In a hard hitting submission (here) to DELWP's independent review of its timber harvesting, the RFPG:

• describes the Group's experience of timber harvesting breaches;
• presents extensive evidence of sloppy administration and lack of transparency;
• argues that the regulator (DEWLP) has been 'captured' by the industry it is supposed to regulate; 
• recommends that the compliance monitoring and regulation function be transferred to an arms length independent regulator, perhaps the EPA;
• argues that VicForests' planning activities be made appealable at VCAT;
• demands an urgent review of the Code of Forest Practice; 
• urges a review of the Timber Allocation Order. 

However, the RFPG also comments on the absurdity of reviewing the adequacy of regulation after egregious policy failure has allowed the exhaustion of this resource (for at least 20-30 years) and continues to allow unsustainable harvesting of the fragile remnants. The RFPG calls upon the Review to conclude that regulatory failure is a consequence of policy failure and that unless the latter is addressed the focus on compliance is a red herring.

Overshadowing any consideration of the regulation of timber harvesting is the exhaustion of timber supply in Victoria’s state forests. Our 2016 publication, Unsustainable!, sets out why the logging of the ash forests of the Rubicon State Forest and Central FMA since the 2009 bushfires is completely unsustainable, both in terms of the ecology and biodiversity of the area and in terms of log supply. 

Continued over-logging of the Rubicon State Forest is a consequence of the over-commitment of wood supply in the Forests (Wood Pulp Agreement) Act 1996 which was unsustainable in ecological terms but which also failed to make any allowance for the effect of bushfires on wood supply. (For more background on this key piece of the jigsaw see Samantha Dunn, Hansard, 22 Aug 2018 here.)  Since 2009 the scale and intensity of logging in the Rubicon State Forest has increased dramatically. See serial landsat images of logging in the Rubicon State Forest.

7 October 2018

The Review

At the request of the Minister for Energy, Environment and Climate Change, the Victorian Department of Environment, Lands, Water and Planning (DELWP) has commissioned an independent review of its timber harvesting regulations.

The independent review panel, led by Nial Finegan supported by Peter Rozen and Jane Brockington will assess forestry and timber harvesting compliance operations. The Terms of Reference for the Review are available here. The address for submissions is timberharvesting.review@delwp.vic.gov.au.