The RFPG January 2020 submission to the Office of the Conservation Regulator's (OCR) draft field guide for old growth forest (OGF) identification highlights five key issues:

• Risks associated with over-reliance on 'undisturbed old growth forest' as comparitor in the OGF determination;
• Need for a comprehensive photo album to complement the technical descriptors;  
• Implications of global warming and increasingly frequent mega-fires for describing the growth, maturation and senescence of old growth forests;
• Dangers of using timber harvesting terms (such as 'advanced regrowth') in determining old growth status; apparently designed to give VicForests carte blanche in logging post 1939 forests; 
• Inconsistency of OCR's OGF definition with that included in the National Forest Policy Statement (1992).

The development of a reliable and scientifically informed field guide for identifying old growth forest emerged from the Victorian Government's commitment, announced in November 2019, to immediately end the logging of old growth forests.  

Forest conservation organisations were concerned that rather than protecting old growth forests stands the new policy might be used to open up previously protected stands to logging. 

At the time of posting the revised field guide has not been published. 

8 July 2020