Royston Report & the Code of Forest Practice

Logging of the Royston Region commenced in mid January 2006 and continues at the date of this report.

This document reports on investigations into the logging of a (“ the Royston Region ”) in respect of its compliance with the Code of Forest Practices for Timber Production (Revision No. 2) November 1996 (“ the Code ”).

1. Government and DSE (the land stewards)

Some of the issues in the Royston Region in relation to the Code are applicable to the role of the government and the Department of Sustainability and Environment.

Paragraph 2.1 of the Code is headed “Regional Forest Planning” and provides:

Given the environmental values of the Royston Region and considering where logging has been undertaken:

· the region must not have been adequately surveyed;

· there must not have been adequate environmental impact assessment; and

· aerial surveying must have been non-existent or must have been insufficient.

Significant areas of rain forest, Leadbeater's Possum zone 1A habitat and pre-1900 Ash trees were predominant in the Royston Region and logging of an area with such traits would not have been in compliance with the Code.

Paragraph 2.1 of the Code goes on to provide that plans for each Forest Management Area must:

The logging of the Royston Region has seen:

· logging coupes between two alpine plateaus cleared;

· fragmentation of the connection between a conservation reserve and National Park; and

· three interconnected rain forests fragmented by logging and roading for the purpose of logging.

This does not “maintain environmental values”, nor does it “achieve ecologically sustainable management” and so its fails to comply with the Code.

Paragraph 2.1 of the Code also provides that plans for each Forest Management Area must:

Non-governmental environment organisations, including local volunteer groups comprised of experts in the applicable sciences and practices, have reported and documented the extensive time, money and resources they have spent on identifying significant regional environmental values in the area. It has been demonstrated that the Victorian state government has failed take into account submissions by these groups on numerous occasions. These groups have often been met with a generic response refusing to take their recommendations into account.

Shortly after commencement of the logging of the Royston Region, the government was met with a high level of public dissent. Submissions by concerned citizens and various local, regional and State groups were provided to the government outlining some of the ways in which the logging of the Royston Region breached the Code. Shortly after that, many of the breaches of the Code identified in the submissions were corrected by the government, including the aggregated coupe being reduced from approximately 101 hectares to 44 hectares. However, the government has denied attribution of any of the corrections to the public’s submissions.

The logging of the Royston Region has failed to comply with the Code in that it has failed to include “public participation” in the development process of the plans for the Forest Management Area relevant to the Royston Region. Additionally public participation has not provided a basis for “monitoring and reviewing management performance”.

The Forest Management Area applicable to the Royston Region is the Central Forest Management Area. Appendix R of the Central Forest Management Plan provides that it is a special water supply catchment area for the upper Goulburn. Accordingly, 20 metre buffers apply, that is, 20 metres on each side of streams must not be logged.

Investigations revealed:

· soil in the river at the rain forest / river road crossing, as depicted in Image 1 below; and

· Nothofagus was removed for roading, as depicted in Image 2 , below.

Accordingly, the Forest Management Plan relevant to the Royston Region was not complied with and, consequently, neither was the Code

2. Vic Forests (the resource managers)

Some of the issues in the Royston Region in relation to the Code are applicable to the role of Vicforests. Vicforests is a state body, recently created, to assume the role of obsolete logging licence holders.

Paragraph 2.2.3 is headed “tree species and seed source for regeneration” and provides that:

The forest coupe plan relevant to the Royston Region does not indicate the proposed source of seed for the regeneration.

Paragraph 2.3.7 is headed “protection of rain forest”. It provides that:

Mr Ian Miles, Director Parks and Forest Stewardship, Department of Sustainability and Environment, communicated personally with the author of this report that the rain forest buffer is currently under review and the buffer will be increased from 60 to 80-100metres.

The Central Forest Management Plan discusses priority 1, 2, 3, and 4 areas, however it is not obvious how these areas are defined. The code on the other hand does define the different rain forests and management plans for them.

Paragraph 2.3.7 goes on to provide that:

Given the stated intention to increase buffers for better protection and those currently prescribed by the Code, it is difficult to conclude that the Central Forest Management Plan provides “detailed strategies” to override the minimum buffers stated in the code for rain forest protection.

However, the coup boundary has been marked by Vicforests approximately 40 metres from a significant rain forest, which has been circled in red in image 9 below.

The significance of this rain forest has been proved through an independent study by Andrew Piccone undertaken by Practical Ecology In August 2005 called “Assessment of Two Rain forest sites within the Royston River Catchment, Central Forest Management Area” commissioned by The Central Highlands Alliance. This report states that:

The Code indicates that such rain forests must be protected by buffers of 60 metres or 40 metres with 40 metres modified harvesting.

This is therefore a breach of the code in relation to rain forest protection.

Paragraph 2.3.7 goes on to provide that:

The coupe was marked by Vic Forests and was clearly in the middle of a rain forest as depicted in image 3 below.

The report by Andrew Piccone undertaken by Practical Ecology In August 2005 was submitted to government in August 2005 Although the government fails to give credit to this report, the rain forest was then removed from the intended logging area in the Royston Region. However, the road accessing the coupe adjoins this rain forest area indicated by a red circle in image 4 below.

Additionally, the road passes through the top of one of the rain forests as depicted in image 5 below.

The report by Practical Ecology referred to above states:

The road also passes through a proposed Zone1A Leadbeater's Possum habitat reserve, as depicted in image 6 below.

The actual road does not follow the exact marking on the forest coupe plan, which is highlighted below by the red box in image 7 below. It appears that the road should have avoided the proposed zone 1a Leadbeater's Possum habitat reserve and proximity to the rain forest.

Paragraph 2.3.7 of the Code goes on to provide that:

Investigations reveal that a road has been marked and is being cleared between the Iron Pipe coupes that is not on the current coupe plan as indicated in the image 8 below. This road cuts through significant habitat area, divides rain forest and crosses a river.

Evidence of the clearing of the road is depicted in image 9  below.

Image 9

Another area of significant Leadbeater's Possum habitat and pre-1900 ash were included inside the coupe boundary by Vicforests. The circled coupe boundary tag is shown in image 10 below.

After submission of the Royston Report the coupe boundary was relocated to exclude these trees from the harvesting area, however one of the trees is still on the boundary of the coupe and the area being on the top side of the coupe is highly susceptible to regeneration burns and their escape. None of these changes to the coupe boundary were formally notified to environmental groups that identified the issues. This demonstrates a failure by the government to adequately engage in the public consultation process and to review its management performance.

The logging practices outlined above reveal the logging of the Royston Region fails to comply with the rain forest provisions of the Code.

Paragraph 2.3.8 of the Code is headed “protection of landscape values” and provides that:

The Code then provides the following pictorial:

The following artist's impression shows what the visual impact from Lake Mountain is likely to look like upon completion of the logging of the Royston Region. It resembles the image in the above pictorial in the Code that represents what is “to be avoided”.

Accordingly, the logging of the Royston Region fails to take into account landscape values as required under the Code and so breaches paragraph 2.3.8 of the Code.

The following map shows the proximity of the logging of the Royston Region from the Panorama Lookout at Lake Mountain. The green lines indicate the filed of view.

3. Harvesting Contractor (The logger)

Some of the issues in the Royston Region in relation to the Code are applicable to the role of contractors, retained by Vicforests to undertake the logging.

As previously identified the access road to the coup does not follow the access road drawn on the coupe plan. This may be a breach of the code by the logging contractor.

The campsite may be outside of the coup boundary, as depicted by an orange circle in image 11 below. The two red circles in image 11  indicate two blue tapes in line of sight. The blue tapes represent the coupe boundary and appear to have been tied on vegetation that has been pushed over since the coupe harvesting began on the left of the orange circle. Vegetation carrying blue tape is not supposed to be logged or impacted by logging.

Paragraph 2.3.11 of the Code is headed “fuel dumps and machinery servicing” and provides that:

Image 12 below depicts that oil drums are being inappropriately stored.

Images 13 and 14 below depict oil drums leaking into the vegetation and spilling onto the ground.

These dealings with oil drums show that the “storage, use and disposal of petroleum products is polluting the environment and is resulting in littering. Accordingly, logging of the Royston Region fails to comply with paragraph 2.3.11 of the Code.

Paragraph 3.2.9 of the Code is headed “log landings and dumps” and provides that:

Image 15 below depicts that not enough top soil has been retained for log landing rehabilitation.

Accordingly, logging of the Royston Region has failed to comply with paragraph 3.2.9 of the Code.

Images 16  and 17  below reveals that three habitat trees have not been marked with red tape as required by the coupe plan.

The three stags in image 18  below are located in the red circle in image 19  below, with no red tapes as required under the coupe plan.

This breaches the code in relation to the logger not following the instructions on the coupe plan and therefore increasing the risk of these habitat trees being removed.

The Government was notified about significant environmental and tourist values that would be compromised if logging were to occur in this area. It was highlighted that adequate surveys had not taken place but the government chose not to act.

The Government was notified that the marking of the coupe by Vicforests had breached a number of aspects of the code and that it was highly likely that if the logging were to go ahead that breaches of the code would be likely. A response from government denying this was received.

Since logging has commenced investigations have clearly conveyed that the logging of the Royston Region fails to comply with the Code in numerous ways. This has caused significant damage to the environmental values of the area including the endangered Leadbeater's possum and rain forest values.

Appendix 1 – Overall coupe plan and key for reference to other excerpts that have been taken from this plan for use throughout this document.