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.
NEFA submissions on proposed modification of the Redbank Power Station in the Hunter Valley to burn wood instead of coal
On behalf of NEFA, Dailan Pugh has made 3 submissions on the proposed biomass (wood) fired Redbank Power Station in the Hunter Valley. Singleton Council exhibited the documents 3 times, each with new information. This development is a major threat to our region's forests. The power plant will burn a million tonnes of wood a year, much of it from native forests.
You can read the submissions here:
NEFA Submission on the Local Land Services (Miscellaneous) Amendment Bill
Here is a short extract from our submission. Prepared by Dailan Pugh, February 2021
So here we are, in Koala’s darkest hour we are back to discussing how disgracefully the Government intended to treat them, while they explore other avenues to remove protections and hasten their extinction...
For the future of Koalas, NEFA hopes that you can make a difference in this life and death struggle. We hope this submission will help.
NEFA considers that the intent of SEPP 44 to identify and protect “core Koala habitat” was the right way to go. We have already wasted 25 years and thousands of Koalas’ lives as the Government has dithered and actively frustrated this intent. It is more urgent than ever that we identify and protect “core Koala habitat”, and prepare Comprehensive Koala Plans of Management (CKPoMs), though Koalas will be extinct in the wild before we achieve this if we continue in this way.
We urgently need to change tack if we want to save Koalas. Most importantly the NSW Government needs to take on the task of undertaking a systematic scientific process to map Koala habitat within each Area of Regional Koala Significance (ARKS), with the output being the identification of feed trees, key Koala colonies, grades of Koala habitat, habitat links, drought refuges and long-term climate change refugia across all tenures within each ARKS. This then can be used to prepare KPoMs and feed into other processes to protect Koalas.
As identified by the Environmental Defenders Office:
Frankly, we can’t wait another decade to debate the wording of a new koala policy or guideline. We need to address the fact that our laws currently allow clearing of important koala habitat.
This Bill was the exact opposite of the law reform that is needed to save NSW koalas from extinction. And the decision to revert back to the former SEPP 44 is also a significant backwards step.
North East Forest Alliance Submission to NSW Bushfire Inquiry
Prepared by Dailan Pugh, April 2020
Due to climate heating bushfires are becoming more frequent and intense. As evidenced in 2019-20, droughts and heatwaves are drying forests out and making them more flammable. The fires were of unprecedented extent burning through 2.4 million hectares of north-east NSW with unprecedented intensity, as evidenced by the burning of 35% of rainforests. The fires likely killed in the order of 350 million vertebrates, leaving many species teetering on the brink of extinction. The situation is dire and urgent action is needed to stop further climatic deterioration and increase the resilience of forests.
To redress the unfolding calamity we need to move towards net zero emissions of CO2 as soon as possible, though we cannot limit climate heating to less than 1.5o or 2o C unless our forests remove excess carbon from the atmosphere and store it in their wood and soils. Clearing of native vegetation must cease, right now. Stoping logging of public native forests is a logical next step as the regenerating forests will store ever increasing volumes of carbon as they age and fulfil the essential role of immediately reducing atmospheric carbon - stoping logging of north-east NSW's State Forests will sequester 6.5% of NSW's annual emissions. By 2050 we need to have undertaken extensive regeneration and reforestation to draw down more atmospheric carbon. Huge gains can be made by rewarding landholders for the volumes of carbon they store in soils and trees.
We need our forests more than ever, not just because of their intrinsic worth and beauty, but for the ecosystem services they provide us, such as generating rainfall, cooling the land, calming winds, regulating streamflows, and capturing and storing the carbon we emit. With forests increasingly stressed by droughts and fires they are losing their ability to mop up our excess carbon - there is no time to waste if we want to avoid the worst of the climate catastrophe.
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.
Compliance of Forestry Operations in North East New South Wales with Commonwealth Requirements for Threatened Species and Ecosystems September 2018
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 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.
State Forests are part of the public estate effectively controlled by the will of the people of NSW.. Along with National Parks, Nature Reserves and State Conservation Areas, and numerous schools, hospitals, sporting, camping and recreation areas, State forests are Crown lands. State forests are public lands that have been allocated for timber production under the control of the Forestry Corporation.
The community has the right and responsibility to ensure that State forests are managed in the community’s best interests. The community has repeatedly identified that they place a very high value on native forests for wildlife, beauty, water and recreation, compared to a relatively low value for logging, mining and shooting. For example the Community Attitude survey for the Upper North East Comprehensive Regional Assessment (McGregor et. al. 1997a) established that the priorities respondents gave to “various activities with relation to public forests” were;
protecting native plants and animals (100%),
maintaining sites of natural beauty (99%),
maintaining water quality (96%),
aboriginal sites (89%),
protecting wilderness (87%),
camping (79%), and
Exploitative uses of public lands received a lot less support (timber production 24%, woodchipping 7% and mining 13%), with the highest opposition being to mining (72%), hunting (70%) and woodchipping (65%).
In response to the question “what is it about forests that you value?”, those values ranked highest were aesthetic (80%), conservation reasons (46%), spiritual (25%), intergenerational equity (14%) and recreation (10%) as compared to relatively low values for economic/employment (6%) and economic goods and use (5%).
While State Forests have been allocated for timber production, the Forestry Act 2012 requires that they be managed in compliance with the principles of ecologically sustainable development, with timber supply environmentally sustainable, and with regard to the interests of the community.
Large areas of State Forests are still required to be added to the reserve system to satisfy the national reserve targets and protect viable fauna populations (see CAR Reserves), logging is being undertaken at an unsustainable rate (see Over-logging ), and they are not being managed in an ecologically sustainable manner (see Bell Miner Associated Dieback), (Logging Prescriptions). NEFA therefore maintains that they are not being managed in the community’s best interests.
McGregor, A., Gibson, C., Miller, F. and Sharma, K. (1997a) Thinking About Forests, community attitudes towards forests in the Upper North East CRA region. Unpublished report prepared Department of Geography, University of Sydney, for the NSW CRA/RFA process.
Forests are key components of the earth's water cycle. Forests do not just respond to rainfall, they actively generate their own. They recycle water from the soil back into the atmosphere by transpiration, create the updrafts that facilitate condensation as the warm air rises and cools, create pressure gradients that draw moist air in from afar, and, just to be sure, release the atmospheric particles which are the nuclei around which raindrops form.
Forests have been described as 'biotic pumps' driving regional rainfall because their high rates of transpiration return large volumes of moisture to the atmosphere and suck in moisture laden air from afar.
While most of our rain originates from evaporation of the oceans, it is estimated that 40% of the rain that falls on land comes from evaporation from the land and, most importantly, from transpiration by vegetation. Recycled water vapour becomes increasingly important for inland rainfall.
Having created and attracted the water vapour, the plants then make it rain. Plants emit volatile organic compounds (VOCs), such as plant scents and the blue haze characteristic of eucalypt forests. They play an important role in communication between plants, and messages from plants to animals, and also between plants and moisture-laden air. They oxidise in the air to form the cloud condensation nuclei around which waterdrops form.
The transpiration of vegetation also results in evaporative cooling whereby the surface heat is transferred to the atmosphere in water vapour. The resultant clouds also help shade and cool the surface.
Forests store water in their tissues, in the soil amongst their roots and in the protected microclimate beneath their canopies, releasing it over time to the atmosphere by evapotranspiration and to streams through the groundwater system. Forests are a vital component of our hydrological cycle and due to their roles in attracting and recycling rainfall, reducing temperatures and regulating runoff they provide immense economic benefits to human societies. Their importance will become increasingly significant as climate change results in more erratic rainfalls and intense dry periods.
There is abundant scientific evidence that deforestation and degradation of vegetation causes significant reductions in rainfall by:
reducing the recycling of rainfall to the atmosphere by transpiration
reducing the drawing in of moist coastal air
reducing updrafts of moist air
reducing rooting depth and the recycling of deep soil moisture
increasing loss of water from the land by runoff
reducing the organic aerosols necessary for the condensation of rain drops.
The overwhelming evidence from around the world is that land-clearing has directly caused a significant reduction in regional rainfalls and an increase in land temperatures (See: Clearing Our Rainfall Away). These impacts have been compounded through the release of stored CO2, with land clearing contributing around a third of our CO2 emissions in the past two centuries.
Across drier areas of Australia the removal of deep rooted forests and woodlands has caused water tables to rise, allowing long-buried saline ground-waters to rise towards the surface, with the resultant dryland salinity affecting millions of hectares.
Logging has the opposite effect, with increased transpiration by the regrowth lowering water tables. The generalised pattern following logging of an oldgrowth forest is for there to be an initial increase in runoff peaking after 1 or 2 years and persisting for a few years. Water yields then begin to decline below that of the oldgrowth as the regrowth can consume 50% more water than oldgrowth. Water yields are likely to reach a minimum after 20-30 years before slowly increasing towards pre-logging levels in line with forest maturity. It can take over 150 years to restore the original water yields. (See: How Forests Regulate Streamflows)
Reductions in water yields are dependent upon the rainfall and the amount of water used by the vegetation. When rainfall is low the regrowth can consume most of the water, leaving little surplus for streams. In areas experiencing high rainfalls regrowth has been found to depress annual water yields by some 50%, though with low rainfalls there may be little water left for streams surplus to the requirements of the regrowth.
With declining rainfalls due to clearing, the increased demand for water by the regrowth can dry catchments, cause water stress and kill trees.
Allowing regrowth forests to mature results in significantly increased water yields to surrounding streams and dams. Water yields will go on increasing for many decades. The increase in water yields from maturing forests represents a significant economic benefit to all downstream users, particularly during dry periods.
Fig. 1 from Speer et. al. (2011): Map of Australia highlighting the decline in annual rainfall (mm/10 years) around Australia from, 1950–2007.
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 8 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, up until 2018 the logging prescriptions required the retention of an additional sound and healthy mature tree for each retained hollow-bearing tree as a recruitment tree 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 used to go to extremes to avoid their obligations to protect them, and were finally successful in having the requirement to protect recruitment trees removed in the 2018 Coastal Integrated Forestry Operations Approval. This up and coming cohort of future hollow bearing trees is rapidly declining due to natural mortality and logging. (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
North-coast Koala populations have declined by 50% over the past 20 years.
In NSW State Forests, the highest quality Koala habitat is being cut down by intensive logging by Forestry Corporation.
There needs to be an urgent intervention to stop the accelerating degradation of Koala habitat in north-east NSW. Surveys need to be urgently undertaken to identify all areas containing remnant Koala populations. These surveys need to be undertaken independently of the Forestry Corporation.
Only with your support will we be able to protect our precious koalas and their homes.
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