSIR to analyse the draft genus exchange regulations, as they are based on hydrological calculations and tables which he produced for DWS many years ago.

Michael said that Dr Gush demonstrated that the DWS had made a fundamental error in their application of his hydrological models, overstating the area which would have to be reduced when switching between pine and eucalyptus.

Once the error had been pointed out, DWS summarily undertook to suspend the regulations, reports Michael.

DWS furthermore agreed that there may be no need for the regulations at all, if the report by Dr Gush substantiates his preliminary findings.

FSA undertook to send Dr Gush’s report to DWS once it is finalised and will be seeking formal commitment from DWS to abandon the genus exchange regulations.

Michael advised FSA members to continue to switch genera on at least a 1:1 area basis in the meantime, and that FSA would be sending out a revised position paper on genus exchange in due course.

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