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.
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.
Allocations of Public Resources for Logging
There are 918,145 ha of State forests in north east NSW (Lower and Upper North East RFA regions). A total of 306.472ha (33%) of these forests are zoned for protection in Forest Management Zones (1, 2, 3A) which prohibit logging. Some 40,338ha is claimed to be hardwood plantations and 37,048ha is pine plantations.
These forests belong to the people of NSW and are managed by the Forestry Corporation of NSW (AKA Forestry Commission, State Forests and Forests NSW). In the 1970’s the intent was to cut over the forests of the coastal plain and dramatically reduce logging until the regrowth matured in 2020-2040, keeping up sawlog supplies by one-off unsustainable logging of oldgrowth forest in steeper country and on the tablelands until pine plantations matured in 2010.
In the 1980’s the coastal forests began to be over-logged to maintain revenue and pacify sawmillers, while community alarm at the depletion of oldgrowth forests initiated campaigns to stop the liquidation logging of oldgrowth. The 1990’s saw a greater emphasis on reducing logging to a sustainable level while creating an adequate reserve system encompassing most oldgrowth forest and wilderness. The reserve system was doubled and most oldgrowth and wilderness protected on public lands.
In the 2000’s the State and Commonwealth Governments ignored evidence that yields were over-estimated and issued Wood Supply Agreements to millers for free at intentionally unsustainable levels. Since then NSW taxpayers have spent tens of millions of dollars helping mills modernise, paying compensation to millers for inability to supply, buying back commitments from millers for timber that never existed, buying timber from private land to meet commitments, and establishing plantations. Despite this sawlogs from public native forests continued to decline and the predictions were that the 2020’s will see massive reductions. (see The Battle for Sustainable Yields is Lost).
In 2014 the yield predictions for the next 100 years were inexplicably doubled. Previously predicted dramatic declines in yields in 2023 and again in 2065 were converted into increasing yields over time. How the parameters underlying the modelling were changed to achieve this have not been identified, though it is partially attributable to increasing logging intensity and treating native forests like plantations. Despite this dramatic turn-around the NSW Government separated the yields from native forests and hardwood plantations to change a modelled resource surplus into a deficit to justify major wind-backs of environmental constraints, and the opening up of oldgrowth and rainforest protected in the reserve system for logging. (see 2018 Timber Review).
Export woodchipping began from north-east NSW in the 1980s and because of the massive volumes, low manufacturing coasts and quick returns proved to be very profitable for millers. It was stopped in 2013 due to competition from overseas eucalypt plantations and an inability to get independent environmental certification for north east NSWs logging. Now there is the even bigger threat of burning native forests in furnaces for electricity (see A History of Export Woodchipping from North East NSW). In 2018 the Government offered new commitments of low quality logs to overseas buyers in 10 year agreements, including reassigning all hardwood plantation resources as low quality for export. (see 2018 Timber Review).
As a result of documents obtained under Freedom of Information it's now clear that the NSW Government ignored it's own scientist's advice when deciding on the koala reserves. Not only did it choose areas that were already protected and where there were few or no koala records...it DIDN'T choose the areas that have been identified as Koala 'Hubs'.
You can read an analysis of the information obtained in this new report by Dailan Pugh for NEFA. September 2018
Dailan Pugh, NEFA. June 2018
The NSW Government announced there would be 12 "new" Koala Reserves as a keystone of its Koala Strategy:Creating new reserves for koalas and protecting habitat corridors is a key pillar of the Strategy. More than 20,000 hectares of state forest on the Central Coast, Southern Highlands, North Coast, Hawkesbury and Hunter with koala habitat will be set aside as new koala reserves. Over 4000 hectares of native forest with koala habitat will be transferred to the national parks estate.
It is fraudulent for the NSW Government to pretend that these are new Koala Reserves. Ten of the 12 Koala Reserves are already protected as part of the informal reserve system (as FMZs 2 and 3). Four have no records of Koalas, and only 2 have "contemporary" records. Only 3 of the north-east reserves have high quality Koala habitat identified within them, and 2 of these have no "contemporary" records to substantiate the models... (View full PDF document)
North East Forest Alliance, Revised March 2017
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 proposal is comprised of inadequately reserved ecosystems, includes 2 Endangered Ecological Communities, and incorporates the known habitat for the Critically Endangered Regent Honeyeater, 3 Endangered plants, one Vulnerable plant, and 17 Vulnerable animals. There is the potential to improve its long term integrity by voluntarily acquiring intervening freehold land which has also been assessed as being of high value for Koalas... (View full PDF document)
Clearing our Koalas Away is a damning new report by Dailan Pugh that puts together intensive logging maps recently obtained via Freedom of Information, and the EPAs new koala habitat model.
The principal findings of this review are that:
Within the 103 State Forest compartments currently being actively logged on public land in north east NSW there are 4,663 ha of modelled high quality Koala habitat and 357 Koala records.
The identified protection for Koalas in current logging entails 2 Koala High Use Areas totalling 1.2ha from which logging is excluded and the identification of 15% of the high quality habitat as "Intermediate Use Habitat" where 5 feed trees of any size are required to be retained per hectare. This is mere tokenism.
Thirteen of the 20 current logging areas with >17% high quality Koala habitat are being targeted for logging intensities (regeneration and heavy Single Tree Selection) involving up to 60-86% basal area removal in blatant contravention of the Integrated Forestry Operations Approval (IFOA's) limit of 40% basal area removal.
During the period when it was practiced from 2000-2010 over 10,000ha of forests in the Lower North East region were allocated to Australian Group Selection patch clearfelling, incorporating 6,460ha of high quality Koala habitat, despite a prohibition on the use of AGS in "intermediate" Koala habitat.
Since 2006 in the Lower North East region. the Forestry Corporation have subjected 74,906 ha to the unlawful logging practices of 'medium', 'heavy' and 'regeneration' Single Tree Selection involving 41-100% basal area removal. This is comprised of 23,742 ha (32%) of high quality Koala habitat and 717 Koala records.
Of the unlawfully logged area, 23,340 ha has been subjected to 'heavy' and 'regeneration' STS, comprised of 39% high quality Koala habitat, in what amounts to clearing and conversion to quasi plantations.
Over the past 10 years the Forestry Corporation have progressively and unlawfuly converted half of the logging area of the proposed North Coast Intensive Zone in the Lower North East Region to "quasi plantations", with the proposed zoning to give retrospective approval.
There have been no records of Koalas from 41% of the current logging areas encompassing high quality Koala habitat, and no records for at least the past 9 years in 12% of the areas. Records over the past 20 years indicate that Koalas are in decline across State Forests.
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. Identified areas, along with sufficient additional areas of potential Koala high quality habitat and habitat linkages, need to be fully protected to establish viable populations across the landscape.
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We have long recognised that our iconic Koalas are in danger of extinction on the far north coast of NSW and, despite having laws in place for over 20 years to redress their decline, our Governments collude to hasten it. Governments of all persuasions have proven that they are willing to have rules and regulations to protect Koala habitat as long as they are ineffective.
Stable breeding aggregations of Koalas are comprised of individuals with overlapping home ranges of around 5 ha. Koalas show strong fidelity for their home ranges throughout their lives, which may be 8-10 years. The size and viability of a Koala’s home range is dependent on the availability of resources within it.
On the north coast Koalas preferentially select larger (over 30cm diameter) individuals of Tallowwood, Grey Gum, Grey Box, Forest Red Gum and Swamp Mahogany for feeding, though also utilise other species. These are the same trees targeted by the loggers.
For Koalas the logging codes variously require the retention of 5 to15 feed trees per hectare (for public and private lands respectively) when Koalas are found in preferred forest types. They also require the establishment of 20 metre exclusion areas around Koala high use trees if they are found. Koala high use trees are taken to be those with at least 20 Koala scats (faecal pellets) beneath them. It is this later requirement that has the theoretical potential to provide protection for parts of core Koala breeding habitat.
For public lands the Forestry Corporation are required to thoroughly search for Koala scats ahead of logging to identify and protect Koala High Use Areas (HUAs). It wasn’t until NEFA caught the Forestry Corporation logging Koala HUAs in Royal Camp State Forest (near Casino) in 2012 that their ongoing refusal to properly search for Koala scats and identify Koala HUA’s was publicly exposed after 15 years of avoiding this requirement (see Doing Surveys).
For private lands loggers are required to protect Koala high use trees, though are not required to look for them (or any threatened species) and therefore they are not usually protected. This wasn’t publicly exposed until the local community and NEFA intervened in 2013 to identify Koala high use trees on a private property being logged by the Forestry Corporation at Whian Whian (north of Lismore). Where the Forestry Corporation had identified 2 such trees, the community identified 26 along with core Koala breeding habitat. Undaunted the Forestry Corporation continued to road and log the core habitat.
It is evident that the Forestry Corporation can not be trusted to provide the required protection for core Koala habitat and have instead been routinely logging it. In order to provide Koalas with the protection they need the National Parks Association have recently proposed the Great Koala National Park and a series of smaller Koala Parks throughout north east NSW. (see A Blueprint for a Comprehensive Reserve System for Koalas on the North Coast of NSW).
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).
The Minister for the Environment, Mark Speakman, has let us know that the steep land logging trial proposed to be held in the upper catchment of the Nambucca, Kalang, Bellinger and Orara Rivers is now “not anticipated to be in” the new logging rules when they come out for public comment in October. He did say he “couldn’t rule something out forever” but this is great news in the short term. The local community stood up and said NO to such an extreme proposal. Had they got away with it, Forestry Corporation planned to extend steep slope cable logging across thousands of hectares of the steep upper catchment areas. It would have ruined our beautiful mountain vistas that are backdrops to our coastal towns, dried up our water catchments that supply farms and towns, destroyed habitat of our forest dependent threatened species and destroyed the opportunity for mature trees to contribute to carbon storage to mitigate against climate change. So thanks to everyone who helped out with the campaign and spreading the word. It’s a victory for common sense.
However the bad news is that we now know Forestry Corporation are planning to introduce massive clearfells, 50 hectares in size, across many of the coastal forests between Grafton and Taree and increase the intensity of logging nearly everywhere else. See our page Forest Slaughter.
NB: NEFA's research into the proposed steep slope cable logging and the reason NEFA lobbied the government to not go ahead with this proposal can be read below.
Right now, the NSW State Government is planning to begin cable logging of steep forested slopes. Areas that are hard to get to and play a vital role in holding our catchments together are now under immediate threat.
The intensity of logging in the first area to be subject to the cable logging treatment can be seen here. Each orange line is a cable site.
This will then be done across the areas outlined in red (see image below). They form an important part of the Nambucca, Bellinger, Coffs Harbour, Taylor's Arm, Kalang, Never Never and Orara River catchments.
After this no forested part of the steep land of the north coast will be safe.
Together we can stop this madness. Sign-up to volunteer.
In 1992 NEFA stopped a relatively small logging operation on extremely steep slopes at Mount Killekrankie in Oakes SF that was causing horrendous erosion, with over 88,000 tonnes of soil being mobilised into the headwaters of the Bellinger River. It was this case that proved the need for legally enforceable prescriptions for forestry and resulted in logging being prohibited on the steepest and most erodible slopes. (see The Folly of Logging on Steep Erodible Slopes)
Now that the NSW Government is becoming desperate for sawlogs to satisfy its Wood Supply Agreements it wants to over-turn the prohibition of logging on extremely steep-lands and introduce cable logging into NSW (see The Battle for Sustainable Yields is Lost).
In 2014 a NSW Government Steering Committee tasked with identifying means of making up for declining yields, proposed logging blackbutt forest on excessively steep slopes in the headwaters of the Taylors Arm, Nambucca, Kalang, Bellinger, Never Never and Orara Rivers. It was considered that with the use of cable-logging around 50,000 m3 per year of sawlogs could be obtained for around 6-7 years from slopes over 30o.
As part of their remake of the logging rules the EPA subsequently announced “FCNSW will conduct a small scale trial to determine which techniques can be used to augment ground-based methods on steep country in coastal NSW”. As well as allowing the Forestry Corporation to “trial” cable logging, the EPA intend to “reduce the prescriptive nature” of Environment Protection Licence and allow clearfelling.
While this may buy a few years of continued over-logging, there is nothing sustainable about it. For a few years worth of logging they will leave behind degraded landscapes and the community will have to bear the costs of the ongoing landslips, massive erosion, increased flooding, reduced dry-season stream flows and the pollution and siltation of their creeks and rivers. If this goes ahead it will just be the start, no forested part of the steep land of the north coast will be safe.
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.
The North East Forest Alliance has always been effective in protecting our forest because of our dedicated band of volunteers. Now NEFA needs you to join us in campaigning for healthy native Forests4Ever. Please sign up today to do whatever you can before it is too late.
With the State & Federal Governments committed to wholesale vandalism of our native forests right now, it is more important than ever that you commit to helping defend them. Even if it's to write a letter to your MP or join us at a public meeting or protest, every contribution brings us closer to protecting our forests forever.
Become a volunteer
Please make a submission on NSW proposed new logging rules today
Government's secret logging agenda: ABC news story
Check out our new short film about what is happening in the forests of northern NSW
Explosive documents reveal Government's secret logging agenda: click here to see ABC news story
The coastal forests will be divided into 3 zones. In northern NSW:
The 140,000ha Intensive Zone will see the alternate coupe clearfell logging practiced in Eden, extended all the way along the coast from Taree to Grafton. Coupes for clearfelling are proposed to be 50 to 80 ha. The current legal limit for clearfelling in northern NSW is 0.25 ha!
The regrowth zone will allow intensive logging but will have some tree retention requirements spread across the net logging area.
The non-regrowth zone, will have slightly less intensive logging and a few extra trees retained.
The requirement for pre-logging surveys for most species will be scrapped. For example 326 species of threatened plants will lose their current legal protections and 32 will have their protection areas significantly reduced. Only 77 species and populations of threatened plants will retain their current protections.
Grevillea quadricauda photo by Hugh Nicholson
Similarly, the requirement to survey before logging for most threatened animal species will also be scrapped. 23 animal species are to have their protection removed and 26 are to have their protection significantly reduced. Only 14 will retain their current species-specific protection.
Eastern Blossum Bat photo by David Milledge
Streamside protection in the upper catchment headwaters will be more than halved (from 10m to less than 5), and other stream protections decreased, when all the evidence is that they should be increased to 30m. The current requirement for streamside logging exclusion buffers, is that they are measured from the top of the stream bank. Under the new rules, they will be measured from the middle of the stream. This means that for many streams, logging will be able to occur right up to the edge of the bank and for all streams will result in seriously diminished protection.
Most areas protected over the last 20 years because of the presence of a threatened species, will be opened up for logging. This includes all the Koala High-Use Areas that have been identified to date.
There will no longer be a requirement to search for koalas prior to logging and exclude logging from the areas they are actually using. Thus areas with active koala populations will be logged.
The areas of greatest logging intensity coincide with the areas the Government has identified as the best koala habitat.
Wood supply contract negotiations with logging companies based on the new logging rules are in process. The government remains committed to enter new wood contracts sometime soon: 'in the middle of 2017'.
All of the above is occurring with the Government promising there will be 'no erosion of environmental values'. They must think we are all idiots.
The destruction has got to stop.
We need your help, can you inform your friends and colleagues?