In November there was a major breakthrough for Victoria’s forests: the Andrews Government admitted that logging the state's native forests is unsustainable and as a result promised the immediate protection for 90,000 hectares of old growth forest and an immediate ban on logging old growth. In light of the announcement, the Victorian Government is seeking input from the community about the process it will use to verify the presence of old growth forest, to protect 90,000 hectares and ban timber harvesting in these precious ecosystems.
Why does the government need to hear from me?
The Victorian government is seeking your input into the procedure it will use to verify the presence of old growth forest. This will help it fulfil its promise to protect 90,000 hectares and to ban logging of old growth forests for good. By answering this survey, you can help shape the final guidelines that are set to be released in early 2020, ensuring the grand, ancient forests of Victoria will stand for generations to come.
But hurry—survey closes 10 January 2020.
How do I complete the survey?
Below we've compiled some tips and suggestions on how to respond to the survey. As with any submission, putting the points in your own words will have the biggest impact.
Transparent
1a. How well does the procedure provide the information required to be able to assess old growth forest?
- What the procedure says: the procedure does not provide the information required, as it requires the absence of old growth forest to be determined to facilitate logging; instead, the emphasis must be on identifying the presence of old growth forest to facilitate protection
- How the procedure will be deployed: the procedure does not provide the information required, as government is relying on its logging agency, VicForests, to use this procedure to gather the information required to be able to assess old growth forests
- Where the procedure will be deployed: the procedure does not provide the information required, as the procedure is only required to assess for the presence (not absence) of old growth forest outside the 90,000 hectares committed for immediate protection—which must be immediately protected and does not need this procedure applied to it.
1b. What additional information should be included in the procedure?
- The procedure takes a ‘one size fits all’ approach to assessing old growth forest; it needs to also require assessment of old growth in the context of the known variations in structure and composition of flora types in old growth forests in the different Ecological Vegetation Classes (EVCs) across the state.
- As the procedure is to be implemented by “the native timber harvesting sectors (including VicForests)” (p. 1) it must apply to any potential future variant of VicForests as well.
- The procedure should contain specific legally binding enforcement and regulatory procedures which allow significant penalties to be applied for non-conformance.
Simple
2a. How easily do you think this procedure could be applied in the field?
- The OCR states that it is important the procedure is clear and well understood by the community; however even more critical is that the procedure is clear and well understood by the native forest logging sector including and especially VicForests.
- The procedure is perhaps already too simple, as at every stage of the survey method, there is ample opportunity to incorrectly determine old growth.
- VicForests has consistently demonstrated an inability to either understand, let alone adequately implement field variation procedures (e.g. correct utilisation of the rainforest differential species key) so there is little confidence that the procedure will be easily—let alone correctly—applied in the field by VicForests.
2b. How could we make it simpler to use this field guide?
- It is not a question of simplicity, it is a question of effectiveness, and Government must not rely on its logging agency, VicForests, to decide what is and isn’t old growth and assessments by other, trusted and expert assessors are essential.
- Any simplification of the procedure risks weakening an already problematic tool.
- Forests are complex, old growth especially so, and, where government intends to log old growth forest, and/or insists on verification to identify it, simplified management is not the solution.
Consistent and repeatable
3a. Does the procedure provide a consistent and repeatable approach?
- Given government has categorically stated that native forest logging is unsustainable, it is problematic in the extreme for the logging regulator and the OCR to be designing a tool to allow for timber harvesting to “occur in a sustainable way” as is stated on p.4 of the procedure.
- Rather than it simply being an “idea” to do as many or few sampling lots (p.14 of the procedure) as is necessary to confidently confirm or discount the presence of old growth characteristics, this should be a requirement.
- Improper and inconsistent use of the procedure is likely at all stages, especially given it doesn’t make specific reference to Ecological Vegetation Classes (EVCs), floristic composition of forest types, or acknowledge the role of diverse and mature understorey—an important feature of old growth forests.
3b. If not, why not and how could we improve this?
- If the procedure is repeatable for application in a target of 80% of coupes, this should be augmented to 100%—indeed to ensure an effective ban on all old growth logging 100% of coupes need to be assessed and verified by entities other than VicForests.
- By mitigating against the impacts of drought being overemphasised, given that sensecing old growth forests can be similar in appearance to drought affected forests—reconsider the role of drought as a disturbance factor.
- Set out a requirement for minimum buffers surrounding any old growth forest, as the edges of these forests will be exposed to wind and natural elements, the impacts of logging activities, as well as post-logging burns. Adequate buffers are required to actually protect old growth forest stands.
Efficient, targeted and fit for purpose
4a. How well do you think the procedure will identify and ensure protection of old growth forests?
- As the OCR will only “advise” VicForests and contractors on the identification and protection of old growth forests, and as the OCR only “expects” this survey method to be applied in a consistent manner, there is little confidence the procedure will identify and ensure protection of old growth forests—to improve this, government should instead require independent oversight, clear and concise regulatory procedures, and most importantly, not leave VicForests to wantonly declassify old growth forests.
- The survey procedure must be complemented by effective implementation and regulation of big old tree protections
- There is a very high risk that this tool will assist in justifying and allowing logging in old growth forest; the aim of the procedure appears to be to determine the absence of old growth forests, throughout the procedure there are ample opportunities for VicForests to discount the presence of old growth and therefore to declassify old growth, rather than protect it.
4b. How could we improve the procedure to protect old growth forests?
- OCR inspections of the operations of the native forest logging sector, including VicForests, must be conducted at all stages -- this means pre- during- and post- timber harvesting. Given there is no way to retrospectively confirm old growth after logging, there will be little evidence as to whether VicForests has complied, and therefore all regulatory action and efforts should be determined prior to timber harvesting and must be done with extreme care and in a rigorous way.
- Reduce timber volume settings which currently act as a disincentive for the identification of old growth forest . Incentivise or encourage the native forest logging sector, including VicForests, to choose ‘no’ in response to the procedure’s question: “Is the disturbance pervasive?” as timber volume settings and requirements mean there is a propensity for VicForests to choose yes to this question, and therefore declare that forest does not meet old growth criteria and can therefore be logged.
- Rather than simply “encouraging regulated parties to comply with the law” the survey method must be used to require regulated parties to comply with the law.
Additional information
5. Do you have any other feedback on the procedure for identifying old growth forests?
The aim of this draft procedure appears to be to discount areas of old growth, not protect them. That is fundamentally flawed and inadequate for meeting government commitments to protect all old growth forests.
Assessments using this procedure are only required outside the 90,000 hectares of old growth forest promised for immediate protection and must only be done as a precautionary measure to ensure an effective ban on logging in all old growth forest —not to facilitate logging.
Government has committed to immediately protect 90,000ha of old growth forests. The first step is to ensure no logging coupes are scheduled inside the 90,000 hectares of mapped modelled old growth.
This procedure is only required to assess for the presence of old growth outside that area, in order to enact an effective ban on logging in old growth, in line with government’s promise that it would immediately ban logging in all old growth forests.