Nora DevoeTitle: “Seeing
the forest for the trees: The future of the SILNA Lands”
Nora Devoe School of Forestry, University of Canterbury, PB 4800, Christchurch Email: n.devoe@fore.canterbury.ac.nz |
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Talk
Dr. Nora Devoe is originally from Honolulu, Hawaii. She has worked with tribal peoples in the
management of their forest resources in Latin America, Asia and the Pacific.
She came to New Zealand in 1995; she is Senior Lecturer, Indigenous Forestry,
School of Forestry, University of Canterbury.
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Abstract South Island Landless Natives Act 1906 (SILNA) lands are exempt from Forest Amendment Act 1993 (FAA) restrictions on forest harvesting, milling, and exporting. This exemption reflects the compensation status of SILNA lands. Successive governments have attempted to remove this exemption with no compensation for economic or rangatiratanga losses that the change in status would entail. This paper considers arguments by the Crown for removal of the exemption, and arguments by the owners for recognition of their Treaty and property rights. Article the First of the Treaty gives the Crown the mandate and responsibility to Act in the public interest. Retaining and stewarding indigenous forest is in the public interest. Article the Second gives the owners the right to decide whether and how to use their forests, and Article the Third protects their property rights. The express intention of Parliament in granting the SILNA lands was to provide for the owners, and a Crown policy that reduces the value of the lands would conflict with the purpose of the grant. The author concludes that the removal of the exemption to the FAA for SILNA lands would reduce their market value, and that the Treaty and the original South Island land purchase agreements obligate the Crown to compensate the owners for any devaluation. The author suggests that it is in the interests of all the parties to both maintain natural values of the forest and to use the lands to fulfil the original purpose of the grant. Owners should be able to choose strict reservation or management of their forests under the FAA and be compensated for the loss of the market value that this narrowing of options entails. |
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Talk
Tënä koutou ka maataa waka kua huihui mai nei. He mihi tino nui kia koutou katoa. Ko Ko’olau te mauka. Ko Waimalu te awa. Ko Kagti Amerika te iwi.
Ko Havaii te rohe. Ko O’ahu te
motu. Ko Honolulu tekaika tuturu. Ko Waitaha te kaika inainae. No reira. Tënä koutou tënä tatou katoa .
I was born on another Pacific Island and I have lived and worked on
many islands. I am a forest ecologist
and a professional forester. Five years
ago I immigrated to New Zealand.
Shortly after I arrived, one of my Mäori students at the University of
Canterbury led me into working with Mäori land owners and the management of
their forests and that’s how I got involved with the SILNA lands.
SILNA
stands for South Island Landless Natives Act 1906 and I am going to be talking
about some of the issues surrounding those lands. What I would like to do is share with you some of my observations
about the conflicts that surround the SILNA lands. I don’t have any personal stake in these lands. I have no whänau connection, no ownership
and no official responsibility for the lands, so I think that I can offer a bit
of an outsider’s perspective that might help us see a way through some of the
conflicting arguments that surround these lands.
The
lands were covered in forests when they were deeded in 1906. About 50% of the SILNA land still retains
some form of forest cover and about 30% of the SILNA lands are virgin forest. Now that contrasts very strongly with the
whole of Aotearoa which is about 24% forest covered and private non-Mäori land,
which is about 7% forest covered.
There
is a small block of SILNA lands up in the top half of Te Wai Pounamu in the
Marlborough Sounds. There is some in
the Catlins and on Rakiura, but most of the SILNA land is in Murihiku. When the lands were deeded in 1906, the
Crown passed fifty-seven-thousand and some hectares to Mäori who had no or
inadequate land.
In
1993 Parliament passed a Forest Amendment Act.
This piece of legislation was really aimed at the idea of sustainability
in the use of forests and it defined very specific limits on the use of forests
to that end. There are four exemptions
to the Forest Amendment Act. The first
is West Coast indigenous production forest, that was Timberlands West Coast
land which is just about history now.
The second is the SILNA land.
The third is DOC lands and the fourth is planted indigenous forests.
The
exemption for SILNA means that SILNA owners can manage their forests in ways
that other land owners cannot. They can
clear fell if the Resource Management Act doesn’t impede them. In some districts of New Zealand, any land
owner can clear fell forests for the conversion of forests to agricultural
land. However, the people covered under
the Forest Amendment Act cannot mill and sell the timber in the way that SILNA
land owners can. In short, that means
that SILNA land owners retain the right to mill, sell and export unsustainably
produced wood. This puts them in a
special category.
There
is a fair amount of objection to that special category and I have grouped that
objection into four larger categories. i.e.
(i) People who believe that forests should not be managed for anything
other than scenic values and habitat;
(ii) People who believe that indigenous forests could be managed for any
kind of product including timber but that the management should be consistent
with the Forests Amendment Act; (iii)
People who are already producing timber (so they’re within the second category
as well) but who feel that the exemption enjoyed by SILNA in some way
disadvantages them in the market place (because it is cheaper to produce timber
under a clear fell regime than it is under sustainable management). Interestingly, since the Timberlands timber
supply has gone out of the equation, I don’t hear that third category of
objections so much as I did three or four years ago and that’s because the
timber market has loosened up a bit.
And finally, (iv) there are people who say that SILNA clear felling
threatens New Zealand’s clean, green image and therefore poses a risk to
tourism and trade.
There
are people within Government who adopt the first position. Most of those people tend to be within the
Department of Conservation. This is
also the position espoused for example by Kevin Smith, the Conservation Forest
and Bird spokesman.
The
second position is probably most often associated with the Ministry of
Agriculture and Forestry who are, of course, in the business of timber
production to some extent. The second
position is also held by the Forestry profession by and large. The New Zealand Institute of Forestry, which
is the body of professional foresters, takes that stance.
So
there are people in Government who adopt the first or the second or both
arguments and quite a lot of people who have sympathy with the third and the
fourth objections. In the short time
that I have been in New Zealand, three successive Governments have attempted to
address the policy inconsistency that the SILNA exemption represents. In 1998 and early in 1999 the Crown
threatened to simply legislate away the SILNA exemption. I understand that the present Government is
also considering this approach. This,
of course, is what the Crown did to private land owners in 1993 when the
Forests Amendment Act was brought in.
The Forests Amendment Act contains a clause that says that anyone,
except for people with a specific contractual arrangement, who loses money
because of this legislation has no right to redress. That is, there will be no compensation for economic loss under
the Forests Amendment Act.
So
let me just sum up there what I understand of the Crown’s argument to be as far
as the SILNA exemption. First, the
Crown has a mandate to act in the public interest. You could argue that acting in the public interest is the purpose
of Government. Second, the retention of
indigenous forest is in the public interest.
Now if you accept those two premises, you have to conclude that the
SILNA exemption, the SILNA right to clear fell, must go. The Crown has said in the past that SILNA
owners will not be compensated for the loss of that right to clear fell. We don’t know what the current Government
policy will be with respect to compensation but it does seem very clear that
the present Government intends to remove the clear fell option.
I
would like to make a couple of comments here.
First, I agree that it is the mandate of Government to act in the public
interest and I would argue that Article 1 of the Treaty gives the Crown both
the right and the responsibility to act in the public interest. This picks up a little bit on what the first
speaker said this morning about that conflict.
That tension between Article 1 rights and Article 2 and 3 rights also
needs to be recognised.
Secondly,
I would like to say that I concur that it is in the public interest to retain
indigenous forest. However, the mere
retention of forest will not protect the bio-diversity and the other values of
forest that are that public good value.
New Zealand’s biota, as I am sure you know, is very severely threatened
by a range of introduced pests. Forests
placed within conservation reserves require pest control expenditures to
protect the native plant and bird and other populations that are part of the
value of the forest. If we make
arrangements for the forest that lack adequate provision for on-going
expenditure on pest control, the result will not be protection but instead
forest deterioration and we have plenty of examples of that in New Zealand.
The
third point that I want to make is that the clear fell option has great and
very real economic value. That value is
now held in private hands, the hands of SILNA land owners and you could argue
that that value belongs to them.
I
want to illustrate this a little with an example. The following economic analysis done by my colleague, Ted Bilek
and myself only treats a sub-set of the SILNA lands. It doesn’t cover the lands that are in conservation arrangements presently
with the Crown, for example Waitutu and Lord’s River. It also doesn’t cover lands for which I didn’t have good data,
like Hokonui which is ten thousand hectares.
I just want to draw your attention to a couple of numbers. Firstly if you take the revenue forever that
you would get from clear-felling and you discount it to today’s net present
value, it is worth approximately ninety-eight million dollars. You should appreciate that there are lots of
assumptions involved in these calculations, like the interest rate for
example. If you then plant the land in Pinus
radiata the added value is just over eleven million dollars. If we managed the land consistent with the
Forest Amendment Act provisions for sustainable management by producing wood
chip we get a value of just over fifteen million dollars. That is rather low because we can’t sell the
chip. It costs us money to produce it
but we can’t sell it in the current market.
If we leave the chip wood in the forest and we spend money to break it
up as normally done for forest hygiene practice, the value of that option is
seventeen million plus. So the
difference between the hundred and eleven million and the seventeen million is
the value of the ‘public good’ that the SILNA forest represents.
If
the Crown legislates away the SILNA exemption it will mean is a net transfer of
something like ninety-four million dollars from SILNA land owners, from their
private freehold estate, to the public of New Zealand. In my opinion that is not consistent with
the current ‘Closing the gaps’ policy.
What
do the owners have to say about this?
Well, first you will appreciate that this is an issue of Mana
Whenua. Because it is an issue of Mana
Whenua, the history of the land has great bearing for the people. The SILNA lands were received in partial
compensation for much more valuable lands and land rights. The issues concern the Treaty of Waitangi
1840 and specific land purchase agreements that the Crown negotiated with
Tangata Whenua such as Kemp’s purchase and the Murihiku purchase 1853. In many of those Purchase Agreements, there
were very specific arrangements for things like mahinga kai and reserve lands
and lands to provide for the maintenance, the sustenance of the people who sold
the land. History establishes very
clearly that the promises made by the Crown in those purchase agreements were
almost immediately abrogated. Europeans
were settled on the choice lands and they had a range of services like cheap
loans and low rentals and agricultural extension. The Mäori were excluded from all of those things and so they
became progressively impoverished.
By
1891, 50% of Ngäi Tahu had no land and 90% were judged to have land inadequate
to support them and their families. At
the time of the signing of the Treaty, all of the land in New Zealand was held
by Mäori but it then declined precipitously.
At
the time of their granting, the SILNA lands were among the least valuable lands
in New Zealand. The intention for their
granting, and I quote from the Statutes of New Zealand 1906, was “to make
provision for landless natives in the South Island to provide for their support
and maintenance”. The Parliamentary
intention was that the land be used by the people for their support and maintenance
and that intention in this legal system is what guides the interpretation of
legislation. So the Crown intended the
lands to be farmed which was their understanding of providing for support and
maintenance. However, the lands were
mostly unsuitable for farming and most SILNA land today remains unoccupied.
I
think the owner’s position could be summed up by a quote from John Sutherwood,
the Chairman of Rau Murihiku Whenua Mäori, the umbrella group for SILNA
owners. He had this to say to the
Minister who was leading the Crown position on SILNA in 1998.
“When they were valueless to the Crown, there was no
restriction on the use of the SILNA lands.
Indeed, the express intention was that they be cleared. Now that the owners could realise some benefit
from these lands, the Crown proposes to take away what it gave in 1906, lands
that were ours to begin with.”
Because
Nick Smith appeared at the Rehua Marae and shook his finger at the SILNA land
owners and told them how bad they were and how immoral it was to clear fell,
John Sutherwood had this to say:
“Minister, since you are an authority on right and
wrong, let me ask you this. Which of
these is the greater travesty of justice?
The clear felling of indigenous forest in private ownership, or the expropriation
without compensation of private property by the Crown. Make no mistake about this. SILNA owners consider that the Crown’s
proposal to restrict use of indigenous forests without equivalent compensation
for the attendant devaluation of our asset amounts to theft. The Ministry of Agriculture and Forestry has
made its calculations of the magnitude of this theft, and we have made
ours. The Crown proposes to take from
Mäori land owners economic opportunity valued by your colleagues at many millions
of dollars.”
So
essentially the SILNA owners argued that without compensation for the foregone
cutting rights, what the Crown gave in original sale and purchase agreements
and in the granting in 1906, it was in fact seeking to take back. That would be a derogation of grant.
The
SILNA owners also argued that Articles 2 and 3 of the Treaty conferred to them
specific rights, rangatiratanga, which the Crown by its policies seeks to
usurp.
I
want to make a couple of quick points about this before we run out of
time. First, I note that the clearing
of indigenous forests didn’t become politically incorrect in Aotearoa until
very recently. These lands have been
exploited, the SILNA lands have been exploited for a very long time for their
forests. I note that the New Zealand
Forest Service clear felled vast areas of indigenous forest until the 1980s.
If
the Crown does remove the SILNA exemption without compensation, it will in fact
be penalising people who preserved forest.
While the people who cut the forest earlier derive some benefit from it,
the people who save the forest will be deprived of that benefit. I find this a little ironic that the people
who conserve the forest should be penalised for their thrift.
I
also note that many SILNA land owners are themselves very staunch
conservationists. They don’t want to
cut the forest. I had this expressed to
me over and over again. But they also
don’t want to be taken advantage of by the Crown. They don’t want their rangatiratanga to be usurped.
SILNA
sections are owned under a collective title by groups descended from the
original beneficiaries. Sometimes there
are several hundred people per section.
I think that a good policy approach would be to facilitate the
strengthening of those groups and the reaching of consensus within
title-holding groups to assist owners to realise the options that they
themselves choose for their lands:
whether that means converting the forest to pine which is what is going
on now, whether it means sustainable management or whether it means strict
reservation.
The
Crown does have a responsibility to act in the public interest and certainly
the maintenance of indigenous forest is consistent with that. Therefore policies to encourage the
maintenance of indigenous forest are a good thing, but not if they come at the
expense of tino rangatiratanga or Treaty rights.
Finally,
many SILNA owners have no asset but these lands. They are seeking to derive something from these lands to build
the future for their mokopuna. These
people want the land to yield something to them and so I think that the policy
needs to find a way to realise what are usually seen as competing
objectives. The Crown has to appreciate
the rights and aspirations of the SILNA owners but this doesn’t necessarily
have to conflict with the protection of indigenous forest.
Compensation
for foregone revenue for clear felling or conversion in the form of cash, land
swaps or other mechanisms would allow the Crown to protect the forest and also to
recognise the rights of the people. In
its settlement with owners, the Crown can encourage the development of
sustainable enterprises for these lands, whether its tourism or forestry or
whatever. It can provide both for the
development of the owners and for the maintenance of the forest benefits.
Discussion
Question/Comment
(Lesley Shand, Forest and Bird)
Thank you very much for your very interesting address but the thing I was concerned about was the pest control issue which I feel was a red herring to the whole thing because I heard the same thing in relation to the West Coast Forest. Are you suggesting for instance that you take one tree out of Riccarton bush every year so that Riccarton bush pays for its predator control? In actual fact there are advances being made on predator control which are making it cheaper and cheaper, and better and better methods that are evolving.
ND - No
I wasn’t trying to suggest that it was some kind of quid pro quo that you should necessarily manage forest in order to
finance pest control. I’ve heard that argument also but what I was trying to
say is, just because you place forest in a conservation designation, it doesn’t
stop there. You still have to provide
for the maintenance of that forest in pest control, and other management is
needed: protection from forest fires, those kinds of things.
LS - But felling is an additional
pressure to predators, instead of just having predators.
ND - Not
necessarily. Sometimes a managed forest
is far healthier than an unmanaged forest.
LS - That is not possible.
ND - Well
I’ve been managing forests in several countries for the last 20 years and I
think I can demonstrate that unequivocally.
Question/Comment
(Eric Roy)
Nora, thank you very much for a very clear overview
of the issues. I’m not sure that I
grasped all of the information you had on the modelling with regard to
costs. It seems to me an absolute
nonsense that in order to control forests, we control what we do with the wood.
And in that respect it would seem to me that if we are sustainably managing a
forest, we ought to get the best price possible which would mean that we ought
to lift export bans on the sale of that wood.
The issue is the management of the forest, not what happens to the
product. Did you have a model that
actually demonstrated what would happen if that export ban was lifted and we
just focused on sustainability?
ND
- Well first of all, the SILNA owners are not subject
to the export ban. The Crown did try to
use an export prohibition but the Court found that it was ultra vires and that happened about eight or nine months ago. So SILNA owners retained the right to
export. However, you will appreciate
that in the Forest Amendment Act there are restrictions on export which do
perhaps reduce the potential value of the resource for this society. But I completely agree with you that what we
ought to be doing is looking at the quality of the results in the forest, as
the point where we exercise control and not worry so much about what we do with
the product.
Question/Comment
(Tiny Metzger, Awarua Runanga and Waitutu Incorporation)
I have been lucky to have been brought up under the Mäori
Lore that has been passed on to me and that I have passed on to my
grandchildren. But this Lore is useless
when dealing with the Pakeha. When
dealing with them you must use their law, spelt L-A-W. And I have spent too much of my lifetime
doing that. SILNA land was given as
compensation for other the land where the people lived, like Riverton, Colac,
Auwi and the Omaui. That other land was
not sold, it was taken when the rest of Southland was sold. Because it was recognised that there had
been a grave injustice, worthless land away in the wopp wopps was given in
compensation to the men or women with family.
Women without family did not even get any. Because it was recognised that the taking of the other land was a
grave injustice, the SILNA land was given for their uninhibited use. Uninhibited. Now other Acts have been brought in since then, the Resource
Management Act and the like. As far as
we can see, these are inhibitions. If
people are not happy - or if Forest and Bird are not happy - with SILNA land
being logged or the people doing what they wish with it, they must deal
directly with the landowners. They
should not do as they do now and go behind the peoples back and try impose
their view through councils and Government.
That sort of approach won’t work.
It will never happen. Thank you.
Question/Comment
(Eveline Cook)
Kia ora tatoue te whanau. E tu ana ahau i raro i te marumaru o tenei whare, o
Te Rakitauneke. Ko taku ingoa ko Eveline Cook ahau. He uri ahau o Meke. I am a descendent of Meke. I am not an owner, I am the daughter of an
owner. We own lands in Tutaekawetoweto.
We own lands in Waimumu. Don’t
misunderstand me, we don’t want the money paid out from Tutaekawetoweto. Our family voted against it, we don’t want
the money. We didn’t want the trees
knocked over either but I pose the question to all of you: Why is it that my great grandmother who was
made an allocation in 1906, my grandfather who succeeded her and my mother who
succeeded him, have not received a penny?
If my mother were to receive $4000, that would for the last 94 years and
for the thousand years to come. That is
all this country is prepared to pay my family forever. Since 1906, if my family had been able to
manage their land the way they wanted, they perhaps may have been able to crop
three crops of Pinus radiata, another
three crops in the life time of my son, and
the mokopuna I hope to have and on and on and on. And for that my
family, that is just my mother, her four daughters and her four grandchildren,
will perhaps receive $4000.
Would any of you put up with that on something that
you absolutely own? No questions asked,
you absolutely own. Would you put up
with those sorts of restrictions?
Because somebody, somewhere, someday might go past on a boat or if its
on the mainland drive past down the road so that they can look and point and
say “Gee there’s a nice bit of native forest.
I’ve put cows all over mine. My
grandparents helped introduce the rabbits and the ferrets and the stoats and
the gorse and the broom and the magpies and all the rest of it. But gee look at that lovely bit of native
bush. Isn’t that nice?” But you don’t put one cent out of your own
pockets into helping keep the pests off that piece of land. We’re expected to do that. Because now you have given us money. So now you can afford to pay the pests rates
and have the pest programmes which is what we are committed to on
Tutaekawetoweto. We have to manage the
land as if it were a national park and allow people free access. But it’s our backyard and because you have
given us ten million dollars, you get to walk all over it. Now I want to know all your addresses so I
can come and walk over your backyard.
Because that’s actually what we as SILNA owners are being asked
for. I think you actually need to start
getting real and go out and tell people the truth about what this nation is
asking of us. We are not theoretical
people. We are me, we are Tiny, we were George, we’re Hom and Stewart and lots
of others that are in this room. You
know, this is just a theoretical exercise for the people who say that we should
not be able to sustainably log our land and who think we’re greedy because we
don’t think ten million dollars is actually enough for something that will
endure forever. It is not just for the
next 25 years. It is for the next 25
generations. So thank you Nora for what
you said. I wasn’t sure what you were
going to say and I came prepared to lynch you if the occasion was appropriate
because you are standing under our roof.
This is our whakapapa on these walls made out of totara.
I just actually wanted to put a face in a real story
to what is for a lot of people, just a theory.
I don’t want people going away from here thinking that we are only
talking about something that is the past.
It will endure to the future and you are depriving my son and my
grandchildren. Kia ora.
Question/Comment
(Rangimarie Te Maiharoa, Waitaha)
Kia ora tatou.
Nora, I’d just like to make a little comment here on some of the
information that Tiny’s just put forward.
He spoke about a woman with no children not having a right here. I have family registered here in the
Landless Native Land Act out in Rowallan.
In that Landless Native Land Act concerning my people, you have children
registered. They’re down as
minors. They have 20 acre shares. Adults, if they had no other shares
throughout the South Island in land, they got a 50 acre share. But if you had 10 acres, 12 acres, anywhere
else, then your share was reduced. I
would like to make that point clear and I know what I am talking about.
Now my other point.
The last speaker, she’s not speaking for me. Bear that in mind. She’s
quite in her own right to speak. I am
going to give you another point of view.
I am going back to the Waitaha point of view again. I am very proud to be the owner of just a
small piece of virgin indigenous forest.
To me, that is part of my
rangatiratanga. It is also my
inheritance and to me I don’t wish one ounce, one cent to be paid to me for
that bush that is standing. I like to
see and appreciate the value of that bush standing and my family are behind me
here. But today’s pressures are
changing the minds of a lot of people.
Now when our people first came to this country, it was a beautiful country. And you can take that from me. But what a mess it is in now. So if we can preserve one little bit of that
ancient indigenous forest in our own ownership, I’m right behind that. I appreciate and respect Nora’s knowledge
here. She is very knowledgeable and she
has probably given the best account I’ve ever heard about SILNA coming from any
individual person. Kia ora Nora. Thank you very much.
ND
- Thank-you Rangi.
Concerning Tiny’s information, you’re correct about the acreages of
course. But I think that Tiny’s point
was that if a woman was a single unmarried woman she received no
entitlement. I think Ken you once
remarked to me that women received a lower entitlement than men. Is that right?
KMcA
- Yes
[THE FOLLOWING TWO QUESTIONS
WERE ASKED DURING THE DISCUSSION OF THE TALK BY LOU SANSON, TANE DAVIS AND PETE MCCLELLAND “PARTNERSHIP
IN CONSERVATION MANAGEMENT, SOUTHLAND CONSERVANCY: CO-MANAGEMENT OF NEW ZEALAND
NATURE RESERVES - WHENUA HOU AND THE TITI ISLANDS”. WE HAVE TRANSFERED THEM TO HERE WHERE THEY ARE MORE RELEVANT -
Editors]
Question/Comment
(Nora Devoe, University of Canterbury)
Kia ora tatou.
I have two related questions for Lou Sanson. Lou, you have been quoted as saying that it is official DoC
policy that trees should not be cut on iwi lands or private lands of any sort,
nor on public lands. If that’s correct,
where does that leave DoC in terms of a future partnership with SILNA land
owners?
LS
- I’d love
to see that quote because I have never said it. No, I don’t have a problem with the application by the SILNA
owners for logging in Waitutu at the moment.
The only problem I have is with the Resource Management Act where I am
being asked to sign-off for a non
notified consent. When I look at the
Resource Management Act, my staff and I have to do an analysis to answer the
question: “Will the effect of that
logging in Waitutu greater than minor?”.
When I look at the tests in the Resource Management Act for what
constitutes effects greater than minor, I cannot sign off on a non-notified
consent for SILNA land. That’s
basically the decision I’ve got to come to.
I know that the previous Minister and the current Minister have also
have that position. But I don’t have a
problem with private land owners wanting to sustainably manage their forests in
the Waitutu.
Question/Comment
(John Sutherwood, Kai whakahaere Waitutu Incorporation)
Well we do have a bit of a problem with it Lou. The DoC policy as stated to me is that because
they are the Department of Conservation, they cannot be seen to be approving
the cutting down of trees. Therefore
they cannot sign it off, which means that in the District Plan where we have an
allowable activity, DoC has decided that it is not going to be an allowable
activity. That will not allow us to get
a consent from the Council. This
creates enormous problems for us. I represent
over 400 sections owned by just some of the people. For one of those sections which we have up as a trial case at the
moment, the Orbell section, it is going to cost between 10 and 20 thousand
dollars if we go from an allowable activity into a notified application. That is the cost for the legal advice and
representation. If you take that $20
000 and you multiply it by the 400 other blocks, you get a cost of about a
million and a half dollars. Our people
are not wealthy people. They just
haven’t got that sort of money. So in
other words, it would appear that the Department is trying to control us by
economic means.