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
Koalas don't like logging
NSW DPI Forestry recently had published a paper by Law et. al. (2022) titled ‘Regulated timber harvesting does not reduce koala density in north-east forests of New South Wales’ which used male Koala recordings from song-meters to assess the impacts of logging on Koalas in 3 State Forests in the north-east NSW, claiming “There was no significant effect of selective harvesting on density and little change evident between years”. These findings are now being relied upon by the NSW Koala Strategy and the Koala Recovery Plan to claim that logging has no impact on Koalas and therefore there is no need to protect Koala habitat from logging.
NEFA recently completed a review of the paper, concluding:
While this review of the data is limited to that presented in Law et. al. (2022), it shows that there were large decreases in male Koala calling activity across recently logged areas and a large increase in areas with no or minimal calling activity, suggesting that Law et. al.‘s (2022) conclusions are invalid and logging appears to have had a large impact. Averaged across the forests actually logged in 2020 within the 3 State Forests assessed by Law et. al. (2022) from the extreme drought in Spring 2019 to Spring 2020 there appears to have been around a 23% decline in areas with relatively high male Koala calling frequency (hot spots), a 27% decrease in areas with moderate calling frequency and a 36% increase in areas of no or very low male Koala calling frequency. This is despite the breaking of the drought.
Two of the 3 previously logged National Parks used as controls by Law et. al. (2022) indicate there was a consistent persistence of high Koala call frequency sites (hotspots) between years suggesting stable breeding colonies, whereas in the recently logged forests the smaller calling hotspots were highly variable between years suggesting unstable populations, supporting the concern that that logged forests may constitute sink habitat where mortality exceeds reproduction.
The impression gained from this review is of unstable Koala colonies in logged forests, declining as mature feed trees are progressively removed, at risk of collapse from the combination of logging, drought and fire. The assumptions and conclusions of the study by DPI Forestry (Law et. al. 2022) misrepresent the threat to the ongoing survival of Koalas, and is therefore a threat itself. The data collected needs a full reassessment and critical review by independent experts.
NSW KOALA STRATEGY RELEASED
On Saturday 9 April 2022 the NSW Koala Strategy was released as the first 5 year stage of a goal to double NSW Koala populations by 2050, with an allocation of $193.3 million for the next 5 years. The strategy is set to fail because it does not fulfill the most fundamental requirement of stopping existing Koala habitat from being cleared and degraded, and lacks a strategic approach to identify the highest priority lands for protection and revegetation.
The $107.1 million allocated in the Strategy for habitat protection and restoration is intended to protect just 22,000 ha of Koala habitat, and create 25,000 ha of new habitat, on private lands. It would be far more cost-effective to allocate this funding as an industry transition strategy, enabling the protection from logging of 2 million ha of native forest on State forests, including over 287,000 of existing medium-high quality Koala habitat encompassing 20,000ha of “Koala Hubs”. If there was a genuine intent to save Koalas the Government would not ignore State forests.
Throwing money around in a piecemeal fashion for private lands will not compensate for the Liberal’s promises to the Nationals, as peace terms in the 2020 Koala Wars, to remove the requirement to obtain permission before clearing core Koala habitat, to end the prohibition on logging core Koala habitat, to open up all environmental zones for logging, and to stop core Koala habitat being added to environmental zones. None of this is mentioned or accounted for in the Strategy.
While it is good to see funds being directed to Koala conservation, what we need most is immediate protection of core Koala habitat and linkages on public lands, and the mapping of core habitat and linkages on private lands to enable the most effective targeting of regulatory instruments and funding to protect it.
FEDERAL INTERVENTION REQUESTED FOR RICHMOND RIVER KOALAS
Within the Federal electorate of Page it is evident the Spotted Gum forests of the Richmond River lowlands, with their extensive stands of Koala feed trees (particularly Grey Gum, Grey Box, and various Red Gums), are a priority area for Koala conservation with the capacity to support a viable population of Koalas, with great potential for population-level recovery from the wildfires and logging.
Unfortunately, the 2019 fires left this Koala population in a highly vulnerable state, which is currently being aggravated by logging of priority koala habitat on State Forests in accordance with North East NSW Regional Forest Agreement signed by Prime Minister Scott Morrison in 2018.
In light of the Commonwealth’s listing of Koala (combined populations of Queensland, New South Wales and the Australian Capital Territory) as Endangered, and the identification in the Conservation Advice as urgent (a) increasing the total area of protected, connected quality koala habitat in priority areas, and (b) reviewing statutory planning instruments to avoid or minimise impacts of land management on koalas, NEFA have written to the member for Page, Kevin Hogan, requesting he:
- Make urgent representations to Environment Minister Susan Ley to engage independent experts to review NEFA’s proposed Sandy Creek Koala Park and identify other priority koala habitat within the Northern Rivers for incorporation into state protected areas.
- Make urgent representations to Prime Minister Scott Morrison to modify the North East NSW Regional Forest Agreement to require:
- pre-logging surveys by independent experts to identify koala habitat prior to logging commencing, and
- protection of identified Koala habitat to retain the quality food and shelter trees needed to meet their daily energetic requirements
NRC Koala response to harvesting in NSW north coast state forests
The Natural Resources Commission (NRC) have released their final report “Koala response to harvesting in NSW north coast state forests”. Their claims that logging has no impacts on koalas are considered to be based on invalid extrapolations of coarse data and selective use of results to justify not rectifying obvious inadequacies in the Coastal Integrated Forestry Operations Approval (CIFOA) and Private Native Forestry Code of Practice. It is ludicrous to claim that logging of Koala feed trees will have no impacts upon them.
It is particularly concerning that the NRC have not reconsidered their decision to over-ride the advice of the EPA and the government’s Expert Fauna Panel that minimum retentions of Koala feed trees should be 15-25 feed trees/ha >25cm diameter at breast height (dbh) in modelled habitat. Their reduction of retentions to 5-10 feed trees/ha and sizes to 20 cm dbh is not supported by this study. It is also obvious that the requirements need to be changed to add Flooded Gum as a feed tree and Turpentine as a roost tree. Their inaction on rectifying these failings is irresponsible.
Demystifying Koala SEPP 2021 - NEFA Webinar
On Thursday 22nd April NEFA hosted its first public webinar, Demystifying Koala SEPP 2021. We invited every councillor from the 14 NE NSW LGAs between Tweed & Armidale.
We had over 100 attendees on the day making the most of the opportunity to hear from 4 leading experts on the issues involved in this regulatory attack by the NSW Berejiklian government on our koalas and councils. They heard from our very own Dailan Pugh, Bellingen Mayor Dom King, Ecologist Steve Phillips and EDO Senior Solicitor Carrin Loane.
Many people have asked if they can review the video of the event and the answer is YES you can see it all and share it around on Facebook by following this link (please Like, Comment and Share)
If you want to know what councillors can do to help, or would like to let them know, here's a few starting points:
How to Extinct Koalas
Dailan Pugh, March 2021.
The Koala Wars erupted between the National and Liberal Parties last September, while the Nationals are claiming victory over the Liberals, it is the loggers that have prevailed over koalas and local councils.
Ironically the National’s declaration of war came after the bipartisan inquiry into ‘Koala populations and habitat in NSW’ released their findings in June 2020 that the regulatory framework for private native forestry does not protect koala habitat on private land, and that without urgent government intervention to protect habitat the koala will become extinct in New South Wales before 2050.
This appeared to inflame the debate about State Environmental Planning Policy (SEPP) Koala Habitat Protection 2019, which applied to private forests, home to more than 60% of NSW’s koalas. In early September the Nationals threatened to cross the floor unless the Liberal’s agreed to their demands to weaken protections for koalas. The Liberals surrendered.
The inquiry reaffirmed that fragmentation and loss of habitat poses the most serious threat to koalas in NSW.
We’ve known for decades that if we want koalas to survive, we first need to protect where they live.
Back in 1995 a Coalition Government even adopted a policy to achieve this - State Environmental Planning Policy 44 (SEPP 44). It required Councils to prepare Koala Plans of Management (KPoMs) to identify where they live, termed “core koala habitat”, and to protect it in environmental zones.
SEPP 44 had a fundamental flaw because it only allowed forests comprised of 15% of 10 feed tree species to be identified as core koala habitat, leaving dozens of key feed trees out, meaning vast areas of core koala habitat didn’t qualify.
The Local Land Services Act relied upon this mapped core koala habitat to meet its obligations to protect koalas, by prohibiting logging of core koala habitat and generally requiring consent before it can be cleared.
A combination of lack of political will and an intent to make SEPP 44 ineffective, coupled with the difficulty and expense for Councils to prepare plans, made SEPP 44 a policy failure.
By 2020 only 6 KPoMs had been approved, mostly covering just parts of Council areas, with just 5-7,000 ha of core koala habitat identified for protection, after 25 years. And most of this had pre-existing logging approvals that were allowed to continue. Another 5 finished KPoMs were still waiting for approval, Tweed and Clarence since 2015 and Byron since 2016.
After years of procrastination, in December 2019 Cabinet approved the new SEPP (Koala Habitat Protection) 2019 that, while still problematic, rectified many of the definitional problems with SEPP 44, including increasing the number of use trees from 10 to 123.
It came into effect in March 2020, when the Guidelines were released. By then the loggers were beginning to freak out because they were concerned that the new rules made it easier for Councils to identify core koala habitat, and they wouldn’t be allowed to log it.
NSW Farmers joined in as they wanted to remove constraints on land clearing. They were spooked by the map of likely koala habitat, the Koala Development Application Map, labelled the pink DA Map. It was only intended to limit the area where development applications had to consider koalas, but some Nationals were falsely claiming it was core koala habitat that all required protection.
The key request was that the SEPP be decoupled from the Local Land Services Act, meaning that core Koala habitat identified in a KPoM would no longer have logging excluded or require consent before it was cleared.
The Liberals had repeatedly agreed to decoupling since the SEPP was adopted in 2019, but wanted the Nationals to first put forward alternative protection for koalas from logging and clearing, though they failed to.
By mid May the Government had begun the formal process of changing the SEPP and the Guidelines, with a focus on removing the pink DA Map.
The release of the koala inquiry report in late June was followed by the release of NSW’s 2018 land clearing statistics, showing that since 2016 clearing of woody vegetation had more than doubled to 60,800 ha. Most worryingly over 50% of this clearing was unexplained, meaning it was unapproved, unassessed and unknown whether it included koala habitat.
While the Nationals hadn’t managed to get the variety of feed trees contributing to core koala habitat reduced from 123 species down to an arbitrary 39, Planning Minister Rob Stokes appeared to have agreed to most of their asks.
Despite this, the Nationals declared the beginning of hostilities in early September, when first Clarence MP Chris Gulaptis and then Coffs Harbour MP Gurmesh Singh claimed they would move to the cross-benches. On 10 September the whole of the National Party piled in and made the same threat, provided they kept all their perks. The Nationals likened it to “greyhounds on steroids”, considering koalas a threat to their political survival. This was dubbed the Koala Wars.
The National’s attack was based on misinformation and lies. For example the pink DA map, and its inaccuracies, was a primary focus, even though the decision to remove it had been made 4 months previously. No wonder the Liberals were outraged.
Under the attack the Liberals surrendered, Rob Stokes amended the SEPP to narrow the definition of core koala habitat, and the Nationals were given carte-blanche to write their own Local Land Services Amendment (Miscellaneous) Bill, which was introduced to the Lower House on 14 October 2020.
This was dubbed the Koala Killing Bill as it removed protection for core koala habitat on rural lands while offering no alternative protection, allowed logging to over-ride all council’s Local Environment Plans and NSW State Environmental Planning Polices, allowed some self-assessed clearing in environmental zones, and doubled logging approvals to 30 years.
It was not just about koalas, the National’s intent was to allow logging to occur in all council’s environmental zones, opening up 167,000 ha of private forests in north-east NSW where “greenie local councils” currently prohibit logging. Council’s existing consent requirements for logging over another 600,000 hectares of private forests was to be removed.
Rob Stokes reputedly also gave the Nationals a promise that councils would not be allowed to protect identified core koala habitat in environmental zones.
While the Liberals supported the Koala Killing Bill, it came to a halt in November when Upper House Liberal Catherine Cusack took a principled stand by crossing the floor and referring the bill to the Upper House Planning and Environment committee for review.
In retribution on 26 November Premier Berejiklian did a deal with the National’s leader John Barilaro to revert to SEPP 44, renamed as SEPP (Koala Habitat Protection) 2020.
To pre-empt the inquiry Planning Minister Rob Stokes and Environment Minister Matt Kean did a deal with Deputy Premier John Barilaro which was announced on 8 March 2021, without any detail. The general thrust is to resurrect most provisions of the Koala Killing Bill, including that the 87% of private lands zoned for primary production or forestry will not be subject to SEPP 2019, logging will be allowed to over-ride local environmental plans, and the Minister for Planning will take over Council’s rights to rezone rural land to an environmental zone.
This time they intend to avoid parliamentary scrutiny by implementing most of this through changes to the SEPP and ministerial directions.
On 17 March the new SEPP (Koala Habitat Protection) 2021 was made. As foreshadowed it does not apply to rural and forestry zones, which comprise 90% (2.4 million ha) of private forests in north-east NSW. The 2020 revision of SEPP 44, with its 10 feed trees and manifest problems, continues to apply to these lands.
In a significant change, KPoMs now also need to be approved by the Secretary of the Department of Regional NSW (Barilaro’s Department).
There is worse to come.
Far from being a step forward, Planning Minister Rob Stokes’ “new solution” has made the already dysfunctional SEPP process into a farce, reduced already inadequate koala protections, and opened up thousands of hectares of protected environmental zones for logging.
With core koala habitat even more difficult to identify and most of its protection about to be removed it’s the height of hypocrisy for Environment Minister Matt Kean to claim this “new solution will ensure protections for core koala habitat and colonies across NSW”.
#SaveOurKoalas Statewide Day of Action
Join Us & #SaveOurKoalas
A new Koala SEPP just released by the NSW Govt is a huge loss in the fight to save koalas from extinction in NSW
Help stop NSW govt driving our Koalas to extinction for their logger and developer cronies
Our alliance is supporting events across our region as part of the State wide Day of Action to Save our Koalas on Sunday, 21 March 2021.
Here are the details (with links to the Facebook events)
Please come along to as many of them as you can and share them with your networks:
- Murwillumbah (on Saturday 20th): 10am Knox Park https://fb.me/e/2mqMTuegU
- Lismore (Sun 21/3 at 11am): Rally across Brewster St from Carboot Market (near recycling depot) - Speakers include: Cindy Roberts (Widjabul Wia-bal Woman), Dailan Pugh (NEFA), Janelle Saffin (ALP), Daisy Nutty (XR), Angella Pollard (AJP) https://fb.me/e/VDp2Hmst
- Byron Bay (Sun 21/3) at The Peace Pole 2 PM https://fb.me/e/241QmQCzn
- Clarence Valley (Sun 21/3 at 12pm): Nature walk and picnic lunch at Shannon Creek Dam, with @lionsclubofclarenceenvironmental #lawrencekoalas https://fb.me/e/26FgelcRC
- Bulga Forest (Sun 21/3 at 10am): Meet on the corner of Doyle's River Rd and Bulga/Glenwarrin Rd. From there we will travel to French's Creek Rd which is scheduled for logging later in the year to see if we can find evidence of koalas https://fb.me/e/20TnrFnbs
- Nambucca Heads (Sun 21/3 8:30am) Visitor Information Centre https://fb.me/e/18At9NFmA
- Bellingen (21/3 at 10:30am) Lavenders bridge https://fb.me/e/1Gx8qvj5x
- Armidale (Sun 21/3 at 1pm) Edgar Street off Arundel Drive https://fb.me/e/1glnjx8C1
- Sydney (21/3 at 11am) Hyde Park Sydney near the Archibald Fountain https://fb.me/e/Cdh0c1nP
Please let your network know about the Day of Action, share these Facebook events and Invite your friends!
ACT TO SAVE KOALAS FROM THE NATIONAL PARTY's KOALA KILLING BILL
North East Forest Alliance, November 2020
We recently asked you to URGENTLY send an email to Liberal parliamentarians to congratulate them for standing up to National Party bullying to strip Koalas of protection on private lands. While the Liberals heard our call, they totally capitulated to the National Party and the demands of the loggers and land developers.
The Liberals altered the 2019 Koala State Environment Planning Policy (SEPP) to make it a lot harder for Councils to identify core Koala habitat. This was not enough for the Nationals, they are now in the process of altering the Local Land Services Act to remove protections for core Koala habitat from logging and broadscale clearing, prohibit Council's from requiring consent for logging and clearing in Environmental Zones, and double the length of logging approvals. This sets Koala protections back 25 years, it is a total capitulation to the loggers.
If this isn't bad enough, Premier Berejiklian is claiming this as a victory and congratulating the National Party on the outcome. It is a war, and the Koalas are losing.
KOALAS URGENTLY NEED YOU TO SPEAK UP FOR THEIR SURVIVAL
The Local Land Services Amendment (Miscellaneous) Bill 2020 has passed the NSW Lower House and is likely to be voted on in the Upper House on 11 November. Parliament's servers have already crashed once due to the outcry. Every letter and phone call helps.
Can you contact parliamentarians in an effort to stop their draconian changes to the Local Land Services Act and hold them to account for their actions? They need to know we don't accept them extincting Koalas!
There will also be a variety of direct actions targeting parliamentarians on 6th November, so watch our Facebook, or come up with your own local actions.
The numbers in the NSW Upper House are currently 20 progressives to 22 potential koala killers. We have little chance of influencing their politics, but we are not without hope, here's 3 targets:
The Liberal's Ballina based Catherine Cusack was on the Koala Inquiry and urged her colleagues to stand up to National Party bullying, now she needs to be encouraged to do what she knows is right.
- Catherine Cusack (02) 9230 2915 <[email protected]>
The National's Byron Bay based Ben Franklin was on the Koala inquiry, but will likely ignore his own findings to tow the party line, he does know better.
- Ben Franklin (02) 9230 3793 < [email protected]>
While Fred Nile is committed to supporting the government, we are talking about one of god's creatures likely to become extinct in the wild by 2050.
- Fred Nile (02) 9230 2478 < [email protected]>
Priority asks are:
- Retain the requirement that core Koala habitat identified in Koala PoMs be identified as State Sensitive Regulated Land under the Local Land Services Act, with current protections from logging and broadscale clearing maintained.
- Retain the ability of Councils to prohibit, or require consent for, logging and clearing in environmental zones.
- Do not extend logging approvals from 15 to 30 years, or at the very least ensure that they are required to comply with updated and contemporary Codes of Practice that take into account new knowledge (not just those given at the time of approval).
Some others you may want to mention:
- Maintain the existing prohibition on logging in Koala habitat identified in Koala PoMs for Ballina, Coffs Harbour, Kempsey, Lismore, Bellingen and Port Stephens LGAs.
- Maintain existing classification as State Sensitive Regulated Land for core Koala habitat identified in Bellingen Shire's KPoM.
- Ensure core Koala habitat identified in Campbellown's KPoM is classed as State Sensitive Regulated Land where appropriate.
- Ensure core Koala habitat already identified in draft Koala PoMs in Port Macquarie-Hastings (Coastal, 2018), Clarence Valley (Ashby, Woombah & Iluka localities, 2015), Byron (Coastal, 2016) and Tweed (Coastal, 2015) Local Government Areas is included as State Sensitive Regulated Land, and that Councils are allowed and encouraged to include it in environmental zones (E2).
Please contact other members as time allows.
While the legislation has already passed the Lower House it is still important to let the Government know how disgusted we are, particularly:
The Hon. Gladys Berejiklian, (02) 8574 5000, Contact the Premier,
The Hon. Rob Stokes, (02) 8574 6707, Contact the Minister for Planning and Public Spaces
The Hon. Matt Kean, (02) 8574 6150, Contact the Minister for Energy and Environment
The Hon. Geoff Provest, (07) 5523 4816, [email protected]
The Hon. Leslie Williams, (02) 6584 0977, [email protected]
The Hon. James Griffin, (02) 9976 2773, [email protected]
The Koala SEPP has already been changed:
- The Koala Development Application Map has been removed. This is the pink map the Nationals focused on and misrepresented, despite the Government deciding to remove it months ago –as the Nationals knew.
The 28 May 2020 Koala Strategy Board Meeting was informed the maps would be removed, on 21 August Stokes wrote to Barilaro that the 'Pink DA map’ would be removed and they would 'revert to a survey process which existed under SEPP 44'.
- The definition of Core Koala Habitat has been altered to only apply to “highly suitable koala habitat” where Koalas have been recorded within the past 18 years, removing the broader criteria “an area of land where koalas are present”.
- Councils are now required to consult with the Chief Executive Officer of Local Land Services when developing a Koala PoM
The Koala Habitat Protection Guideline has been changed:
- Landholders can ‘stop the clock’ to request an additional 60 days to object to proposed core koala habitat on their land, which has to be reassessed at Council’s expense.
If passed the Local Land Services Amendment (Miscellaneous) Bill 2020 will:
- Stop core Koala habitat identified in draft and future council Koala Plans of Management from being included as Sensitive Regulated Land, and thereby require approval for broadscale clearing,
- Remove the prohibition on logging of identified core Koala habitat.
- Allow up to 6,000 ha of core Koala habitat identified as Sensitive Regulated Land in the Ballina, Coffs Harbour, Kempsey, Lismore and Port Stephens LGAs to remain, though remove 900 ha of core Koala habitat identified in the Bellingen LGA
- Stop Councils being able to include core Koala habitat in environmental protection zones.
Ben Franklin stated in parliament ”e-zones will not be created in relation to any koala plans of management”
- Create the concept of ‘allowable activity land’, which is land that at some time has been rezoned from rural zoning to environmental zoning, and permits clearing for ‘allowable activities’ (including buffers) without approval in these E zones
allowable activities include construction timber, farm forestry, gravel pits, grazing, powerlines, water and gas pipelines, fire breaks, fences, roads, tracks, sheds, tanks, dams, stockyards, bores, pumps, water points or windmills. The Government is now intending to allow clearing within 25m of property boundaries.
- Prevent local environment plans from requiring development consent for Private Native Forestry (PNF)
- Double the duration allowed for PNF plans from 15 years to 30 years.
Feel free to reply to this email with questions or news on how you went.
Thank you for speaking up for koalas survival!
Koala State Environment Planning Policy (SEPP) Changes
If the Powerpoint doesn't load below: you can download it here.
Proposed Sandy Creek Koala Park
Dailan Pugh, North East Forest Alliance, August 2020
NEFA are proposing that 6,988ha of public land south-west of Casino in north-east NSW be created as the Sandy Creek Koala Park, comprised of Royal Camp, Braemar, Carwong and Ellangowan State Forests, and remnant native vegetation on land purchased for plantations. The Bandjalang clan are the recognised native title holders and so the future management of this reserve needs to be determined in consultation with them.
The genesis of this proposal was the finding of exceptional densities of Koalas at a number of localities and widespread Koala usage. The Koalas appeared to be increasing as the forests recovered from past logging, with good future prospects if the forest was allowed to age and provide increasing resources over time.
The Koalas suffered a mortal blow when the Busby's Flat fire swept through the proposal on the night of 8 October 2019, with the apparent loss of 78-89% of Koalas, which suggests the loss of 270-310 Koalas due to the fires and a surviving population that could be as low as 40-80 Koalas.
As most Koala feed trees survived the fires, Koala populations can recover over time and increase if survivors and their habitat are protected. Given the prognosis that Koalas are likely to become extinct in the wild by 2050 if we continue 'business as usual' , and the devastating impact of the 2019 fires on the Banyabba Koalas, protecting an area where Koala populations can recover is more important than ever.
Saving Banyabba Koalas
On 3 March 2020 the Environment Protection Authority (EPA) approved the Forestry Corporation to undertake logging of burnt Koala habitat in three State Forests on the Richmond River lowlands. Given the failure to account for the landscape scale impacts of the fires on this Koala population, this approval was irresponsible and jeopardises the Koala's recovery, and possibly the survival of this population.
The EPA are requested to immediately withdraw their approvals for logging of Koala habitat in Bungawalbin, Doubleduke and Myrtle State Forests and do due-diligence by assessing the landscape impacts of the fires on Koalas. As shown by this example, a moratorium is needed on further logging of populations of all species significantly affected by the fires until surveys are undertaken to assess their vulnerability.
The approved logging is in parts of the 142,000 ha Banyabba Area of Regional Koala Significance (ARKS) that had 83% of its modelled 71,000 ha of 'likely' Koala habitat burnt in the 2019 wildfires, with the apparent loss of 90% of Koalas from burnt areas.
NEFA have been particularly focussed our efforts on the conservation of Koalas since we caught the Forestry Corporation illegally logging Koala High Use Areas in Royal Camp State Forest in 2012.
We are gravely concerned that Koala populations on the north coast have crashed by 50% over the past 20 years, and that the increase in land clearing and reduction in logging rules will likely see them made extinct in the wild within the next 20 years.
Within a given area Koalas will firstly select feed trees based on species, and secondarily on size, preferring trees over 30cm diameter, with use increasing in line with tree size. They also utilise understory trees for shelter on hot or windy days. In good habitat they have stable home ranges, with a male overlapping a number of females. Logging is targeting the mature trees preferred by Koalas for feeding, with less feed trees there are less Koalas and social systems can break down.
For the past 20 years the Forestry Corporation were meant to thoroughly search for Koala scats (faecal pellets) ahead of logging. Where small numbers of scats are found token feed trees (5 of any size per ha) were required to be retained. Where there were abundant scats they were required to protect small areas around the scats as Koala High Use Areas. Because the Forestry Corporation normally refused to do thorough searches, and because of the minimal protection when found, only some 13 hectares of Koala habitat were protected in any year, and they are allowed to log these next time around. On private land there are few records of Koalas and no need to look before they log, so most Koala habitat is indiscriminately logged.
The Government has decided to remove the need for the Forestry Corporation to look before they log and are instead protect 10 Koala feed trees per ha over 20cm diameter in modelled high quality habitat and 5 per ha is medium quality habitat. The EPA recommended that it should be 25 feed trees per ha over 25cm diameter in high quality habitat and 15 trees per hectare in moderate quality habitat. The NRC over-rode the EPA to support the Forestry Corporation.
The 2018 OEH submission to the IFOA laments that there will "be a reduction in protections offered to koalas", with Koala feed tree retention rates "less than half those originally proposed by the Expert Fauna Panel", noting:
"The increased logging intensity proposed under the draft Coastal IFOA is expected to impact Koalas through diminished feed and shelter tree resources. Animals will need to spend more time traversing the ground as they move between suitable trees that remain, which is likely to increase koala mortality".
It is outrageous that 43% of the high quality Koala habitat on State Forests identified by DPI-Forestry is in the North Coast Intensive Logging Zone where clearfelling will be the norm.
On the north coast Koala populations have crashed by 50% over the past 20 years because they generally prefer the more productive forests left on the coastal floodplains and foothills, the forests that have been most targeted for clearing, logging and urbanisation. If Koalas are to be given a chance it is essential that all remaining colonies be identified and fully protected.
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).
The North East Forest Alliance has proposed that the 2,100 ha Sandy Creek National Park be created over an important Koala population in Royal Camp and Carwong State Forests, south-west of Casino.
We are seeking the protection from clearing and logging of all resident Koala populations across the north coast of NSW.
Dailan Pugh, March 2019.
This review focuses on assessing recent logging by the Forestry Corporation of Koala Hubs as identified by the Office of Environment and Heritage.
The Office of Environment and Heritage (OEH) have analysed Koala records "to delineate highly significant local scale areas of koala occupancy currently known for protection", which they term Koala Hubs. Based on the data then available these are the known highest priority areas for Koala protection in NSW to increase their survival prospects.
Koala populations in NSW are in precipitous decline. The threats are immense in coastal areas (where most hubs are), making the protection of the 19,785 ha of Koala Hubs on State Forests in hinterland areas the highest priority for the basis of a Koala reserve system to safeguard core Koala populations and begin to stabilise Koala numbers.
Further work has been undertaken by WWF which identifies Koala Reserves based on a broader analysis of Koala Hubs, though this assessment is limited to Koala Hubs as identified by OEH.
This review found that of the OEH Koala Hubs on State forests in north-east NSW, 2,546 ha has been logged over the 4 year assessment period 2015-2018, which is an average of 636 ha logged per annum within Koala Hubs. It is assumed that some 430 ha of Koala hubs have so far been logged since they were identified. Many more are proposed for logging in current harvesting plans,
Outside exclusion zones and plantations there are 12,253 ha of Koala Hubs identified on State Forests, which means that over the past 4 years 21% of the loggable area of Koala Hubs within native forests on State Forests have been logged. Many of these have been logged well in excess of allowable logging intensities, with significant areas subjected to the unlawful logging practices of heavy and regeneration Single Tree Retention.
Of the 2,546 ha logged from 2015-2018, 1,283 ha (50%) has been modelled by DPI Forestry (Law et. al. 2017) as high quality Koala habitat and 574 ha (23%) as medium quality habitat. There are also 590 Koala records within the logged areas of the Koala Hubs. These confirm the importance of these areas for Koalas, and emphasise that this should have been well known to the Forestry Corporation before they logged them.
Over the period 2015 to March 2017 in the Lower North East forestry region, of these logged Koala hubs 22 ha is identified as being subject to the unlawful logging regimes of Regeneration Single Tree Retention (STS), 116 ha to heavy STS, and 348 ha to medium STS. It is evident from Harvesting Plans that intensive logging of Koala Hubs is more widespread than indicated by these figures, which is also shown by satellite images. This shows that many of these Koala Hubs, and surrounding areas, were subject to more intensive logging than the logging rules allowed.
It is essential for the future of Koalas that a moratorium be immediately placed on all remaining OEH Koala Hubs on State Forests, along with potential habitat within one kilometre, while further ground based assessments are undertaken to delineate the full extent these "highly significant" resident populations which, based on current records, are the highest priority for protection on public lands.
You can read the full review document here: Forestry_Logging_of_OEH_Koala_Hubs.pdf
Illegal logging of Koala habitat at Gibberagee State Forest prompted peaceful action as shown in the NEFA video below.
Dailan Pugh, North East Forest Alliance, March 2019.
The one survey relied upon by the timber industry to justify the ongoing logging of Koala habitat was undertaken by the forestry unit of the Department of Primary Industries, who are not independent and whose data do not justify their subjective conclusions.
There are far more robust studies that shows that Koalas are declining on State Forests and that this will be exasperated by the increased logging intensity, reduced retention of mature trees and reduced exclusions allowed by the new logging rules.
The DPI-Forestry1 survey used acoustic recorders to record male Koala calls for a week during the breeding season at 171 sites in modelled medium-high quality Koala habitat throughout northern NSW, recording one or more calls at 106 sites.
The biggest failing of the DPI-Forestry assessment is that it is based on extrapolation from just the calls of male Koalas somewhere within 300m (or more2) of the recorder, with no indication of whether other Koalas were present or whether it was just a transient male searching for a mate.
Forestry's current rules for identifying a high use Koala tree is that it has to have more than 20 Koala scats (faecal pellet) under it, and a Koala High Use Area has to have an additional 3 out of 10 trees searched with scats under them.
The only ground-truthing reported3 for Koala occupancy in the DPI-Forestry study were searches of 40 trees at each of 65 sites for Koala scats, with no scats found at 54 sites and just 1-2 scats found at 11 sites.
Koalas were recorded calling at 19 of the 65 ground-truthed sites, with no scats found at 16 sites and only single scats found at 3 sites. This indicates either a very low usage by Koalas or that the calling Koalas were outside the sampled area.
Half the sites recorded only1-3 calls over 7 nights in the breeding season, which does not indicate the presence of a breeding colony anywhere nearby.
It is particularly significant that any Koalas calling could have been hundreds of metres away or transient. Given that measurements of habitat variables were made within 50m of the recorders it means the variables measured (i.e. tree species, tree cover, stand structure, logging intensity) and used in analyses are not necessarily indicative of where Koalas live.
Both DPI-Forestry and the industry conveniently ignore other more robust research that has found Koalas prefer the larger trees targeted by loggers and that their populations are declining on State Forests.
A 2016 EPA study4 found that higher Koala activity was positively correlated with trees and forest structure of a more mature size class, and areas of least disturbance, concluding that once high quality Koala habitat in Clouds Creek and Maria River State Forests had been degraded and now have declining Koala populations.
A 2004 study5 by Dr. Andrew Smith of Pine Creek State Forest found that Koalas preferred structurally complex, uneven-aged forests with some mature and oldgrowth elements and a large basal area, concluding that modern high intensity harvesting practices that remove a high proportion of stand basal area and leave only small diameter stems (<50 cm diameter) are incompatible with koala conservation.
A 2013 Biolink6 study for Port Macquarie-Hastings Council found that State Forests had less than half the number of active Koala sites than nearby National Parks and concluded that logging had decimated the once substantive local Koala populations.
Whatever its shortcomings, the DPI-Forestry survey7 is based on past logging regimes where they attribute the persistence of Koalas near their sites to half the surrounding area being excluded from logging, including in riparian buffers, old growth and rainforest exclusion areas and Koala High Use Areas, as well as the retention of mature trees, habitat trees, recruitment trees and feed trees for other species in logged areas.
The NSW Government's new logging rules have doubled logging intensity, zoned 140,000 ha of coastal forests for clearfelling, removed the need to retain mature trees (including recruitment and most eucalypt feed trees), reduced the buffers on headwater streams and is intending to open up protected oldgrowth forest for logging. This will significantly increase impacts on Koalas.
Specifically for Koalas they are removing the need to look before they log and protect Koala High Use Areas, despite DPI-Forestry finding that Koala High Use Areas have 3 times the Koala call rate of recently logged forests.
In their submission to the new logging rules, the Office of Environment and Heritage8 complained in 2018 that the new Koala feed tree retention rates are less than half the number and of a smaller size than proposed by the Expert Fauna Panel, concluding that the increased logging intensity proposed under the new rules is expected to impact Koalas through diminished feed and shelter tree resources.
It is ironic that DPI-Forestry refer to a Forestry Corporation radio-tracking study2 in the early 1990s near Eden NSW to justify their claim that koala home ranges can comprise a mosaic of regrowth and unlogged habitat, as that population was extinct a few years later9.
Now history is repeating itself as the Forestry Corporation use dodgy science to deny impacts while introducing an Eden-style alternate coupe clearfelling regime into 140,000 ha of what they identify as the best Koala habitat on the north coast.
To download a copy of the document or to see the references click here.
NEFA President Dailan Pugh, OAM presentation at the Nature Conservation Council (NCC) Koala Forum in Lismore December 12th, 2018
You can find NCC's Koala campaign here: https://www.nature.org.au/koalas
Koalas and Logging of Public Lands
Koalas and Loggers prefer larger trees. Koalas preferentially select individual trees of preferred species for feeding. They prefer larger and older trees because they: provide more forage have less toxins are more stable and comfortable. You can read Dailan's powerpoint presentation here:
Koalas and Logging of Public Lands.
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)
If there is a genuine desire to stop the slide of NSWs Koalas into extinction then the primary requirement is for the current NSW Premier to direct her Ministers and their agencies to implement the intent of current legislation. We don't need to reinvent the wheel, we just need to make what we have work better.
She needs to direct that the agencies immediately identify and protect remaining core Koala habitat and habitat linkages across all tenures. This will require the allocation of significant resources to undertake the required mapping of core Koala habitat and to provide financial incentives to private landowners to conserve core Koala habitat in perpetuity. There is also a need to rehabilitate degraded habitat and to replant essential habitat linkages.
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.
Authorised by Daniel Peterson for the North East Forest Alliance at 115 Molesworth Street, Lismore, 2480
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