Publicly
owned commercial native forests as operated by Sustainable Timber Tasmania P/L
(STT) are perpetual assets managed for the benefit of future generations.
Yet when STT
values its forests every year it values the estate as a single rotation crop.
Which is a patently absurd assumption for a perpetual asset where replanting is
mandatory.
This is the loophole that allows STT to pretend to be sustainable. Replanting costs are excluded when determining the expected net proceeds which forms the basis for a forest’s value.
Valuation of
forests is covered by accounting standard AASB 141 Agriculture. Trees are
included by virtue of them being biological assets which produce timber (an
agricultural product). Para 4 lists examples of biological assets to which the
standard applies. Plantation forests are one example. Native forests are not specifically
listed as an example, but it is clear native forest trees are biological assets
and STT is a for-profit business, hence AASB 141 applies.
Everyone,
virtually without exception recognises the value of native forests are far
greater value than mere timber values. There are many others – biodiversity,
carbon storage, water management, climate mitigation, nutrient recycling, and
erosion control. To date valuers, while acknowledging these values have made
little progress in including these values when assessing the sustainability of
a native forest. In the case of STT, it is given a convenient leave pass on
this issue because its mandate as per the Forest Management Act 2013 doesn’t
specifically require it to have regard to other forest values. Its statutory
role is essentially to supply minimum quantities of timber as specified in the
Regulations. Any other non-timber losses are considered sunk costs, costs that don’t
need to be taken into account when assessing the profit or losses from forest
operations.
A valuer
starts with the premise a forest estate comprises three components land,
improvements such as roads, and trees. For accounting purposes, they are three
separate assets, but only trees are biological assets. Land and land
improvements both fall into the category Property Plant and Equipment.
Changes in
the value of biological assets are brought to account in the profit and loss
statement. That’s why the way forests are valued has a huge bearing as to
whether an entity makes a profit or loss from forest operations. An entity
might spend more on its forest estate, to plant more trees say, but it’s the movements
in the value of a forest over a year apart from the additional spending, which
determines the amount that impacts the P&L statement.
Roads are
treated as items of plant. Any spending adds to the balance sheet Depreciation
each year reduces the balance and becomes an expense in the P&L.
Land is also
a balance sheet item. However it is not depreciated.
The
accounting treatment of land and roads are governed by different accounting
standards.
Both roads
and trees are obviously attached to the underlying land. It is very difficult,
indeed impossible, to value the three components separately when combined they constitute
a perpetual native forest. There’s little or no market information for the
assets separately. Hence the accepted valuation approach to derive a fair value
for biological assets is to value the forest estate as one before deducting a
fair value for land and roads.
The only
recognised approach to establishing a fair value for a forest estate is to determine
the net proceeds from the forest and convert them into a lump sum amount in
current dollars.
When STT
assesses which costs to include when valuing native forests it uses a loose
interpretation of AASB 141 para 25 which says:
An entity does not include any
cash flows for financing the assets, taxation, or re-establishing biological assets after harvest (for
example, the cost of replanting trees in a plantation forest after harvest).
The para
specifically mentions a plantation forest, a crop in other words. But STT takes that to cover native forests as
well. A long bow one would suggest. If that was the intent the word ‘plantation’
wouldn’t have been included. AASB 141 covers all biological assets, of which
crops are only a subset. The value of a crop is determined without having to
bother with what happens after harvest. There are lots of crops that span more
than a year and are followed by a completely different crop. It is not unreasonable
to use the same rules for valuing a tree plantation as applies to all crops.
What happens post-harvest shouldn’t be a consideration. That is not to say post-harvest
costs shouldn’t be recorded, only they needn’t be considered when valuing a
crop.
But a native
forest isn’t simply a crop, it’s a perpetual ecosystem. After ignoring most of the values which
comprise such an ecosystem, the valuer settles on a narrow view of a forest
estate comprising land, roads and trees before proceeding. But at least the valuer’s
underlying assumption is that a forest estate is a perpetual asset.
This
pre-empts the question as to what period of time needs to be considered when
valuing a native forest. Foresters and valuers have pondered this question, and
to remove any doubts have issued guidelines [1]
discussing what to include over what period. They have said a valuation:
“……should use the expected net cash flows over the specified
planning horizon (generally
not less than a full rotation and the transition to the next in the case of a
sustainable going concern).”
In the case
of a sustainable going concern net harvest proceeds should include the
costs to transition to the next rotation. That must include replanting.
Logically it should as it’s a cost of maintaining a perpetual forest.
When
discussing what discount rate to use to convert future cash flows to a present
value the following appears:
“The choice of discount rate has traditionally been one of
the most controversial elements in the valuation of forest estates and plantation estates.”
Note the
phrase forest estates and
plantation estates. Professional foresters and valuers distinguish
between the two. STT doesn’t.
Just to
pause for a moment to review the above. The way forests are valued is to value
them as one, and then split the total value among the 3x components, land,
roads and trees (biological assets). The matter we’ve addressed thus far is what
expenses should be included in determining net proceeds from a native forest
which then forms the basis for assessing its value.
Arguably
replanting cost should be included.
The issue that
now arises is should road costs and a return on the land itself be included. STT’s
Notes to financial statements are skimpier each year. Annual Reports
before Forestry Tasmania renamed itself
to STT in 2018/19 are no longer available on line. In 2014/15 the extensive
note covering the valuation of the forest estate[2]
said:
“…… an imputed land rental charge is not included on the
basis that the land value recognised in the Statement of Financial Position is
deducted from the valuation and recorded separately.”
The only
trouble is land is given a zero value. Only trees and roads have value
according to STT.
There’s a
touch of convenient circularity to the proposition that imputed land rents aren’t
included because land is given a separate value, which we later find out to be
zero.
The latest STT
Annual Report (2022) is much briefer when discussing valuing the forest estate.
At page 48 it says:
The Group does not hold freehold title over the majority of
PTPZ land but is deemed to control the land pursuant to the Forest Management
Act (2013). Any value attributed to land is therefore discounted to a nil
value.
Any value attributed
to the land is therefore nil is a non-sequitur. STT may not own the land, but
it controls it, therefore it’s an asset of STT for accounting purposes. The
reason STT is able to give land a nil value is because the land can only be
used to produce timber. The Crown as owner doesn’t expect a return, it only
requires STT to supply timber as per the Regulations.
Applying the same logic to road expenditures means roading costs incurred in harvesting operations aren’t included as expenses when calculating net harvest proceeds, because roads valued separately are deducted from the value of the forest estate when deriving a value for the trees.
The
following is a table showing the various components of the value of STT’s
forest estate since 2010.
Just to explain
a little further. From 2010 land was given a zero value and is not included in the chart. In the 2013/14 year for instance the forest estate was valued
at $171 million. Land was given a zero value, the written down value of roads
was $85 million which left the trees with a value of $86 million. Forest roads
were worth as much as the trees, and both were attached to land worth zero. It
was Monty Python stuff.
STT had to
come up with another way of valuing roads. As can be seen in years before 2016 roads
were a large proportion of a forest’s value and getting larger as the value of forests
fell in $ terms. At that stage roads were valued at cost less depreciation. It was
decided to change the method of valuing roads. Henceforth they would be valued according
to the toll income received for those roads. In 2015/16 roads were given a
value of $9 million which meant more of the forest estate, which was valued the
same way, was allocated to trees. The value of roads since 2016 doesn’t vary
much from year to year.
Back in 2011
the Auditor General wrote a detailed report on the financial and economic
performance of STT, then called Forestry Tasmania. One of his comments was[3]:
Without stronger financial performance, investment in roads
and plantations over the past 15 years will not yield future benefits to
Forestry and arguably should be expensed rather than capitalised.
That’s an
accounting principle that’s still relevant. If roads aren’t going to yield
future benefits, they should be written off immediately. On past patterns future benefit are only possible
if replanting costs are excluded.
That will
mean roads, like land, will have a zero value.
Another
problem with the way valuers deduced the value of trees came to light in 2016. The value of the forest estate, and
hence the ensuing value of trees, included the value of forests yet to be
replanted. To overcome this very real problem, STT valued what it termed a
‘make good’ amount that needed to be spent to regenerate felled forests. This
in turn was deducted from the value of the forest estate, along with roads, to
value the current trees in the forest.
The above
chart shows the value of the make good asset from 2015 onwards. In 2022 for
example the forest estate was worth $200 million. Land was given a zero value,
roads $11 million, the make good asset was $9 million, which left $180 million
for trees. That’s how STT currently values its trees.
The
treatment of trees appears to show a conflicted approach. On one hand
identifying a make good asset suggests acknowledgment of the fact that a forest
is a perpetual asset, but to exclude the costs of maintaining that perpetual
asset (i.e. replanting) when assessing future net proceeds and hence the value
of a forest, is inconsistent.
Just to
reiterate how STT treats replanting costs and road costs for both accounting
purposes and for valuation purposes.
In the case
of replanting costs, they aren’t included when estimating net proceeds as part
of the valuation process. This means net proceeds and forest values are
overstated. Expenses incurred in any year are capitalised. Arguably replanting costs should form part of the
valuation process and should be expensed when incurred.
In the case
of roads, they are also excluded when estimating net proceeds. Net proceeds and
hence forest values are overstated. A value for roads is obtained independently
which is subtracted from the value of the forest estate together with the value
of the make good asset to arrive at a value for trees. Arguably roading
costs too should form part of the valuation process and should be expensed when
incurred.
Having eventually
determined a value for trees any movement in value from year to year is what
constitutes the major source of fluctuations in stated net profits. If roading and
replanting costs were expensed because they’re unlikely to yield future benefits,
STT like all other native forest operators would be showing big losses.
When one
looks at STT forest valuations over time its difficult to escape the conclusion
that when values are failing to back-up the frequent assertions about the
profitability of native forest operations, STT changes the valuation method.
When forest values kept falling, the first casualty was to dispense with the
need to allocate any value to land. Values kept falling until the roads were
worth as much as the trees. Another way was needed to value roads so trees could
be allocated a higher value. Then the reality dawned on someone that forests as
valued included areas yet to replanted following harvesting. For STT it’s been
a constant changing of the valuation method to fit the narrative.
Underpinning
STT valuations are two shaky premises:
·
STT
claims to adhere to accounting standard AASB 141. However, it values trees as
one would a planation crop rather than valuing a forest as a perpetual asset where
replanting and regeneration expenses are integral.
·
Land
is given a zero value which negates the need for a forest owner to allow for an
imputed return on land when valuing trees in a forest. As a corollary the costs
of non-timber losses are treated as sunk costs and are also ignored when assessing
net proceeds and hence the value of native forest harvesting.
The shaky foundations
and the dubious interpretation of accounting standards allows STT to continue
its pretence that native forest harvesting is a sustainable activity.
(The above was amended on 24th Oct 2023 with a revised chart on STT Forest Estate components and a subsequent revised comment on 2022 components)
[2]
2015/16 Annual Report page 94.
[3]
Page 139 Introduction (audit.tas.gov.au) The quote is from a draft of the Report in April
2009 which was included in the Final Report. FT signed up a new valuer in 2010 and the method of valuation subsequently
changed.
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