NEFA makes submissions to the NSW Government on a wide range of issues affecting our forests. These detailed submissions can be found using the hyperlinks to the relevant topics below.
North East Forest Alliance Submission to Private Native Forestry Review
Prepared by Dailan Pugh, January 2019
It is evident that Private Native Forestry has never been undertaken on an Ecologically Sustainable basis because of political interventions, lack of political will, opposition from some landholders, failure to adopt best practices, refusal to adopt science-based prescriptions and consider relevant environmental research, refusal to require pre-logging surveys and apply mitigation measures for threatened species, inadequate retention and recruitment of old trees, failure to undertake assessments to identify ecosystems and features requiring protection, inadequate protection of streams and riparian buffers, failure to take into account forest degradation and require rehabilitation, failure to monitor the effectiveness of prescriptions and apply adaptive management, failure to undertake effective regulation, secrecy surrounding PNF operations, and contempt for genuine community concerns.
You can visit the LLS Government site here: https://www.lls.nsw.gov.au/sustainable-land-management/pnforestry/private-native-forestry-review-2018
See also the report immediately below which formed the basis of a submission to a Commonwealth Senate Inquiry into Threatened Species.
This report reviews the protection applied both in theory and practice to nationally threatened species and ecological communities in forestry operations in the North East NSW Regional Forest Agreement (NE RFA) area.
North East Forest Alliance submission to:
Photo: Dailan Pugh giving evidence to the Inquiry into the EPA's regulation of forestry practices at Royal Camp State Forest
North East Forest Alliance Submission to the Federal Inquiry into:
The effectiveness of threatened species and ecological communities' protection in Australia
Prepared by Dailan Pugh for NEFA, December 2012
Sandy Creek National Park Proposal
It is proposed to create the 2,100 ha Sandy Creek National Park in the headwaters of the Richmond River south-west of Casino. The proposal is comprised of two parts, including part of Royal Camp State Forest (compartments 13-16, 1,500ha) and the whole of Carwong State Forest (600ha). These forests are primarily proposed for protection for their exceptional importance for Koala conservation in an area where populations are in decline and in danger of extinction.
The outstanding natural universal values of north-east NSW’s rainforests have long been recognised, though have only been partially protected for political reasons. As noted by the Department of the Environment (2014):
Although rainforests cover only about 0.3 per cent of Australia, they contain about half of all Australian plant families and about a third of Australia's mammal and bird species. The Gondwana Rainforests have an extremely high conservation value and provide habitat for more than 200 rare or threatened plant and animal species. The distributional limits of several species and many centres of species diversity occur in the property. The Border Group is a particularly rich area with the highest concentration of frog, snake, bird and marsupial species in Australia.
Since 1986 rainforest has been added to the World Heritage List in an incremental political process, with Governments only willing to add rainforests protected through other processes. There are still numerous qualifying rainforests protected over 1995-8 that are yet to be added, and the commitment to incorporate eucalypt forests with universal values by 2002 has yet to be progressed.
In order to entrench the protection of national parks created as an outcome of the 1982 Rainforest Decision, the ‘Subtropical and Temperate Rainforests of Eastern Australia’ were inscribed on the World Heritage List in 1986 for their outstanding natural universal values:
as an outstanding example representing major stages of the earth's evolutionary history
as an outstanding example representing significant ongoing geological processes and biological evolution
containing important and significant habitats for the in situ conservation of biological diversity.
When a renomination was being proposed in the early 1990’s NEFA proposed a greatly expanded property based on protecting rainforest, oldgrowth and wilderness. Our proposal was ignored. In 1994 Queensland reserves, along with Oxley Wild Rivers National Park (93,220ha) and 16 generally small and disjunct flora reserves on state forests in NSW, were added to the renamed Central Eastern Rainforest Reserves of Australia.
The NSW and Commonwealth Governments initially committed to undertake an assessment of World Heritage values as part of the CRA process. The outcome was meant to be a renomination to complete the Gondwana Rainforests of Australia. A World Heritage Expert Panel identified that World Heritage values of north-east NSW’s forests related to rainforest and Eucalyptus dominated vegetation, with supporting values including representation of passive marginal swells and Aboriginal ceremonial sites.
The required assessment of the values was not done. The March 1999 Forest Agreements committed NSW to undertake studies of rainforest and to nominate additional qualifying areas of reserves for World Heritage Listing as extensions by 1 April 2001. They also agreed to identify qualifying eucalypt and Aboriginal dreaming sites by 2002. In 2007 the name of the world heritage property was changed to Gondwana Rainforests of Australia.
In 2009 the rainforest assessment was finally undertaken, though other values were not considered. In 2010 the NSW, Queensland and the Commonwealth Governments submitted a Tentative List of 459,739 ha of NSW national parks to the World Heritage Centre which were proposed, along with Queensland reserves, for future nomination as additions to the Gondwana Rainforests of Australia World Heritage area on the basis of rainforest values.
No further progress has been made. An expansion of the Gondwana Rainforests of Australia World Heritage property will increase recognition of these reserves’ values, provide another layer of protection, attract tourists, and require the Commonwealth to assist in management costs. It is long overdue. (see Assessing World Heritage Values)
It is already apparent that global warming is affecting our climate and will go on doing so into the foreseeable future. Aside from the environmental costs, there are significant social and economic consequences. The sooner we start reducing our emissions the better.
Irrespective of what we now do, we have already locked in ongoing warming for decades to come. Anticipating and adapting to inevitable climatic changes is essential to minimise future costs
The climate changes already initiated by global warming are having significant impacts on our forests and their inhabitants. As climate change accelerates it will have profound and dramatic consequences (see North East NSW expected climate changes).
Across Australia droughts and rising temperatures are putting forests and woodlands under increasing stress. Stressed trees are more vulnerable to insect and fungal attack, and many are dying. In extensive areas the remnant the big old trees, so vital for animal’s food and homes, are dying out.
In north-east NSW large swathes of forest are being affected by dieback apparently being aggravated by climate change (see: Logging Dieback), while in rural landscapes on the northern rivers Forest Red Gums are rapidly deteriorating. Undoubtedly there are numerous other changes occurring that are not being documented.
As heat waves become more intense animals too become stressed, in extreme events animals may just drop out of the trees dead. Hundreds of thousands of flying foxes died in heatwaves in 2014 across eastern Australian, with 5,000 being killed at just one site at Casino.
Many plants and animals have climatic tolerances beyond which they can not survive. As the climate changes they are being forced to track the changes. If they are unable to move due to inhospitable barriers, or if they run out of suitable habitat, they die.
Increases in extreme weather events are causing more frequent extreme fire weather and thus fires. As fires become more frequent and intense they are causing a change in forest structure and species. These impacts are being accentuated by burning-off and clearing for fire breaks. As fire intensity increase so too does the risk of tree dwelling animals being burnt alive.
Many plants can only regenerate from seeds and take more than a decade to mature, flower and seed. Often a single fire can result in the death of all mature individuals. If the regrowth is burnt before it matures there is no seed left for regeneration. Too frequent fires are causing the loss of some species from large areas. Vast swathes of Alpine Ash forests in the Snowy Mountains have already been eliminated by too frequent wildfires.
Rainforests are particularly vulnerable to fire. In north east New South Wales the increasing frequency of extreme fires will eat into rainforest margins and eliminate many smaller stands. Impacts are being exasperated by logging of buffer areas promoting weeds and making them more fire prone.
Disturbances, such as logging, destabilise and degrade ecosystems, increasing their vulnerability to climate change. We need to build resilience back into our forests by restoring natural processes and ecosystem functions to better enable them to resist the consequences of climate change.
Allowing forests to regrow and recover allows them to sequester and store significant volumes of carbon. What is good for the forests is also good for us. (see Carbon Storage)
North East NSW expected climate changes
Sequestering and Storing Carbon in Forests
Logging Dieback is the dominant form of Bell Miner Associated Dieback affecting forests in northeast NSW. Bell Miner Associated Dieback (BMAD) is spreading through our forests as a consequence of logging opening the canopy and promoting understorey dominance by lantana. It is principally a problem of wet forests and gullies, though is increasingly affecting surrounding forests subject to lantana invasion. For over two decades the Forestry Corporation have intentionally procrastinated over the causes and management of BMAD so that they can go on logging affected and susceptible stands. (see The Battle to Redress Logging Dieback)
March 2018: Dailan Pugh has reviewed the extent and effect of Bell Miner Associated Dieback (BMAD) on the NSW section of the Border Ranges (North and South), one of Australia's 15 Biodiversity Hotspots and part of one of the world's 36 Biodiversity Hotspots. These forests are recognised as being of World Heritage Value.
Read the Review: Killing Our Forests with Their Songs
Read an earlier NEFA report For Whom the Bell Miners Toll.
The causes of logging dieback continues to be debated but many scientists agree that logging and weed invasion are the primary causes of logging dieback. (see The Causes of Logging Dieback).
Forests are the lungs of the earth. They play a vital role in sequestering and storing carbon. Carbon storage has been significantly diminished in vast areas of NSW’s forests due to logging. As trees grow their carbon storage increases. By simply stopping logging of regrowth forests will allow trees to mature and increase their carbon storage. (See: Sequestering and Storing Carbon in Forests)
Protecting degraded forests is part of the solution to climate change, continued logging is part of the problem. Allowing regrowth forests to mature will avoid significant releases of CO2 and allow carbon to be sequestered and stored in the tree trunks and soils of the regenerating forests. The regenerating forests will continue to store carbon in ever increasing volumes as they mature over decades and centuries.
Climate change represents a significant environmental, economic and social cost to the people of NSW. Increasing carbon storage in forests and avoiding emissions represents a significant economic benefit to all people in NSW.
North-east NSW has internationally significant conservation values that single it out as one of the world's strongholds of biodiversity. Its high diversity of threatened species, large number of endemic species, significant populations of species which have declined elsewhere in Australia and importance for migratory fauna, identify it as one of Australia's major refuge areas with the best ability to maintain Australia's declining biodiversity. (see Natural Values of North East NSW)
The global significance of the region’s forests has been recognised by the inclusion of many of its forests on the World Heritage List as the Gondwana Rainforests of Australia, and the assessment that extensive additional areas of rainforests and the region’s diverse eucalypt forests also qualify. (see World Heritage)
Around half North East NSW’s forests have been cleared, and over two thirds of those remaining significantly disturbed, with those on floodplains and more productive sites very severely affected. They support a multitude of species threatened with extinction, with clearing, logging, grazing and climate change being the principal threats to their survival. These threats need to be redressed (see Logging Prescriptions).
It is the bigger and older trees that provide resources in the abundance required by numerous animals. It may take a tree one or two decades before they begin to flower and set seed, which they produce in increasing abundance as they mature. Numerous species of invertebrates, many birds, and a variety of mammals feed on these flowers and seeds. As they mature their trunks and leaves also exude a variety of sweet substances used by many species. Invertebrates harbour within their rough and shedding bark where they are eagerly sought out for food. Yellow-bellied and Squirrel Gliders chew channels through their bark to tap trees for sap. As the trunks and branches thicken the trees provide more stable nesting and roosting sites, while enabling Koalas to hug them on hot days to keep cool.
Once a eucalypt tree is over 120-180 years old they may start to develop hollows in their branches and trunks. In NSW at least 46 mammals, 81 birds, 31 reptiles and 16 frogs, are reliant on tree hollows for shelter and nests. As the trees get bigger so do their hollows, and it may not be until they are over 220 years old that they develop hollows big enough for the largest species. Most eucalypts may only live for 300-500 years, though some are reputed to live for over 1,000 years (see The Importance of Old Trees).
photo: Dailan Pugh OAM
Crown of a Sydney Blue Gum (Koreelah SF) hundreds of years old showing the numerous broken branches and large hollows necessary for large-hollow dependent fauna
Natural forests may support 13–27 hollow-bearing trees per hectare, with numbers varying between species, and increasing on more productive, moister and flatter sites. On agricultural lands the numbers of hollow-bearing trees have been drastically reduced. Similarly they have been significantly reduced throughout the remnant forests by logging, prescribed burning and by culling in Timber Stand Improvement operations.
In State forests in north-east NSW logging prescriptions now require the retention of an average of 5 hollow-bearing trees per hectare within logging areas, though numbers have already been reduced below this level in many forests. Where retained, hollow-bearing trees continue to decline with each logging due to token implementation of prescriptions, poor tree selection, inadequate protection, damage during logging and in post-logging burns, and lax enforcement. (see Protecting Habitat Trees)
Natural forests are generally multi-aged, so that as existing hollow-bearing trees die and collapse there are new trees with developing hollows to replace them (see The Importance of Old Trees). To account for this, logging prescriptions require the retention of an additional 5 sound and healthy mature trees per hectare as recruitment trees to be able to develop into the hollow-bearing trees of the future. Trees meeting this definition are also high-quality sawlogs so the Forestry Corporation go to extremes to avoid their obligations to protect them. This up and coming cohort of future hollow bearing trees is rapidly declining due to natural mortality and logging, along with token implementation of prescriptions, poor tree selection, inadequate protection, damage during logging and in post-logging burns, and lax enforcement . (see Protecting Habitat Trees)
If we are to minimise the hiatus in the availability of hollows for a plethora of native species we must act now to protect, as far as possible, all large old trees, along with sufficient recruitment habit trees to replace existing hollow-bearing trees as they die and to restore hollow-bearing trees throughout native forests.
The North East Forest Alliance was formed in 1989 as an alliance of groups and individuals from throughout north-east NSW, with the principal aims of protecting rainforest, oldgrowth, wilderness and threatened species. NEFA has pursued these goals through forest blockades, rallies, court cases, submissions, lobbying, and protracted negotiations.
After our second blockade of North Washpool and a court case we stopped logging of mapped rainforest on public lands in 1990. We managed to get rainforest more fully mapped and protected during forest negotiations from 1995-98. (see A Short History of Reserves in North East NSW)
After a blockade and court case over Chaelundi in 1990, and promises of more to come, we forced the NSW Government to establish moratorium over some 180,000 ha of oldgrowth forest until EISs were prepared. We managed to get oldgrowth mapped during forest negotiations from 1995-98, with mapped “high conservation value” oldgrowth protected. In 2003 we had protection extended to cover all mapped oldgrowth stands over 10ha on public land. Wilderness on public land was also protected as part of that process. (see A Short History of Reserves in North East NSW)
After our second and biggest blockade at Chaelundi in 1991, and another court case, we were successful in getting NSW’s first threatened species legislation, the Endangered Fauna (Interim Protection) Act. It took many more blockades, submissions and negotiations to get requirements for fauna and flora surveys and a comprehensive set of prescriptions for public land in 1996-9. Unfortunately they remain inadequate and poorly applied. (see The Battle to Protect Threatened Species)
It took NEFA’s 1992 blockade of a logging operation at Killekrankie in the New England Wilderness to halt horrendous logging and roadworks that were causing massive erosion, and a threatened court case, to force the Government to agree to adopt Pollution Control Licences for State Forests’ operations. Though a comprehensive suite of prescriptions to reduce erosion and protect streams wasn’t finally applied on public lands until 1996-9. Inadequate as they are, the Forestry Corporation was successful in having over 90% of their operations exempted in 2004. (see The Battle to Protect Soils and Streams)
For north east NSW, NEFA were also instrumental in getting the area of national parks and other conservation reserves increased from 968,335ha in 1989 to 2,033,227ha in 2011, an increase of 1,064,892 ha or 110%, with most of this being protected over the period 1995 to 2004. In addition to this, 311,615 ha of State Forest was incorporated into Forest Management Zones (FMZ 1, 2, and 3A) and Special Management Zones which are counted as contributing to the reserve system and protected from logging, bringing the total protected from logging to 1,376,507ha. The proportion of north-east NSW’s land area in reserves has increased from 10% in 1989 to 21% in 2011, with an additional 3% protected from logging in management zones. . (see A Short History of Reserves in North East NSW)
There is still a lot to do, north east NSW still does not have an adequate reserve system, attempts to implement ecologically sustainable forestry have failed, forests are being over-logged, weeds and dieback are being spread through our forests, and their carbon stocks depleted.
NEFA's new policy