Following the finding of yet more widespread and ongoing breaches of logging laws, the North East Forest Alliance is calling on the Baird Government to restore the rights of the public to take the Forestry Corporation to court to enforce environmental laws,
"If the Baird Government refuses to enforce the logging rules, then let us do it" said NEFA spokesperson Dailan Pugh.
"For years we have been finding the same sorts of logging offences, time after time after time. The Forestry Corporation are being allowed to flout environmental laws with impunity. The Environmental Protection Authority's (EPAs) lax regulation is clearly not working".
It took a freedom of information request, by the North Coast Environment Council, but the Environment Protection Authority have finally released the membership of the Threatened Species Expert Panel advising on the re-writing of the logging rules for public forests.
The documents show that far from being independent experts they are Government employees, dominated by current and former employees of Forestry Corp.Read more
The North East Forest Alliance has condemned commitments by the Liberal-National Coalition today to repeal the Threatened Species Conservation Act 1995 and the Native Vegetation Act 2003.
“The proposed changes would be an environmental disaster and setback conservation in NSW 25 years,” said NEFA spokesperson, Dailan Pugh.
NEFA makes submissions to the NSW Government on a wide range of issues affecting our forests. These detailed submissions can be found using the hyperlinks to the relevant topics below.
North East Forest Alliance submission to:
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.
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 began 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 continue to decline and the 2020’s will see massive reductions. (see The Battle for Sustainable Yields is Lost).
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).
Forestry operations have a profound impact on native plants and animals. Natural forests are normally multiaged, with large numbers of big old trees providing hollows for nesting and denning, along with abundant nectar and seed resources. They also contain mature and young trees providing for succession as trees senesce and die. The understorey may naturally be open and grassy or more often is comprised of a wide diversity of understorey plants providing nesting sites, foraging habitat, and essential food resources for a suite of species. Even the dead trees and logs are critical habitat for numerous species.
In general, forestry aims to remove the mature trees for timber and get rid of the big old trees and unsuitable species that suppress regrowth of commercial species. Understorey and logs are just impediments. The outcomes are often a mess due to loss of critical habitat trees, early removal of potential sawlogs, excessive damage to retrained trees, poor regeneration, escaped burn-offs, significant soil erosion, stream pollution and massive weed invasion.
Plants are killed by logging, trampling with machinery, burning and being smothered by weeds. Animals are directly killed in falling trees and by being crushed in logs and burrows, and slowly by loss of dens, nest sites, territories and essential food resources.
Of those 175 animal species identified as being of particular conservation concern in north-east NSW, a total of 7 mammals (excluding bats), 27 bats, 31 birds, 16 frogs, 5 turtles, 15 lizards and 8 snakes were identified as being specifically vulnerable to logging, with many of these species, and a number of others, also vulnerable to the associated fire regimes, hydrological changes, stream pollution and weed invasions. For 41 of these 109 species logging is identified as a primary (number 1) threat. (see Threatened Species).
In a natural forest rainfall is mostly intercepted by the canopy or absorbed by the ground cover. Subsurface flows of excess waters then generate streamflows. In logging operations the reduced canopy and widespread soil compaction and baring result in overland flows that transport large volumes of sediments and nutrients directly into streams where they have significant long-term impacts on stream biota (see Logging impacts on streams). Impacts on stream flows are also long lived as the regrowth forest has high water demands and there is less surplus for streams (see How Forests Regulate Streamflows).
It is obvious that if we want to limit the impacts of logging on native species, soils and streams then we need to restrict the scale and location of activities we allow to occur. Regulation of forestry activities was found to be necessary because of the Forestry Corporation’s repeated failures to voluntarily minimise their impacts (see The Battle to Protect Threatened Species, The Battle to Protect Soils and Streams).
Forestry operations on public lands in north east NSW are governed by the Integrated Forestry Operations Approvals (IFOA) for Upper North East Region and Lower North East Region, and the licences they contain. These are referred to as Environmental Protection Licence (EPL), Threatened Species Licence (TSL) and Fisheries Licence (FL). Together with various clauses of the IFOA these constitute the regulatory regime applied to forestry operations on the public’s state forest lands in north-east NSW
The Integrated Forestry Operations Approval is one of the means by which NSW implements obligations and undertakings given in the joint NSW and Commonwealth North East NSW Regional Forest Agreement (Cl 36,48) and is the principal vehicle by which Environment and Heritage Values that are impracticable to include in reserves can be considered. The IFOA, along with the CAR reserve system, is required to provide for the protection of rare or threatened flora and fauna species and ecological communities (Cl 60). A key requirement is to monitor and review the sustainability of forest management practices (ie Cl 53), which includes the IFOA (Cl 52).
While we now have a comprehensive regulatory process for the management of State forests, the prescriptions are inadequate because they are the result of numerous political compromises with expert opinions and evidence often ignored. Neither have they been subject to monitoring and expert review. Even the minimalist prescriptions now applied are routinely flouted by the Forestry Corporation. (see Protecting Exclusion Areas, Doing Surveys, Protecting Threatened Fish, Protecting Habitat Trees).
NOTE: The Forestry Corporation has undergone many name and structural changes since the Forestry Commission of NSW was first formed in November 1916. In August 1993 the Forestry Commission adopted State Forests of NSW as its trading name and was overseen by a board of Governance. Nothing much changed on the ground. In November 2005 the Forestry Commission again tried to change its image by adopting the new brand name of Forests NSW. On 1 January 2013 Forests NSW was corporatized and became the Forestry Corporation. These names are used interchangeably throughout this site, though to avoid confusion attempts have been made to use the name Forestry Corporation to apply to all incarnations.
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).
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
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.
The allocation of Crown land for conservation dates back to 1866 in NSW, with the first National Park created in 1879. Since then it has been a slow and tedious process to construct an effective reserve system in north-east NSW. NEFA was instrumental in achieving a doubling of reserves (See: A Short History of Reserves in North East NSW).
Reserves have been established for recreation, scenic qualities, heritage values, and flora and fauna conservation. It has been community agitation that has been primarily responsible for public land being set aside for conservation, with destructive uses such as logging, mining and grazing generally excluded.
Vested interests have led the fight against reservation of crown land for conservation. Historically they were successful in largely limiting reserves to the least productive areas with limited commercial potential.
In 1992 the National Forest Policy committed all Australian Governments to establishing Comprehensive, Adequate and Representative reserve systems for forests based on explicit national reserve targets (See: CAR Reserves). This was meant to be a way forward to ensure that reserves encompassed representative samples of all ecosystems and species while being of adequate size to maintain viable populations of flora and fauna into the future.
The process leading to the 2000 Regional Forest Agreement (RFA) for North East NSW did result in a significant increase in the reserve system in north-east NSW based on sound data and targets. Though unfortunately politicians once again bowed to pressure from vested interests and intervened to stop the promised CAR reserve system from being established (See: CAR Reserves).
Despite north east NSW’s forests being one of Australia’s and the world’s biodiversity hotspots, the reform process still left us with one of the worst forest reserve systems in Australia, and many of the national reserve targets unmet. There remains an urgent need to expand north east NSW’s reserve system to achieve the basic requirements of a CAR reserve system, particularly in light of the accelerating impacts of climate change.
Due to the conservation of more productive lands in recent decades, the vested interests are now campaigning to have reserves opened up for logging and grazing. The pretence is that they need to be logged for “ecologically thinning” and grazed for fire protection.