Under the 1992 National Forests Policy Statement (NFPS) state governments are committed to developing and maintaining their own codes of forest practice, however named.

In speaking about the role of the codes the NFPS notes (p10) that,

Forest management agencies will continue to assess forest areas for the purpose of developing strategic management plans and, where necessary, operational harvesting plans. As a consequence of these forest assessments, areas that have important biological, cultural, archaeological, geological, recreational and landscape values will continue to be set aside and protected from harvesting operations or managed during operations so as to safeguard those values.

Measured against this commitment the Victorian Code of Practice for Timber Production 2014 has been a failure, certainly in the Rubicon State Forest.

The Victorian Code needs to be read in conjunction with the Management Standards and Procedures for timber harvesting operations in Victoria’s State forests 2014 which specifies in more detail the principles of the Code.

The provisions of the Victorian Code and the Management Standards are particularly weak where forest biodiversity and scenic values are concerned.  Its shortcomings include absurdly narrow protective buffers, inadequate protection of retained trees in regeneration burns, and an outdated schedule intended to protect tourist routes.

Section 2.1.1.1 (vi) of the Code provides that “Long-term forest management planning must … minimise adverse visual impact in landscape sensitivity areas”. Section 5.3.1 of the Management Standards provides for protection of landscapes of scenic importance.  However, most of the provisions of this section are restricted to scenic routes and vistas specified in Table 9 of Appendix 5 of the Standards and excludes vistas from roads with great tourist potential and only requires 50 m buffers along all of the specified roads.

See also Table 12, Habitat tree prescriptions; Table 13, Rare or threatened fauna and invertebrate prescriptions; Table 14, Rare or threatened flora prescriptions; Table 15, Management of historic places; Table 17, Landscape management prescriptions; and Table 18, Road classification system.

Poor specification of a rule that limits the size of an overall area being logged in a 5 year period allows it to be routinely flouted.  Rule 3.1.1.5 provides that,

The size of clearfall, seed tree harvesting or shelterwood coupes should generally not exceed 40 hectares net harvested area. Coupes may be aggregated but not exceed 120 hectares net harvested area over a period of up to five years. Aggregated coupes must not be contiguous (forming a coupe greater than 120 hectares within a five year period).

In the Rubicon State forest there are several such offending areas with more likely.  In other areas there are likely to be many more such breaches, especially in coming years as harvestable areas dwindle.

DELWP undertakes Forest audits to monitor compliance with the Code. As of August 2017, there are no audits mentioned or audit reports published since 2015. DELWP also undertakes investigation of breach allegations through Forest reports. It is the experience of the RFPG that the investigations of breach allegations can take years to finalise and logging proceeds apace during such investigations.  There is good evidence that drawing out investigations is being used to avoid responding to FOI requests.

The RFPG calls for an independent public inquiry into the provisions and enforcement of the Code of Practice for Timber Production 2014.

RFPG calls for a community based scheme for monitoring logging practices and reporting possible breaches along the lines of the ‘official visitors’ scheme which operates in the mental health and disability sectors.