Proposed TRP Amendments - Victorian Rainforest Network

Dear VicForests

I write on behalf of the Victoria Rainforest Network(VRN) opposing logging in the Upper Acheron (southern end) as indicated on the Draft Marysville Timber Release Plan.

Specific coupes that should not proceed include:

309-512-0001

309-512-0002

309-511-0005

and road line 309-512-0003.

Logging of these coupes would breach the Flora and Fauna Guarantee Act (Action Statement 238) and is hence in breach of the Code of Forest Practices for Timber Production 2007.

Specifically:

1. These entire coupes are within the Acheron Rainforest Site of National Significance.
2. According to Action Statement 238 (page 13) it states “all sites of national significance for rainforests in Victoria will be protected within the comprehensive, adequate and representative reserve system.”
3. Appendix 1 of Action Statement 238 under the heading “Site of significance for rainforest ” it states:
   ”Sub-catchment protection of rainforests stands must be provided in core areas of Nationals Sites of Significance for rainforest with buffers to the nearest watershed.”

1. Hence all core rainforests in the Acheron rainforest Site of National significance, regardless of their priority rating as stated in the Central Highlands Forest Management Plan (See Appendix F), must be granted sub-catchment protection. This rules out logging any of the above coupes as Action Statement 238 (2009) takes precedent over the Forest Management Plan (1995).

Other key issues:

1. Logging these coupes would pre-empt Research Actions 13, 14, 22 and 23 (page 17) of Action Statement 238, and would be a serious breach of the intent of the Rainforest Action Statement. Ignoring relevant research priorities which will determine if logging in such sensitive high conservation areas is appropriate would be a very serious breach in public faith in the Victorian State Government and VicForest.

2. Fire associated with Black Saturday has moderately burnt the forests and some of the rainforests is these coupes. Much of the rainforest survived and is still recovering from these fires. Evidence on pin hole borer beetles associated with myrtle wilt is evident in every burnt tree however this may not mean the presence of myrtle wilt. . Additionally the fires have cause significant wounding to many beech trees. The extent myrtle wilt may be elevated is not known. Similarly it is not known how many damaged rainforest trees will ultimately survive the 2009 fires. Completion of Research Action 23 of Action statement 238 would resolve these issues.

3. Given the rainforest canopy has been burnt and some trees have fallen down but not died, it may be difficult to determine the true extent of the rainforest canopy. Logging these coupes will be perceived as a cynical attempt to take advantage of the effect of the Black Saturday fires. These coups should not be logged so soon after a fire, while full canopy recovery is still occurring.

4. There is clear evidence that the regeneration fires in nearby coupes from 2007-2008 got out of control and totally destroyed ash trees and the understorey that was to be retained (area was burnt again in 2009 wildfires). Such management clearly indicates that VicForests cannot guarantee regeneration fires will stay out of rainforest stands, generally and in the above coupes.

5. As has already been raised at the Bushfires Royal Commission by Scientists, and by myself in the media, logging practices elevate wildfire risk across the forested landscape of the Central Highlands. VRN maintains that rainforests help stop wildfires. Logging practices reduce the ability of rainforest to stop wildfires. The Bushfire Royal Commission recommendations need to be considered before making any decision to log these areas.

6. The Public Land Safety Zone legislation cannot be relied upon to stop protests and public condemnation. VRN fully understands that the only purpose of the Safety Zone legislation is to stop protestors challenging the legality of logging under the above laws, prescriptions and codes. The Safety Zone legislation serves no other purpose.

In summary logging these coups is totally irresponsible. To persist with logging these coupes will be a breach of the law and of the public’s faith in due process.

Please provide feedback on all the issues I have raised in this submission.

I act in good faith in providing this advice.

Simon Birrell

Victorian Rainforest Network