Registration No. 017-638NPIO

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MP/AB/MP10 - 2013

30 May 2013

Mr NTP Nhleko

Director- General

DEPARTMENT OF LABOUR

Private Bag X117
PRETORIA
0001

BY FAX

C/O

Dear Sir

INVESTIGATION INTO FORESTRY WAGES

We refer to the meeting that was urgently convened by your department on 1 February 2013 in Pietermaritzburg, to discuss the agricultural and forestry Sectoral Determinations.

Forestry South Africa, representing over 90% of timber growers in South Africa, commissioned an analysis of the affordability of different wage levels on timber growers in the country and this was given to your department during the meeting. Industry also indicated during the meeting that at a minimum wage of R105.00 per day, which had already been Gazetted for the agriculture sector, the forestry sector could lose around 50% of the 96 500 jobs in the primary side of the industry, that is governed by the Sectoral Determination.

Based on these and several other representations made by industry during the meeting, the department and ECC representatives, indicated that they would urgently commission an analysis of forestry wages in South Africa, as had been done by the Bureau for Food and Agricultural Policy, for the agricultural sector. This study was to be used by the ECC in making its recommendations to the Minister on the Forestry Sectoral Determination, as we were advised that the ECC could not use a study that had been commissioned by the industry itself.

We were greatly surprised when the Minister announced the new Forestry Sectoral Determination, without the department or ECC having commissioned the study. We are unclear as to what the ECC used as a basis for its recommendations, as the costs and other economic trends in the forestry industry, like trade volumes and timber prices, are far worse currently and for the foreseeable future, than for many other agricultural commodities and yet the Forestry SD made no allowances for this.

Many forestry companies have started mechanisation in earnest, to try to mitigate rising costs and other pressures. This trend was already flagged in the ECC’s last report into forestry in 2011 and is going to accelerate sharply with any further labour cost increases.

As a rural-based economic activity, in both the timber growing and processing sub-sectors, the contribution of the industry in terms of jobs, is disproportionate to its size and to other land uses. This should be protected at all costs, not just for the value of the jobs in the industry, but for the broader contribution from the industry to rural development, transformation and growth of the economy.

We urge you therefore to ensure that either the Department or the ECC, commissions the study on the forestry sector, so that any future deliberations of the ECC, can be properly informed by research and there is a rationale basis, for all recommendations to the Minister.

Yours faithfully,

Michael Peter

Executive Director