11 September 2020

The RFPG has written to the Victorian Auditor-General regarding his current audit of the Government's biodiversity plan, 'Biodiversity 2037'. 

The submission (here) sets out five broad propositions for the AG to consider: 

1. There are stark contradictions between the Victorian Government’s forest conservation obligations (mandated in the Sustainable Forests (Timber) Act 2004 and the Code of Practice for Timber Production) and its timber supply commitments (in particular those arising from the Forests (Wood Pulp Agreement) Act 1996). The extent of timber harvesting required to meet VicForests’ supply contracts is simply incompatible with maintaining the biodiversity of Victoria’s native forests as the SF(T)Act and the Code require.
2. The ecological integrity of the native forests of the Central Highlands is being degraded. Year by year these forests are drier, younger, are losing understory, and are infested with weeds and pests. Forest biodiversity is being degraded by bushfires and logging. The resilience of these forest ecosystems, in the face of a warming climate and wider, hotter and more frequent bushfires, is being actively undermined by unsustainable logging. Ecological collapse looms large along this trajectory.
3. The Code includes a range of provisions governing the operations of VicForests which are designed to ensure ecological sustainability (including the preservation of biodiversity). VicForests breaches these provisions with impunity. The conservation regulator routinely fails to detect and prosecute breaches of the code. Unfortunately, owing to its timber supply commitments, VicForests is obliged to breach code provisions. The conservation regulator is obliged to turn a blind eye to such breaches. Government ministers are obliged to okay the draft timber release plan (TRP) proposed by VicForests. The VicForests board is obliged to authorise a TRP which rubber stamps the harvest areas that VicForests management needs to fulfil its supply contracts.
4. Continued native forest logging runs directly counter to all three of the slogans of Biodiversity 2037: explore nature; connect with nature; and protect nature.
   1. Explore nature; Connect with nature. The Rubicon State Forest has huge untapped potential for nature tourism. It is the site of a 350m year old Caldera; it includes the much beloved Cathedral National Park; to the North the Snobs Creek Hatchery; to the South iconic Lake Mountain. However, the tourist potential of the RSF is being trashed by saturation logging (see Figure 2, RFPG 2019) and swarms of log trucks threaten the lives of tourists. Protections written into the Code are ignored and breach reports in relation to such protections white-washed.
   2. Protect nature. The RFPG is committed to protecting the values of the RSF. This includes carefully reviewing the periodic draft revisions of the TRP and urging VicForests to remain within the spirit and letter of the Code. However, VicForests has in recent times made two changes to its procedures which make this kind of community input more difficult: first, by delaying the release of coupe schedules so that timber harvesting exclusion zones are put in place at the time the schedule is released community members are unable to inspect the high priority coupes before they are logged; and second by removing the net harvest area from the TRP.
5. The Environment Department has rich expertise in the assessment of ecosystems and biodiversity. The recently released Bushfire Emergency: Biodiversity Response and Recovery report provides a detailed account of the different elements of biodiversity and how they have been impacted by the 2019-20 fires. However, there has been no such assessment of the short, medium and long term impacts at local, meso and macro scales in relation to logging. This is despite the findings of the VAGO reports of 2013 and 2018.
   1. The IUCN has declared the mountain ash ecosystems of the Central Highlands to be ‘endangered’. In fact, the alpine ash forests have also been highly impacted by bushfires and are also likely to justify listing as ‘endangered’ under the Flora and Fauna Guarantee Act.
   2. We urge your auditors to explore why these two precious ecosystems are not being protected under the F&FGA. 

The submission refers to a range of RFPG submissions and research reports over the last two years by way of evidence in support of these propositions. 

These include: 

1. RFPG’s current submission to VicForests regarding the current draft revision of the TRP (9 Sept 2020), 
2. RFPG’s submission to the Parliamentary Inquiry into Ecosystem Decline in Victoria (7 July 2020),
3. RFPG Research Paper: ‘Fire and logging as a biodiversity threat with serious and potentially irreversible ecological consequences for the Rubicon State Forest’ (Nick Legge, 8 Aug 2019), 
4. RFPG Research Paper: ‘Skewed age class distribution as a biodiversity threat and breach of precautionary principle: Rubicon State Forest as a case study’ (Nick Legge, 30 June 2019), 
5. ​Submission by Rubicon Forest Protection Group to the Independent Review of Timber Harvesting Regulation (7 Oct 2018), 
6. RFPG research video: ‘100 years of logging in the Rubicon State Forest’ (Nick Legge, October 2018), 
7. RFPG submission to Third Five Year Review of the Regional Forest Agreements (29 Jan 2018) plus the associated submission (25 Jan 2018), Ann Jelinek .

A-G's Report (13 Oct 2021): 
Protecting Victoria’s biodiversity