LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 2

Terms of Reference Addressed

This submission deals variously with all six of the terms of reference. The submission focuses on the interrelationships between forest ecosystem management and the three pillars of ecologically sustainable development - environmental, social and economic impacts. Comment is made on effectiveness of past and current land and vegetation management, basis for relevant management activities and the environmental, social and economic impact on urban, rural and remote communities over the last few decades. Disclaimer

John Cameron issues this submission to the Parliament of Victoria for their own use. No responsibility is accepted for any other use. The submission may be published on the Parliament’s website but should not be reproduced or transmitted in any other form or by any other means without the author’s permission. Nothing in this submission is, or should be relied upon as, a promise by John Cameron as to any outcome. Actual results may be different, anticipated events may not occur as expected resulting in variations. John Cameron has no responsibility to update this submission. Acknowledgements

Aspects of this report has been prepared with the assistance of Frank Batini of The Bushfire Front Inc.2 Neil Burrows, David Packham and various other foresters, who suggested papers and reports on forestry, ecology, fire behaviour, weather, climate, forest regulation and forest land-use that may be relevant. Independence

This report has been prepared entirely at my own cost without any financial assistance from any organisation, association, company, entity or individual. Generally the findings and conclusions are my own apart from where work by others is cited. Tribute

This report is dedicated to those people who continue to tirelessly advocate for responsible multiple use forest management based on a holistic appraisal of the wide range of imperatives that should be considered in ecologically sustainable forest land-use and forest management decisions. This report is also dedicated to those who advocate for improved bushfire mitigation. The report is also dedicated to many pioneering forest scientists and managers who were responsible for the original conservation and prescriptions for our forests and finally to those talented people in DELWP who could make an even greater contribution if released from the shackles of an unfocused mega Department.

2 The Bushfire Front Inc. is an organisation of fire behaviour and bush fire experts that advocates better management of fire in WA, especially on forested lands, to reduce the impact and severity of bushfire damage. They are practical bushfire specialists, with hundreds of years’ accumulated experience in preventing bushfire damage to people, property and forests. Each of them has worked in bushfire prevention, bushfire science, fire control planning, administration or operations. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 3

Contents 1. SUMMARY ...... 7 2. INTRODUCTION ...... 9 2.1 INTRODUCTION TO TYPES OF FIRE ...... 9 2.2 INTRODUCTION TO FACTORS DRIVING FIRE INTENSITY AND THUS DAMAGE ...... 10 2.3 HIGH FIRE INTENSITIES ARE VERY DAMAGING AND SHOULD BE MINIMISED ...... 11 2.4 DISASTEROUS IMPACT OF VICTORIAN MEGA WILDFIRES ...... 11 2.5 TRADE-OFF BETWEEN HIGH INTENSITY WILDFIRE & LOW INTENSITY PRESCRIBED FIRE ...... 12 2.5 VICTORIA’S FAILED FIRE RISK REDUCTION TARGET ...... 13 2.6 VICTORIA HAS USED PRESCRIBED BURNING EFFECTIVELY BUT NEEDS MORE ...... 13 2.7 RATIONAL FOR LOW INTENSITY PRESCRIBED FIRE TO MITIGATE WILDFIRE ...... 14 2.8 RATIONAL FOR FIRESTICK ECOLOGY ...... 15 3. EXTENT OF THE DECLINE IN FOREST ECOSYSTEMS ...... 15 3.2 VICFORESTS MANAGEMENT OF HIGH CONSERVATION VALUES ...... 16 3.2.1 HCV 1 Species diversity - rare, threatened or endangered species ...... 18 3.2.2 HCV 2 Landscape-level ecosystems and mosaics - significant global, regional or national .... 19 3.2.3 HCV 3 Ecosystems and habitats - rare, threatened, or endangered, including refugia...... 20 3.2.4 HCV 4 Critical ecosystem services – protection of water catchments and control of erosion 20 3.2.5 HCV 5 Community needs - for livelihoods, health, nutrition, water ...... 21 3.2.6 HCV 6 Cultural values - sites, resources, habitats and landscapes culturally significant ...... 22 3.3 IMPACT OF WOOD PRODUCTION ON VICTORIAN NATIVE FORESTS FLORA & FAUNA ...... 23 3.4 IMPACT OF PEST WEEDS AND ANIMALS ON VICTORIAN NATIVE FOREST ECOSYSTEMS ...... 24 3.5 IMPACT OF CLIMATE CHANGE ON VICTORIAN FOREST ECOSYSTEMS ...... 25 3.6 IMPACT OF CLIMATE CHANGE ON NATIVE FOREST CARBON STOCKS ...... 26 3.7 IMPACT OF BUSHFIRES OR WILDFIRE ON VICTORIAN NATIVE FORESTS ...... 26 3.8 IMPACT OF HARVESTING ON FLAMMABILITY OF VICTORIAN NATIVE FORESTS ...... 27 3.9 HARVEST REGENERATION CAN HELP AVOID ECOSYSTEM DECLINE FROM WILDFIRE ...... 29 3.10 IMPACT OF PRESCRIBED BURNING ON FOREST ECOSYSTEMS ...... 30 3.11 IMPACT OF PRESCRIBED BURNING IN A WATER CATCHMENT – CASE STUDY ...... 31 3.12 IMPACT OF PRESCRIBED BURNING VERSUS WILDFIRE ON CO2 RELEASED ...... 31 4. RELEVANCE OF LEGISLATIVE FRAMEWORK ON FOREST MANAGEMENT ...... 31 4.1 LEGISLATION OF MANAGEMENT AND HARVESTING OF VICTORIAN NATIVE FORESTS ...... 32 4.2 VICTORIA’S COMPREHENSIVE, ADEQUATE AND REPRESENTATIVE RESERVES ...... 33 5. EFFICIENCY & EFFECTIVENESS OF NATIVE FOREST PROGRAMS ...... 34 5.1 STATE OF THE FOREST REPORT 2018 ...... 34 5.2 POLICY SHIFT FROM PRESCRIBED BURNING TARGET TO THE RISK REDUCTION TARGET ...... 35 5.3 VICTORIA’S POOR RECORD AT MITIGATING WILDFIRE BUSHFIRES...... 36

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 4

5.4 DELWP’S UNFAVOURABLE PERFORMANCE AGAINST OPERATING TARGETS ...... 37 5.5 FAVOURABLE OPERATING STRUCTURE AND PERFORMANCE OF VICFORESTS ...... 38 6 IMPROVING MANAGEMENT OF NATIVE FOREST ECOSYSTEMS...... 38 6.1 DELIVERING IMPROVED MANAGEMENT OF FORESTS & MITIGATING DAMAGE ...... 38 6.2 ISSUES WITH THE ORGANISATION OF FOREST/ECOSYSTEM MANAGEMENT ...... 39 6.2 RESTRUCTURE TO DELIVER BETTER FOCUS ON FOREST & ECOSYSTEM OUTCOMES ...... 40 7 OPPORTUNITIES TO INCREASE NATIVE FOREST ESD OUTCOMES ...... 41 7.1 VICTORIAN ‘FORESTRY PLAN’ ...... 41 7.2 PAST REDUCTIONS IN VICTORIAN NATIVE FOREST TIMBER ...... 43 7.3 SOCIOECONOMIC IMPACT OF PAST REDUCTIONS IN NATIVE FOREST LOG SUPPLY ...... 43 7.4 PROJECTED DECLINE IN NATIVE HARDWOOD SUPLY – VICTORIAN ‘FOREST PLAN’ ...... 45 7.5 SOCIOECONOMIC IMPACT OF VICTORIAN ‘FOREST PLAN’ ...... 45 8 PLANTATIONS ARE NO SUBSTITUTE FOR NATIVE FOREST SUPPLY ...... 46 8.1 DECLINING GIPPSLAND PLANTATION ESTATE ...... 46 8.2 VICTORIAN PLANTATION HARDWOOD LOG SUPPLY HAS PEAKED AND WILL DECLINE ...... 46 8.3 VICTORIAN SOFTWOOD SUPPLY HAS PLATEAUED AND MAY DECLINE ...... 47 8.4 PLANTATION PULPLOGS ARE NOT A PERFECT SUBSTITUTE FOR NATIVE PULPLOGS ...... 48 8.5 PLANTATION SAWLOGS ARE NOT SUBSTITUTABLE FOR NATIVE FOREST SAWLOGS ...... 48 8.6 SPECIAL LONG-ROTATION PLANTATIONS ARE REQUIRED TO PRODUCE SAWLOGS ...... 49 8.7 FINDING HIGH QUALITY LAND FOR NEW PLANTATIONS IS PROBLEMATIC ...... 49 8.8 FARMLAND FOR PLANTATIONS IN VICTORIA PARTICULARLY NEAR MILLS IS EXPENSIVE ...... 50 9. ADVERSE IMPACT OF USING OTHER BUILDING MATERIALS ...... 51 9.2 ECOLOGICAL SUSTAINABILITY OF SAWNTIMBER ...... 51 9.3 GREENHOUSE FRIENDLY ATTRIBUTES OF SAWNTIMBER AS A BUILDING MATERIAL ...... 51 9.4 TIMBER HOUSE WALLS HAVE LOWER EMBODIED ENERGY THAN ALTERNATIVES ...... 51 9.5 TIMBER HAS MUCH LOWER POLLUTION IMPACTS THAN OTHER BUILDING MATERIALS ...... 52

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 5

Tables

Table 1: Listed key threatening processes affecting forest-dwelling threatened species ...... 24 Table 2: Comparative impact of prescribed burning on fires in the Mundaring catchment WA ...... 31 Table 3: Key Victorian legislation applicable to public land management ...... 32 Table 4: Prescribed burning, wildfire and deaths in Victoria compared to South West WA ...... 36 Table 5: Some Victorian Megafires and Campaign Bushfires over the last 20 years ...... 36 Table 6: Increasing wildfire area coincides with move to mega government departments ...... 37 Table 7: Initial manufacturing, further manufacturing and end-products from native forest logs ...... 41 Table 8: Victoria’s native forest log supply and Gross Regional Product and Jobs in 2016-17 ...... 43 Table 9: Plantation area burnt in the 2019‒20 bushfires ...... 48 Table 10: Ecological sustainability of building materials (energy & emissions are in manufacture) ...... 51 Table 11: Greenhouse friendly attributes of Sawntimber as a building materials ...... 51 Table 12: Timber house walls have lower embodied energy than alternatives...... 51

Figures

Figure 1: Relative impacts of a prescribed burn (left) and a wild uncontrolled bushfire (right) ...... 9 Figure 2: Fuel reduction (top left), back-burn (top right) and bushfire (bottom left & right)...... 10 Figure 3: Impact of fuel load and Forest Fire Danger Index on fire intensity ...... 10 Figure 4: Indicative relationship between deaths & fire intensity or forest fire danger index ...... 11 Figure 5: Great Divide 2003 Bushfire in East Gippsland ...... 11 Figure 6: Victorian losses per annum for 101 years to 1999 and for 21 year to 2020 ...... 12 Figure 7: Victorian mega fires could have been predicted from the “Sneeuwjagt curve” ...... 12 Figure 8: Victoria's wildfire area and bushfire risk profile, 1980–2021 (last 3 yr predicted %) ...... 13 Figure 9: DELWP Fire Management Zones in Eastern Victoria (Easton FMU) ...... 21 Figure 10: Threat rating and threat categories for forest-dwelling threatened species ...... 23 Figure 11: Number of Victorian native forest vascular fauna and vertebrate fauna species ...... 24 Figure 12: Melbourne’s days of extreme temperature and rainfall over the last 150 years ...... 26 Figure 13: Location of very large bushfires in 2003, 2006, 2007, 2009, 2013, 2014 and 2019-20...... 27 Figure 14: Unburnt 10 y E. diversicolor (A) and burnt mature E. Diversicolor (B) & E. marginate (C) ...... 28 Figure 15: Young unburnt regeneration (fore-/mid-ground) & burnt 70 year forest (background) ...... 29 Figure 16: Unburnt young regrowth (foreground) & killed mature forest (background) ...... 29 Figure 17: Young unburnt 5 year old regeneration near Marysville following 2009 wildfire ...... 30 Figure 18: Vicforests Normalised Profit before tax and Cashflow Return on Equity ...... 38 Figure 19: Location of 96,000 ha of Immediate Protection Areas (IPAs) under ‘Forestry Plan’ ...... 42 Figure 20: Decline in Victorian native forest log supply over the last 24 years ...... 43 Figure 21: Impact of reduced native forest log supply on Gross Regional Product & Employment ...... 44 Figure 22: Ash sawmill at Heyfield and Opal (Australian Paper) pulp and paper mill at Maryvale ...... 44 Figure 23: Projected decline in Victorian native forest log supply over the next decade ...... 45 Figure 24: Projected ‘Forest Plan’ native forest log supply, Gross Regional Product & Jobs ...... 45 Figure 25: Decline in the plantation estate in Central Gippsland NPI Region ...... 46 Figure 26: Victorian plantation hardwood log supply has peaked and will decline ...... 47 Figure 27: Victorian plantation softwood log supply has peaked and will decline ...... 47 Figure 28: Increase in transacted prices of Victorian farmland over 2001 to 2017 ...... 50

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 6

Glossary

ABARES Australian Bureau of Agricultural and Resource Economics and Sciences AFAC Australian Fire and Emergency Services Authority Council Inc. BNH Bushfire and Natural Hazards (a CRC) ca. circa or approximately CALM Conservation and Land Management WA (predecessor of DBCA) CFA Country Fire Authority Code Victoria’s Code of Practice for Timber Production (2014) CRC Co-operative Research Centre DBCA Department of Biodiversity, Conservation and Attractions WA DELWP Department of Environment, Land, Water and Planning DEPI Department of Environment and Primary Industries (predecessor of DELWP) DHHS Department of Health and Human Services DNRE Department of Natural Resources and Environment (predecessor of DELWP) DPW Department of Parks and Wildlife WA (predecessor of DBCA) DSE Department of Sustainability and Environment (predecessor of DELWP) ECV Ecological vegetation communities FFDI Forest Fire Danger Index FFMV Forest and Fire Management Victoria (potential name for new agency) FFMG Forest Fire Management Group FTE Full Time Equivalent with respect to employment FSC Forest Stewardship Council (of Australia) GRWE Gross Round Wood Equivalent (a measure of log volume) ha hectare HCV High Conservation Value h or hr hour HVP Hancock Victorian Plantations IUCN International Union for Conservation of Nature IGEM Inspector General Emergency Management kW kilo Watt M million MW Mega Watt = 1000 kW m metre mill million mm millimetre NPI (Region) National Plantation Inventory (Region used by ABARES for reporting forest data) OFOF Our Forest Our Future, Estimates of sawlog resource DNRE 2002 pa per annum PEFC Program for the Endorsement of Forest Certification (Global authority) South West WA South West WA - Swan, South West and Wallan forest regions (2.5 million ha) South West region South West Forest region of South West WA (0.9 mill ha excl. Swam and Wallan) t tonne VicForests Victorian government body responsible for timber supply from state forests VBRC Victorian Bushfire Royal Commission WA Western Australia WAFD Western Australian Forests Department WILDFIRE Unplanned bushfire usually of sufficient intensity to cause significant damage yr year $M Million dollars Wildfire Bushfires that are generally, not prescribed, intense and difficult to supress

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 7

1. SUMMARY This submission examines the state of ecosystems in Victorian native forests and takes a holistic approach to analysis of the impacts of various agents and potential future management options, against the three pillars of ecological sustainable development – environment, social and economic impacts.

The most serious factors contributing to decline of Victorian native forest ecosystems are high intensity wildfire, grazing from introduced and native fauna, invasive species, competition from introduced plants, clearing for farming and mining, illegal collection, competition from introduce animals, predation by introduced animals and illegal hunting. Timber production in native forest pose a low threat to High Conservation Values (HCVs) and can enhance HCVs, flora and fauna and genetic adaptation to impacts.

Timber production can ensure different forest ecosystem or seral ‘stages’ necessary in ecology, because landscape diversity and associated biological diversity is necessary for the viability of plant and animal populations and delivering a range of required habitat needs. Well planned harvest regeneration and prescribed fire can help deliver the Landscape-level ecosystems and mosaics required under High Conservation Value 2 (HCV 2) - Landscape-level ecosystems and mosaics. Harvesting and regeneration from seed enhances adaption to climate change by ensuring genetic recombination, desirable for the sustainable perpetuation of forest ecosystems and the enhancement of their ability to adapt to change.

Impact of climatic change on plants is partly accommodated by adaptions in plant structure and function. The major impact of climate change is likely to be through the impact of drought and days of extreme weather on the intensity, extent and frequency of wildfires. However, this impact of climate change on wildfire can be moderated substantially through prudent fuel reduction in our forests and by other fire mitigation actions, particularly early detection (before dawn after lightning) and much more rapid and effective initial attack.

Large high intensity wildfire is the most significant threat to Victorian forest ecosystems. Intense wildfires over the last 20 years have inflicted damage on forest ecosystems that will take a very long time to restore. These fires have adversely impacted all High Conservation Values (HCVs) - species diversity (HCV 1), ecosystems and mosaics (HCV 2), ecosystems and habitats (HCV 3), critical ecosystems and services including clean water (HCV 4), community needs including livelihoods (HCV 5), and cultural values including archaeological or historical significance (HCV 6).

Low intensity prescribed burning is akin to the firestick strategy employed by our first people for thousands of years, to reduce wildfire risk, maintain fire dependant ecosystems, deliver a mosaic of habitats, ensure a range of seral stages and enhance biodiversity.

Forest policy and high intensity wildfires have constrained ecologically sustainable development, due to their contribution to a decline in sustainable supply of native forest timber and resultant loss of economic output and jobs in regional Victoria. Native forest timber is our most ecologically sustainable building material.

Decline in native timber supply by policy or wildfire over the last 20 years has resulted in economic loss of $6.6 billion and 5,500 jobs, most in regional Victoria. Rural communities have lost assets, livelihoods, and lives, because wildfires escaped public land and destroyed private property. DELWP has used private property as ‘neighbour firebreaks’, rather than better fire mitigation in public forests. This is inequitable and probably actionable under Worksafe or Common law. Fire escaping from public forest are attributed to poor fuel reduction, firebreaks and fire access; and tardy detection, initial attack and suppression.

Victoria continues to underutilise low intensity prescribed burning, successfully employed in Western Australia for 60 years, resulting in 312 lives lost in Victoria versus 2 lives in South West WA with ‘best practise’ over the last 60 years. The Victorian ‘Risk Reduction Target’ introduced in 2015 has failed. The target of 70% residual risk was far too high and has only been achieved through substantial high intensity wildfires, or ‘killing’ fires that it was supposed to avoid.

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 8

The publically available ‘Forestry Plan’ is essentially a ‘media release’ on compensation for closing the native forest timber industry in 2030 and a ‘token’ establishment of 500 ha of plantation on marginal sites. The ‘Forestry Plan’ does not comply with an ‘equitable’ definition of ‘High Conservation Value 5’. Loss of access to the native forest for timber production will decrease local community wellbeing, economic output and jobs.

The ‘Forestry Plan’ lacks rigorous strategic analysis of adverse socioeconomic impacts on rural communities caused by exiting native forest supply. It fails to acknowledge the current decline in plantation supply and the considerable and possibly insurmountable challenges to establishing new plantations. The challenges include very limited availability of suitable land, high land cost, poor plantation log quality, unsuitability of plantation sawlogs for existing mills and large scale required for returns on investment in new mill technology. Replacing native forest timber with new plantations on agricultural land threatens to push up farmland prices, crowd out farmers and lead to diminishing scale economies in agricultural production and food processing.

A major issue is that we do not have a market system with price signals for the efficient allocation of conservation like wood (auctioned) from our public native forests. Allocation has essentially been undertaken by non-market forces, or politically, in a manner consistent with allocation of goods and services in overseas ‘command economies’. Where bipartisan support is absent, political influence by minor parties, supported by activists, has held sway over the majority and particularly disenfranchised rural communities.

The area of public forest available for timber production has declined from ca. 10% in 2000 to 6% in 2020. This misallocation of a multiple use resource is contributing to ‘socioeconomic underdevelopment’ of regional communities for so called ecological benefits that are contested by experts. The misallocation by policy and exacerbated by wildfire loss has resulted in the loss of $6.6 billion Gross Regional Product and 5,560 jobs over the last 20 years. The Victorian ‘Forestry Plan’ is likely to contribute to a further loss $5.6 billion in Gross Regional Product and the loss of another 3,660 jobs over the next twenty years.

The ‘Forest Plan’ will lead to an exacerbation of the ‘economics of underdevelopment’ for disenfranchised rural communities and timber towns, already severely impacted by years of reducing native log supply and is poorly timed coinciding with the recent impact of Covid-19 on regional economies.

We are witnessing a classic example of the ‘economics of underdevelopment’ being played out, albeit in this case at the direct hand of government, rather than the invisible hand of market forces. Rural communities and timber towns are being stripped of economic output and employment opportunities. This is causing adverse impacts on community services. This adverse impact is a result of the abandonment of the application of ‘multiple use’ to the remaining 6% of forest currently available for timber production. This 6% equates to only 0.004% or 3,000 ha of the forest logged each year across spatially dispersed small coupes.

The ‘Forestry Plan’ ignores the poor substitutability of plantation timber, diminishing plantation log supply, and poorer (rather than better) ecologically sustainable outcomes from increased mining required to support the use of less sustainable building materials such as concreate, brick, steel and aluminium to replace sawntimber. Sawntimber is renewable, recyclable and biodegradable; has low energy use and air emissions in manufacture; and good carbon sequestration. Native forest log production uses substantially lower inputs in production than alternative plantation log production and also is more employment intensive than plantation timber production - generates more jobs per cubic metre.

The population of timber towns such as Orbost and Cann River declined following the decline in native forest log supply and the ‘Forestry Plan’ will add towns such as Morwell, Heyfield, Bairnsdale etc. to the list of rural communities disenfranchised by the political power of metropolitan Melbourne and activist groups in pursuit of well-intentioned but misguided aspirations.

Management of Victoria’s public forests could be substantially improved with a demerger of DELWP, reallocation of resources, fewer HO and more field staff, improved structure and systems to unleash DELWPs human talent and deliver greater focus on real outcomes in the forest.

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 11

2.3 HIGH FIRE INTENSITIES ARE VERY DAMAGING AND SHOULD BE MINIMISED Ease of suppression, area burnt, damage done to ecosystems, flora and fauna and lives lost from wildfire are related to fire intensity. Analysis of the separate fires from the 2009 tragic Victorian bushfires and the 2005 Pickering Brook wildfire in WA, indicate that the number of lives lost is more strongly related to fire intensity, than the Forest Fire Danger Index, as indicated by the good correlation (R2) for fire intensity and weak correlation for Forest Fire Danger Index - FFDI (Figure 4). Protection of forest ecosystems and people requires well planned, resourced and managed fuel reduction to reduce the intensity of wildfires. Figure 4: Indicative relationship between deaths & fire intensity or forest fire danger index5

2.4 DISASTEROUS IMPACT OF VICTORIAN MEGA WILDFIRES It is paramount to minimise large-scale and high intensity wildfires across the landscape, as survival of diverse age structures, species mixes and habitat values decreases with wildfire intensity. High intensity fire can severely burn the entire landscape including riparian strips and carbon in the soil (Figure 5), whereas prescribed burns target burning only 70% to 90% of the area within the planned coupe and avoid burning riparian strips. Figure 5: Great Divide 2003 Bushfire in East Gippsland6

5 L. McCaw et al (2009). Victorian Bushfire Research Response, Final Report Oct 2009. And J. J. Hollis et al (2011). The effect of fireline intensity on woody fuel consumption in Southern Australian Eucalypt fires. Aust. Forestry V74, No 2. 6 From Wikipedia. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 12

The impact of wildfire on forest ecosystems can be viewed through the impact on area, property and human life. Wildfire has burnt about 5 million hectares (average of 260,000 ha pa) over the last two decades and resulted in unacceptable loss of houses (average 129 houses pa) and lives (average 9 people pa) (Figure 6). The increased loss is despite substantial improvements in firefighting resources including a ca. 3.5 fold increase in DELWP expenditure on fire management over the last 20 years. Figure 6: Victorian losses per annum for 101 years to 1999 and for 21 year to 20207

2.5 TRADE-OFF BETWEEN HIGH INTENSITY WILDFIRE & LOW INTENSITY PRESCRIBED FIRE The ‘Sneeuwjagt curve’ indicates that if you want to avoid large intense forest wildfires you must prescribed burn at least 8% of the forest each year (Figure 7), using low intensity fire according to an appropriate spatial pattern across the landscape. South West WA have always maintained the rolling average proportion prescribed burnt above 3.5% and avoided mega fires. Victoria have never exceeded 3.5% pa prescribed burnt and experienced mega wildfires fires in 1983, 2003, 2006-07, 2009 and 2019-20, plus ‘campaign’ fires over the last 20 years. As a rule of thumb, on a rolling four year basis, the equation (blue line) suggests for every 1% increase in prescribed burning, wildfire loss is reduced by approximately 0.45% of the forest each year and if you want an average wildfire loss of less than 1.0% pa, you need to prescribe burn ca. 8% each year. Figure 7: Victorian mega fires could have been predicted from the “Sneeuwjagt curve”8

7 Derived from DELWP webpage and annual Reports. 8 The figure is based on 60 years of actual data for the entire forest in both regions. Victorian data derived from Tolhurst (2007) Submission to the “Inquiry into the Impact of Public Land Management Practices on Bushfires in Victoria” conducted by the Environment and Natural Resources Committee of the Victorian Parliament; and DELWP annual reports. WA data derived and updated from Sneeuwjagt (2011). The Effectiveness of Prescribed Burning in the Control of Large Eucalypt Forest Fires. 5th International Wildfire Conference, South Africa. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 13

2.5 VICTORIA’S FAILED FIRE RISK REDUCTION TARGET In 2014 Victoria chose a residual ‘fire risk’ approach. Figure 8 shows ‘fire risk’ (black line plotted against the right axis) only falls below the target of 70% when there has been considerable high intensity wildfire (orange bar plotted against the left axis). Achieving lower risk from more ‘low intensity’ prescribed burning (not high intensity wildfire) would have saved lives, properties, forests, ecosystems, biodiversity and the environment. Figure 8: Victoria's wildfire area and bushfire risk profile, 1980–2021 (last 3 yr predicted %)9

A ‘risky’ bushfire risk reduction target that is only achieved through burning large areas of forest by devastating bushfires is a nonsense. It is incongruous to good management of ecosystems and ‘good neighbor’ policy given the substantial damage done to neighbor’s assets, livelihoods and lives.

There appears to be a prima facie case of failure of ‘duty of care’, particularly given damage to the forest and neighboring properties and communities. The Victorian Bushfire Royal Commission recommended prescribed burning should be at least 5% of the forest each year and many fire behavior experts called for 8%, and only 2% has been achieved. 2.6 VICTORIA HAS USED PRESCRIBED BURNING EFFECTIVELY BUT NEEDS MORE The effectiveness of Victoria’s limited amount of prescribed burning was demonstrated in the 2019-20 East Gippsland bushfire. Recent prescribed burns saved Nowa Nowa, Waygara and Bruthen and according to reports, if implemented (rather than blocked by Head Office), Sarsfield may have been saved.

Some Victorian case studies10 on the effectiveness of prescribed burning on the suppression of wildfires are mostly drawn from the 1970’s and 1980’s when Victorian prescribed burning approached 5% of the forest in a few years:

 In five fires (Lorne-Anglesea 1983; Mt Macedon 1983; Stawell 1980; Barkstead 1980; and Dimboola 1980), assets were saved when firefighting was assisted by previous prescribed burning.  Fuel reduced areas limited the spread of multiple fires in remote country, including the Dargo fires of January 1978, when more than 60 fires were simultaneously ignited by lightning (lightning started the fires in 2019-20).  Extensive fuel reduced areas assisted the control of bushfires near Cann River in 1982-83 by; reducing fire intensity and spread to a level that allowed direct control close to the fire edge; and by creating low fuel zones where control lines for back-burning could be safely constructed.  Four bushfires in the Little Desert and Grampians during 1990-91, were limited from attaining a larger size by prescribed burns conducted one to three years earlier.

9 Derived from DELWP and its predecessor’s annual reports and webpage. 10 BNH CRC (2016). Effect of prescribed burning on wildfire severity – A landscape case study from the 2003 fires in Victoria. Report No 2016.189. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 14

 A prescribed burn in Brown Stringybark (Eucalyptus baxteri) woodland reduced bark hazard for up to 10 years, thereby reducing spotting potential, which greatly assisted bushfire suppression.  Fuel reduction greatly assisted suppression of the 1988 Bemm River bushfire in mixed eucalypt forest, with FFDI up to 82, fire spread of up to 4 km/hr and a total fine fuel load of approximately 20 t/ha with a highly flammable shrub layer.  Reduction in fire severity and assistance with fire suppression were still evident for areas that had received fuel reduction burns within ten years of the 2003 Victorian bushfires.  The Tostaree fire in February 2011, under severe to extreme fire danger, 40 degree temperature and strong winds, burnt 11,400 hectares before being slowed and eventually contained in extensive areas of low fuels from prescribed burning conducted from one to four years earlier. The Phoenix model predicted the fire would have burnt 30,000 ha if there was no fuel reduced area to help suppression. 2.7 RATIONAL FOR LOW INTENSITY PRESCRIBED FIRE TO MITIGATE WILDFIRE This summary draws heavily on a report11 by two experienced fire behaviour experts Neil Burrows and Rick Sneeuwjagt, and a recent presentation by Neil Burrows12. The Neil Burrows and Rick Sneeuwjagt rationale behind prescribed burning is as follows:

 Prescribed burning is the lowest-cost form of fuel reduction at the present time.  About 60 years of ‘actual’ historical data from the forests of south west WA unequivocally show that when the area of prescribed burning trends down, the area burnt by bushfire trends up.  The area burnt by wildfire escalates rapidly when the area of prescribed burning in a region falls below about 8% per annum (8% pa results in about 40% of the land carrying fuels 0-5 years old).  In the recent tragic bushfires in NSW and Victoria the prescribed burning amounted to less than 2% per annum, well below the threshold for effective bushfire mitigation (this results in only 10% of the bushland is carrying fuels 0-5 years old and 80% is carrying heavy fuels older than 10 years).  “If fuels are allowed to accumulate over large areas, suppression will be dangerous, difficult or impossible under all but mild weather conditions - large, damaging bushfires will result. Reducing fuel load and flammability reduces the speed and power of bushfire, reducing damage potential and makes fire suppression is easier. Inadequate levels of prescribed burning will be costly in more than dollar terms, and results in high risk.”  Without fuel reduction the accumulation of dead leaves, twigs, branches and bark builds up, and drives forest fires because it is at the base of the ‘fuel ladder’, it is dry, and it reaches very high loadings if left unburnt. “In forest fuels, doubling fuel load results in a four-fold increase in fire intensity”.  Prescribed burning often allows fires to be suppressed prior to extreme conditions under which firefighters are nearly always overwhelmed. “Fuel load / age have a major direct effect on fire speed, growth rate and fire intensity around the perimeter, hence lower perimeter fuel loads offer safer suppression options”. “Slower fires, lower intensity fires buy time for fire fighters and the community.” “Prescribed burning does not prevent bushfire, but greatly assists in safer suppression and synergises community preparedness”.  When confronted with multiple fires on the same day, fires burning into 1 or 2 year old fuel can be temporarily ignored, while all the focus is placed on the fires that threaten greatest damage.

11 How and why prescribed burning mitigates bushfire losses. Bushfire Front Inc. January 2020. 12 Neil Burrows (2019). Conflicting evidence, prescribed burning – when ‘evidence’ is not the reality. Invited keynote address to the AFAC Conference in Perth, September 2018. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 15

2.8 RATIONAL FOR FIRESTICK ECOLOGY The forest ecosystems of Victoria are adapted to low intensity fire. Complete absence of fire (proved to be impossible) is problematic for ecosystems and subjecting our forest ecosystems to very intense wildfire will cause ecological damage. The following commentary is drawn from Vic Jurskis:13

 Australian Aborigines operated sustainably with a firestick approach to managing forest ecosystems.  The state of many plant communities in Australia is now very different from that maintained by Aboriginal ‘firestick’ of low intensity burning over millennia, because we have allowed too many megafires.  All Australian forest ecosystems are dependent on low intensity fire apart from rainforest/scrub. Low intensity firestick prescribed burning does not penetrate or damage rainforest which is protected from burning during fuel reduction by low fuels in the forest surrounding it.  Low intensity fire is required to maintain the herb and grass ecosystems within our forests.  Fire sensitive species survive because low intensity fire does not penetrate the moist gullies or rock outcrops or closed scrub where fuel remains too moist for low intensity ‘firestick’ or prescribed fire.  Without low intensity fire, mega fires will eventually burn extremely large areas in a single fire and create large areas of uniform age leading to loss of biodiversity and threatened species e.g. threat to Leadbeater’s Possum from the large even-aged forest resulting from the 1939 mega bushfire.  Low intensity prescribed fire, typically over a ca. 10 intervals, maintains natural nutrient cycling.  Such burning also enhances diversity by maintaining recently burnt, black, brown and unburnt green patches.  Firestick burning is not simply fire protection but creation of better habitat and may be viewed as an artist’s brush creating aesthetic landscapes.  National Park managers have a history of some fire escaping from prescribed burns (Wilsons Promontory 2005) when done poorly under the wrong conditions or too infrequent.  Traditional Aborigines burnt all year round.  Elimination of disturbance by modern humans will be the greatest upset to the ecosystem leading to decreased diversity and decreased productivity.

The role of Aboriginal firestick ecology has also been favourably endorsed by Neil Burrows14:

 Aboriginal people used fire frequently, skilfully and purposefully.  The oldest land management practice by the oldest culture on the oldest continent.  In many landscapes, they were the predominant ignition source.  A new dynamic equilibrium established following their arrival.  Likely a fine-scale mosaic of diverse seral stages (fuel ages).  Megafires were probably rare events.

3. EXTENT OF THE DECLINE IN FOREST ECOSYSTEMS This section deals with term of reference (a) – The extent of the decline of Victoria’s biodiversity and the likely impact on people, particularly First Peoples, and ecosystems, if more is not done to address this, including consideration of climate change impacts.

Evidence is presented on the likely impact of forest management, fire regimes and climate change on the extent of decline or enhancement of ecosystems of Victoria’s native forests.

13 V. Jurskis (2015). Firestick Ecology, Fairdinkum science in plain English. Connor Court Publishing. 14 Neil Burrows (2019). Conflicting evidence, prescribed burning – when ‘evidence’ is not the reality. Invited keynote address to the AFAC Conference in Perth, September 2018. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 16

3.2 VICFORESTS MANAGEMENT OF HIGH CONSERVATION VALUES This section draws heavily on a May 2020 update review by VicForests15 of its High Conservation Value (HCV) Assessment, after changing circumstances as follows:

• New Victorian policy the ‘Forestry Plan’ to phase out timber harvesting in native forests over the next 10 years and exclude an additional 96,000 ha (‘Immediate Protection Areas, indicative’) of State forest from timber harvesting to protect Greater Gliders. • The 2019-20 wildfires which burn 54% of Mixed Species and 13% of the Ash forest in VicForests’ operable area. • The progressive implementation of VicForests’ new harvesting and regeneration systems introduced in 2019 to maintain and/or improve structure and biodiversity within its working forest area. • The modernisation of Regional Forest Agreements for Victoria with assessment of High Conservation Values (HCVs) at the Forest Management Unit (FMU) level to be complemented by more detailed assessments at the local landscape level and coupe level over time.

Following the 2019/20 wildfires, VicForests adopted these actions under the precautionary principle:15

 No harvesting in East Gippsland FMA until further assessments and certainty is gained.  Restricted harvesting of fire affected areas to only fire killed Ash stands.  Retention of all green patches and retention of all green/live trees where safe to do so.  Retention of all dead large hollow bearing trees where safe to do so.  Developing a ‘gaps and corridors’ method of salvage harvest, to minimise the creation of large contiguous areas impacted, and to retain forest structure and connectivity.

VicForests have passed a recent audit according to the internationally endorsed Programme for the Endorsement of Forest Certification (PEFC audit), PEFC ‘Responsible Wood’. PEFC is a global authority on sustainable forest management, a leading global alliance of national forest certification systems and is more widely used than FSC. PEFC focuses on ‘responsible management’, continuous improvement and recognises four principles to sustainable forest management – Environmental, Economic, Social and Cultural:

a) PEFC environmental sustainability entails maintaining and or enhancing:  Ecological processes within forest ecosystems.  Forest soil and geological features.  Food chains and energy flows.  Carbon, nutrient and water cycles.  The biodiversity of forests. b) PEFC economic sustainability entails optimizing the economic benefits for income, employment, goods and services from the mixture of forest uses within ecological constraints. c) PEFC social sustainability entails maintaining and enhancing the net social benefit derived from the mixture of forest uses while maintaining options for the future. d) PEFC social sustainability entails maintaining and enhancing the cultural capital of the community - the collective knowledge, wisdom, cultural practices and related environmental assets.

PEFC assessment is undertaken according to nine rigorous criteria:

 Criterion 1 - Systematic Management; provide for continual improvement.  Criterion 2 - Stakeholders; demonstrate proactive stakeholder engagement.  Criterion 3 - Biodiversity; maintain or enhance biodiversity.  Criterion 4 - Forest Productive Capacity; maintain the productive capacity of forests and land.  Criterion 5 - Forest Ecosystem Health; maintain forest ecosystem health and vitality.

15 VicForests (2020). Management of High Conservation Values, Status update. May Draft Ecologically sustainable management of Victorian native forests – J N Cameron

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 Criterion 6 - Soil and Water Resources; protect soil and water resources.  Criterion 7 - Carbon; maintain or enhance forests' contribution to the carbon cycle.  Criterion 8 - Cultural Values; protect and maintain, for Indigenous and non-indigenous people, their natural, cultural, social, recreational, religious and spiritual heritage values.  Criterion 9 - Social and Economic Benefits; maintain and enhance long-term social and economic benefits.

VicForests operations meet PEFC certification on the ca. 450,000 ha it manages.

VicForests monitor its performance against criteria under the High Conservation Values (HVC’) used by the Forest Stewardship Council (FSC) under the FSC National Forest Stewardship Standard of Australia (February 2019), FSC ‘Controlled Wood’.16 Unlike PEFC who emphasise responsible management and continuous improvement, FSC emphasise ‘controlled’. The inherent risk in this is that the Certifier controls the Manager, and this can stifle initiative and retard continuous improvement in ecological-socio-economic outcomes.

VicForests has decided to postpone achieving the FSC® ‘Controlled Wood’ Standard by the end of 2020 due to COVID-19 restrictions on international auditors, last summer’s bushfires, FSC® ANZ (Australia & NZ) governance issues, and VicForests’ upcoming appeal against a Federal Court decision. FSC governance issues pertain to alleged inappropriate activist activity associated with FSC ANZ.

VicForests is appealing the ‘Friends of Leadbeater’s Possum’ Federal Court decision which relates only to the small number of forest areas harvested between 2014 and early 2019. VicForests now uses a different approach to harvesting that provides even greater protection for threatened species. Also an additional 96,000 ha has been set aside in November 2019 under the ‘Forestry Plan’. All timber harvesting and regeneration operations continue to be conducted in accordance with Victoria’s strict environmental regulations and the State’s Forest Management Zoning scheme. They are also scrutinised by the Office of the Conservation Regulator and its strict regulatory guidelines ensuring protection of threatened flora and fauna.

The FSC criteria are presented below, as they are used by VicForests in their May 2020 status report:

 HCV 1 Species diversity - Concentrations of biological diversity including endemic species, rare, threatened or endangered species, that are significant at global, regional or national levels.  HCV 2 Landscape-level ecosystems and mosaics - Intact forest landscapes, large landscape-level ecosystems and ecosystem mosaics that are significant at global, regional or national levels, and that contain viable populations of the great majority of the naturally occurring species in natural patterns of distribution and abundance.  HCV 3 Ecosystems and habitats - Rare, threatened, or endangered ecosystems, habitats or refugia.  HCV 4 Critical ecosystem services - Basic ecosystem services in critical situations, including protection of water catchments and control of erosion of vulnerable soils and slopes.  HCV 5 Community needs - Sites and resources fundamental for satisfying the necessities of local communities or Indigenous Peoples (for livelihoods, health, nutrition, water, etc.), identified through engagement with these communities or Indigenous Peoples.  HCV 6 Cultural values - Sites, resources, habitats and landscapes of global or national cultural, archaeological or historical significance, and/or of critical cultural, ecological, economic or religious/sacred importance for the traditional cultures of local communities or Indigenous Peoples, identified through engagement with these local communities or Indigenous Peoples.

The ‘Victorian Forestry Plan’ for a complete cessation of native forest harvesting ignores HCV 5 and 6 and the importance of some harvesting regeneration for the maintenance of ecosystem mosaics under HCV 2, and the progress made on improving High Conservation Values (HCV’s) within the ca 450,000 ha of State Forest managed by VicForests for multiple, use including wood production.

Ecologically sustainable management of Victorian native forests – J N Cameron

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It appears that good progress has been made by VicForests on improving High Conservation Values. The following commentary on section 3.2.1 to 3.2.6 is drawn from VicForests16 unless shown otherwise and generally relates to the ca. 450,000 ha in VicForests working area within the Eastern Forest Management Unit, within which harvesting is only generally permitted within the General Management Zone of State Forest and excluded from all Parks, Reserves and Special Zones. 3.2.1 HCV 1 Species diversity - rare, threatened or endangered species VicForests undertakes pre-harvest surveys, investigating the presence or absence of sensitive flora and fauna including Leadbeater’s Possum, Greater Gliders, Yellow-bellied Gliders and other species. VicForests also conducts collaborative programs on biodiversity.

Refugia, valley heath forest, floodplain riparian woodland and rainforest EVCs; areas with steep climatic and environmental gradients (e.g. mountain ranges and deep valleys), mountain tops that provide habitat for a range of endemic species e.g. Mt Baw Baw Frog (Philoria frosti), Mt Buffalo Sallee (Eucalyptus mitchelliana) and Buffalo Sallow Wattle (Acacia phlebophylla) have been incorporated into the national reserve system. Species of significance include, but are not limited to, the Powerful Owl (Ninox strenua); Leadbeater’s Possum (Gymnobelideus leadbeateri); and Spot-tailed Quoll (Dasyurus maculatus maculatus).

Leadbeater’s Possum (Gymnobelideus leadbeateri).

Leadbeater’s Possum was listed as critically endangered in 2014, mainly due to the loss of species habitat from the 2009 bushfires. High intensity wildfire in Victoria is the greatest threat to the possum.17 On-going survey work by VicForests is showing that Leadbeater’s Possum is more prevalent than was known when the Action Statement was published in 2014, and the species depends on diversity of forest structure to provide both nesting and feeding sites.18 In 2019, the Threatened Species Scientific Committee conservatively estimated the Leadbeater’s possum population at between 2,500 and 10,000.17

Since 2014, 783 Leadbeater’s Possum colonies have been identified across State Forests, Parks and Reserve lands in Victoria. A VicForests’ study found six new individual colonies located up to 15 km outside the previously known range and showed they are present in both mixed-species and ash-dominated forests. Leadbeater’s were recorded more often in mixed age-class stands of fire regrowth and younger timber harvesting regrowth than in old growth forests. Old growth forests are not necessarily the preferred or exclusive habitat. VicForests is investigating a range of site-specific forest management plans that can accelerate the development of key features of Leadbeater’s Possum habitat.19

Greater Glider.

Preliminary post-harvest results show that individual gliders continue to reside in coupes where habitat retention has been implemented. Further surveys were conducted throughout 2019-20 to assist in understanding the long-term occupancy of glider populations in the managed forest.19

Spotted Tree Frog (Litoria spenceri).

Potentially threats to this species include disturbance in and adjacent to streams resulting in changes to water flow, water quality, stream sedimentation or other changes to the physical or biotic habitat. These include stream sedimentation and physical disturbances associated with intense fire such as wildfire, poorly constructed/managed roads, harvesting in the immediate vicinity of frog populations (excluded), human disturbances, weed invasion, impoundments, careless use of herbicides or pesticides, and possibly grazing.20

16 VicForests (2020). Management of High Conservation Values, Status update. May Draft. 17 VicForests Fact Sheet. 18 VicForests Annual Reports. 19 VicForests Annual Reports. 20 DSE (2004) Flora & Fauna Guarantee Act, Action Statement No 112. Ecologically sustainable management of Victorian native forests – J N Cameron

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Birds.

The Swift Parrot (Lathamus discolour) and the Brolga (Grus rubicunda) are seasonal, but neither of these are strongly forest-dependent and occur more commonly in open woodlands. Similarly known major migratory species such as the Bogong Moth (Agrotis infusa) move through the forests but do not congregate in the VicForests Working Area. Collaborative research is underway on the effectiveness of acoustic monitors to enable analysis of thousands of hours of bird-call data to improve VicForests’ understanding of avian biodiversity.19

Beetles (Coleoptera: Staphylinidae, Nitidulidae and Leiodidae species.)

Diversity and taxon richness of these predatory and fungus eating beetles was not affected by two short rotation prescribed fires in spring. Activity levels were expected to return to pre-fire activity levels without causing unacceptable adverse impacts on litter-frequenting Coleoptera.21 The fires were 3 years apart, whereas prescribed burning for bushfire mitigation is typically much longer such as 10+ years. 3.2.2 HCV 2 Landscape-level ecosystems and mosaics - significant global, regional or national There are no contiguous forests landscapes of global significance, within the eastern FMU (or Victoria), the large areas of contiguous native forest that resembles intact or undisturbed forest and Wilderness Areas are within designated parks and reserves and Wilderness Areas and excluded from logging.

The mountain ash forest of the Central Highlands, constitute part of a landscape-level forest ecosystem that the International Union for Conservation of Nature (IUCN) Red List of Ecosystems has listed as ‘critically endangered’, based on the exceptionally tall height of the mountain ash forests and the reported risk of ecosystem collapse. VicForests challenge this listing. The status of ‘critically endangered’ was based on modelling using a probabilistic model of tree growth stages to estimate the risk of ecosystem collapse where the risk of collapse was based largely on the loss of hollow-bearing trees (using old-growth forest as a surrogate) which substantially under-estimated the presence of hollow-bearing trees located within VicForests’ estate, but outside the old-growth forest. Most hollow-bearing trees are in areas excluded from harvesting in streamside reserves or are actively marked out for exclusion from felling.

VicForests is not aware of any corridors that are crucial for species migration in the Eastern FMU and much of the FMU has contiguous, intact forest landscapes. State forest provide habitat connectivity between larger forest areas, e.g. national parks and reserves, and habitat connectivity is incorporated in the ‘protected’ Special Protection Zone or Special Management Zone.

Areas of contiguous forest with relatively low levels of post-European disturbance are all protected within the dedicated CAR reserve system, as either National Parks, State Parks, Wilderness Parks or other parks and reserves.

IUCN-classified Wilderness Areas in eastern Victoria are designated as special conservation areas (including parks and reserves), located outside areas of State forests available for sustainable timber harvesting.

Intact forest landscapes are substantially protected by the existing CAR reserve system, and complemented by additional reservations and connectivity with State forest areas where possible, through VicForests’ tactical planning process, culminating in Timber Release Plan (TRP) proposals and approvals.

At the forest coupe or compartment level, VicForests manage landscape-level native forests with increased focus on maintaining ecological structural diversity and integrity.

21 N. G. Collet & F. G. Newman (1995). Effects of two spring prescribed fires on epigeal Coleoptera in dry sclerophyll eucalypt forest in Victoria, Australia. Forest Ecology and Management V76. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 20

3.2.3 HCV 3 Ecosystems and habitats - rare, threatened, or endangered, including refugia Rainforest communities are protected from timber harvesting under the Code, including the use of buffers to maintain microclimate, protect from disease, wildfire, regeneration burning and other disturbance.

While some areas of rainforest fall within the General Management Zone (GMZ), timber harvesting is not permitted and appropriate Code buffers are applied. Where rainforest is found in the field and it isn’t already classified as Special Protection Zone (SPZ) a SPZ is created to preclude harvesting.

Old-growth and ecologically mature forest stands are protected within the permanent reserve system and the 30% in VicForests’ working area is protected in Special Protection Zones. Old-growth forest can be more resilient to fire than younger stands, because of greater bark thickness, leaving some scarred old trees surrounded by younger regeneration, creating multi-aged stands.

Any ash stand in the Leadbeater’s Possum range is excluded from harvesting, with a 100 m buffer around the modelled old-growth polygon

Harvesting and regeneration systems incorporate the retention of more hollow-bearing trees and recruiting potential habitat trees; focus on protecting retained trees through post-harvest operations; and implementing alternative regeneration treatments to minimise threats to High Conservation Values (HCVs).

Some forests may be at risk of changing where the interval between fires is too short i.e. eucalypt forests which can only regenerate from seed (‘obligate seeder’ ash species) which can be lost if forests are repeatedly burnt before regrowth has reached the maturity to produce seed. Large-scale wildfires are recognised as a threat and improved fuel reduction and wildfire mitigation critical. Localised effects can be mitigated through aerial re-seeding.

Genetically distinct populations of Mountain Galaxias and the Koala population in the Strzelecki Ranges, are present within conservation areas that provide for their protection. 3.2.4 HCV 4 Critical ecosystem services – protection of water catchments and control of erosion An ecosystem service is ‘critical’ where a disruption is likely to cause, or poses a threat of, severe negative impacts on the welfare, health or survival of local communities, on the environment, on High Conservation Values (HCVs), or on the functioning infrastructure (roads, dams, buildings, etc.). Criticality here refers to the importance and risk for natural resources and environmental and socioeconomic values.

Most of the major floodplain areas in Victoria including riverine, wetland, riparian and flood dependant native vegetation, that provide important barriers to flooding, are currently under agricultural land uses (i.e. cropping or pasture), and are outside of VicForests’ working forest area. Riparian zones within the General Management Zone (GMZ) are subject to protection measures under the Code.

Providing protection from erosion in harvestable forests is protected under the Code. Harvesting is excluded on slopes greater than 30 degrees (25 degrees on areas with granitic soils in the East Gippsland FMA) and buffers and filter strips around waterways to minimise erosion. These topographic exclusions together with riparian zone exclusions result in significant additional ‘reserve areas’ being created.

Fire Management Zones established by DELWP under the Code of Practice for Bushfire Management on Public Land (2012), provides fire management procedures and practice on public land in Victoria (Figure 9):

 Asset Protection Zone - High level localised protection for human life, property and key community assets.  Bushfire Moderation Zone – Reduce the speed and intensity of bushfires.  Landscape exclusion Zone – Reduce overall fuel level and bushfire hazard in the landscape. Ecological resilience through appropriate fire regimes. Landscape Management for specific values.  Planned Burning Exclusion Zone – Excludes prescribed burning primarily in areas intolerant to fire

Ecologically sustainable management of Victorian native forests – J N Cameron

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Figure 9: DELWP Fire Management Zones in Eastern Victoria (Easton FMU)

Designated Water Supply Catchments within VicForests’ eastern Forest Management Unit (FMU) have strict harvesting limits (limited to ca. 200 ha per year), and include the following main catchments:

 Yarra Tributaries catchments (Starvation, Armstrong, McMahons and Cement Creeks).  Thomson, Bunyip, and Tarago catchments managed by Melbourne Water.  Learmonth Creek catchment, which is critical to the Powelltown community.

Within the Designated Water Supply Catchments detailing harvest limits and protection prescriptions apply, including slope limits, seasonal closures, buffer strips and filter strip widths for timber harvesting operations and associated roading and regeneration.

There are multiple requirements relating specifically to the management of riparian zones, with the focus on protection through the Code, principally on managing water quality and biodiversity, including aquatic and riparian habitats. Maintaining riparian zones by using buffers and filter strips are expected to assist in providing protection from flooding also.

The intensity of regeneration burns has been reduced by burning on cooler days to lower the risks of fire escape. Other regeneration treatments that further reduces risks of damage to retained trees include measures such as mechanical disturbance to create a seed bed (instead of burning), the use of hand planting, burning under cooler conditions and removal of logging slash away from individual habitat trees. 3.2.5 HCV 5 Community needs - for livelihoods, health, nutrition, water High Conservation Value 5 (HCV 5) applies where local people use the resource to obtain basic needs on which they are critically dependent, and where a fundamental loss of the resource would significantly decrease local community well-being. Potential fundamental basic needs include, but are not limited to unique sources of water for drinking and other daily uses; food, medicine, fuel, building and craft resources; the production of food crops and subsistence cash crops; protection of “agricultural” plots against adverse microclimate; and traditional farming practices.

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 22

The FSC® National Forest Stewardship Standard specifies HCV 5 values as a site or resource that is fundamental for satisfying basic needs if the services it provides are irreplaceable (i.e., if alternatives are not readily accessible or affordable), and if its loss or damage would cause serious suffering to affected stakeholders. HCV 5 is most likely to be more important in areas where whole communities or significant portions of them are heavily dependent on those ecosystems for their livelihoods, and where there is limited availability of alternatives. There would appear to be a case that this applies to ‘Timber Towns’.

It appears that HCV 5 does to apply to timber harvesting within VicForests eastern FMU, when based on the specific FSC® guidance relating to forest areas being fundamental to meeting basic needs of local communities, in respect to drinking and other daily uses, the irrigation of subsistence food crops, and provision of food and medicines.

However, VicForests argues that its Working Forest Area supports timber industry jobs that generate local employment and provide the basic needs of local communities and many rural towns and local communities depend on the timber industry, e.g. Noojee, Heyfield, Swifts Creek, Orbost, Morwell, and Bendoc. If State forest areas were ‘closed’ to sustainable timber harvesting and downstream processing, this will reduce or remove a source of socioeconomic development that supports basic needs in these communities. The new FSC® National Forest Stewardship Standard of Australia clearly sets out a definition of HCV 5 that limits the consideration of basic needs to subsistence and health. This is unfair, inequitable and unjust.

The ‘Forestry Plan’ does not comply with a ‘fair and equitable’ definition of High Conservation Value 5 as the decline and eventual loss by 2030, of access to the native forest resource for timber production will substantially decrease local community wellbeing. FSC appears to downplay the importance of socioeconomics in ecologically sustainable development. VicForests notes that HCV 5 ensures access rights for apiarists, graziers, recreationists, tourism operators, and Aboriginal traditional owners. Surely access rights should also apply to the current low level of sustainable timber harvesting seems (subsistence level). 3.2.6 HCV 6 Cultural values - sites, resources, habitats and landscapes culturally significant There are extensive areas of public native forests with aesthetic values within the eastern FMU. Sites of outstanding national significance, including natural landscapes, are recognized as part of the National Heritage List and are protected under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and include the Australian Alps National Parks and Reserves.

Individual natural feature zones (e.g. caves, mineral springs geological areas) and Heritage River corridors with aesthetic value linked to forest recreation (e.g. bushwalking), are conserved under SPZs; along with other (non-heritage) rivers and streams in the Central Highlands, that are of significant natural, scenic or recreational value. Areas with high scenic quality and visual sensitivity are also protected under the Code.

Non-Indigenous cultural heritage sites (past gold mining and sawmill operations, tramways, cattlemen’s huts, and settlements are listed on either the National Heritage List or the Victorian Heritage Database and the most significant or representative sites are in Special Protection Zones (SPZs), in which timber harvesting is not permitted; or in Special Management Zones (SMZs) that allow modified harvesting operations following strict procedures under the VicForests Instruction - Identification and Protection of Non-Indigenous Cultural Heritage Values.

The Heritage Act 2017 provides blanket protection for all historic archaeological sites and objects older than 75 years. Indigenous historic sites include areas with scar trees, mounds, freshwater middens, stone tools and surface scatters. All Indigenous artefacts are protected under the Aboriginal Heritage Act 2006 and their specific location is kept confidential by Aboriginal Victoria.

Many research sites are protected within SPZ areas, but some are in GMZ areas; with no adverse impact by harvesting activities. This includes the 1980s Silvicultural Systems Project (SSP) in Mountain Ash near Tanjil

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 23

Bren, and in lowland mixed forests to the east of Orbost; and ANU network of forest research sites in the Eastern Highlands, with some since 1983; and Variable Retention Harvesting research which dates to 2003.

HCV 6.4 Social (including economic) values includes special recreation values (which may also represent aesthetic or amenity values registered under HCV 6.1, and forest-based enterprises that are dependent on forest management and are of critical importance to local communities. For example, the apiculture (beekeeping) industry in Victoria is dependent on licenced access to native forests on public land administered by DELWP under the Livestock Disease Control Act (1994) and is predominantly located within low elevation mixed eucalypt species forest.

All Indigenous artefacts are protected under the Aboriginal Heritage Act 2006 (Vic). 3.3 IMPACT OF WOOD PRODUCTION ON VICTORIAN NATIVE FORESTS FLORA & FAUNA Forestry operations for wood production pose the lowest threat to Flora and one of the lowest threats to fauna relative to other more serious threats. Threats to threatened native flora are much higher from grazing from introduced and native fauna, invasive species, competition from introduced plants, clearing for farming and mining, unsuitable fire (essentially wildfire) and illegal collection. Threats to threatened native fauna are much greater for invasive species, competition from introduce animals, wildfire, illegal hunting, predation by introduced animals and clearing for agriculture and mining (Figure 10). Figure 10: Threat rating and threat categories for forest-dwelling threatened species22

Small localised populations are an issue for threatened plants and animals. Forest fragmentation, (the extent to which forest areas are separated by or adjoin non forest areas) can be a contributing factor. At the 1- hectare scale, 72% of Australia’s native forest area is not fragmented (comprised of areas that are completely bounded by forest) and 68% of Australia’s native forest is in patches of over 100 thousand hectares. Native forest that is not fragmented is typically in higher rainfall regions that have experienced the least clearing for agriculture, in state forests used for timber production, and in conservation reserves. The most fragmented

22 Derived from ABARES (2018). Australia’s State of the Forests Report 2018 Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 24 forests occur in drier regions (not used for timber) where woodland forest borders vegetation with lower tree canopy cover and in areas with higher impacts from clearing for agriculture and from urban development.

The number of recorded forest-dwelling species of flora and fauna have been steadily increasing in Victoria over the last 10 to 15 years (Figure 11). Figure 11: Number of Victorian native forest vascular fauna and vertebrate fauna species22

3.4 IMPACT OF PEST WEEDS AND ANIMALS ON VICTORIAN NATIVE FOREST ECOSYSTEMS Focus of government and green activists on wood production forests, in their pursuit of an improvement of ecosystems has been misplaced, as the major threats are elsewhere. This misplaced focus has come at a huge opportunity costs. The substantial human and financial resources could have been deployed on proactive management of the threats from the following threatening processes including pest plants animals and diseases (Table 1). Table 1: Listed key threatening processes affecting forest-dwelling threatened species23

Key threatening process Date listed Competition and land degradation by rabbits 16/07/00 Competition and land degradation by unmanaged goats 16/07/00 Dieback caused by the root-rot fungus (Phytophthora cinnamomi ) 16/07/00 Predation by European red fox 16/07/00 Predation by feral cats 16/07/00 Land clearance (for changed land-use such as agriculture) 4/04/01 Loss of climatic habitat caused by anthropogenic emissions of greenhouse gases 4/04/01 Psittacine circoviral (beak-and-feather) disease affecting endangered Parrot (psittacine) species 4/04/01 Predation, habitat degradation, competition and disease transmission by feral pigs 6/08/01 Infection of amphibians with chytrid fungus, resulting in chytridiomycosis 23/07/02 Reduction in biodiversity of Australian native fauna & flora due to the red imported fire ant, Solenopsis invicta 2/04/03 Loss of biodiversity & ecosystem integrity by yellow crazy ant (Anoplolepis gracilipes ) on Christmas Island 12/04/05 Loss & degradation of native plant & animal habitat by invasion of garden plants, including aquatic plants 8/01/10 Novel biota and their impact on biodiversity 26/02/13 Exclusion of birds from woodland & forest habitat by over-abundant noisy miners (Manorina melanocephala ) 9/05/14 Various plants and animals rely on different forest ecosystem seral “stages” to meet their habitat needs. Some plant species can only develop in open, treeless, freshly disturbed sites. Landscapes and the ecosystems benefit from the presence of ‘age’ sequences. The process of forest aging called “succession”

23 ABARES (2018). Australia’s State of the Forest Report. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 25 transforms the composition of forested ecosystems as biotic communities respond to and modify their environment. Succession is an important topic in landscape ecology because of its significant effects on landscape diversity and the subsequent biological diversity and viability of various plant and animal populations. Habitat needs of most forest organisms are met if a broad range of forest stand ages (“seral stages”) are maintained across landscapes. Managing biodiversity at the landscape level should24:

 Protect old growth and other biologically important ecosystems; and  Maintain a range of seral stages. 3.5 IMPACT OF CLIMATE CHANGE ON VICTORIAN FOREST ECOSYSTEMS One of the most pronounced impacts of climate change is likely to be through the frequency and intensity of wildfire. This impact of wildfire can be moderated substantially by prudent fuel reduction in our forests.

While there is focus on the potential risks to biodiversity of ecosystems directly as a result of climate change or indirectly as a result of fire, the evolutionary history suggests we have the genetic ‘foundation’ for coping with changing climate and fire regimes (and better able to cope with low rather than high fire intensity)25.

Adaption of our forests to climate change will be enhanced by ensuring sufficient genetic recombination through sexual reproduction. This essentially means prudent application of harvesting plus regeneration from seed. Harvesting is required to ensure sufficient light and reduced competition so new seedlings can emerge. Prescribed fire or some other appropriate disturbance is required to provide a ‘seedbed’ for successful germination of the next generation, resulting from sexual reproduction embodying genetic recombination.

Evidence exists25 that forest plants adapt to climate changes. Fossil records show changes of climate on plant growth are partly accommodated by adaptions in plant structure and function. Within species the density of stomata change with changes in concentration of atmospheric CO2. The potential increase in productivity from ‘CO2 fertilisation’ could be offset by decreased density of stomata leading to little net change in CO2 concentration inside leaves. Plants adapt many other fundamental biochemical processes in response to changes in temperature or water availability, such that they remain productive and reproductively viable.

The ability of forest ecosystems to adapt to fire is very dependent on the intensity, frequency and spatial extent, and we should limit high intensity wildfire. A decline in fuel reduction burns in Victoria over the past 20 years is associated with an increased abundance of woody shrubs (some promoted by wildfire) at the expense of grasses and herbs which are just as important components of biodiversity25.

Increased frequency of unsuppressed wild fires as a result of hotter and drier conditions associated with climate change, may also lead to an increase in woody shrubs25. High intensity wildfire in lower rainfall forests (600-650 mm) stimulated the rapid recovery of a shrubland with the ‘elevated’ fuel component (woody shrub) 600% above the pre-fire fuel loads after six years. The shrubland was estimated to support fireline intensities and rate of spread at least 50% greater than the traditional forest structure26.

Australian mean annual temperature has increased by one degree over the last 40 years, insufficient to cause measurable change in forest ecosystems or meaningful impact on fire behaviour. The impact of climate change on drought may impact on ecosystems, and drought combined with increased days of severe fire weather are likely to have an impact on frequency and severity of bushfires and thus impact on ecosystems.

It would appear that some of the change in severe weather observed over the last 30 years is a reversal of a slight decline over 130 years to 1991 as indicated by number of days above 35 °C and the number of days above 40 °C. The 13% decline in mean annual rainfall over the last 60 years is more significant (Figure 12).

24 Ministry of Forests British Columbia (1998). Seral Stages across Forested Landscapes: Relationships to Biodiversity. Extension Note. 25 From M. Adams and P. Attiwill (2011). Burning issues, sustainability and management of Australia’s southern forests. CSIRO AND Bushfire CRC. 26 L. Volkova, A. Aparicio and C.Weston (2019). Fire intensity effects on post-fire fuel recovery in Eucalyptus open forests of south-eastern Australia. Science and the Total Environment 670. Ecologically sustainable management of Victorian native forests – J N Cameron

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Figure 12: Melbourne’s days of extreme temperature and rainfall over the last 150 years27

3.6 IMPACT OF CLIMATE CHANGE ON NATIVE FOREST CARBON STOCKS Climate change may have a considerable impact on soil carbon. The respiration of soil and litter (heterotrophic respiration) is one of the most important process in the carbon cycle because of the huge amount of carbon stored in soils. Losses of soil carbon by respiration (oxidisation by soil microbes) is highly dependent on temperature and vegetation types25 and loss by fire is highly dependent on fire intensity.

Victoria’s native forest timber industry has a positive net impact on emissions, conserving 835 t/ha of carbon. This exceeds the 522 t/ha of carbon that would be conserved under a ‘no harvest’ model such as the governments new ‘Forestry Plan’. A kilogram of timber consumes 1.47 kilograms of carbon dioxide (CO2) and 28 returns 1 kilogram of Oxygen (O2) to the atmosphere. About 50% of wood dry weight is carbon. 3.7 IMPACT OF BUSHFIRES OR WILDFIRE ON VICTORIAN NATIVE FORESTS Fire is an essential component of many ecosystems, a natural instrument for maintaining biodiversity and hence a tool that enables many species to survive29. Whether the impact is positive or negative depends on the intensity of the fire, the interval between fires and the spatial distribution of the burnt areas.

Most wildfire particularly the intense Mega fires like 2003, 2006-07, 2009, and 2019-20 and several campaign fires, have caused considerable damage to ecosystems The damage was because they were too intense, the spatial distribution of the burnt area was very extensive and/or the interval between the wildfires was too short. These catastrophic outcomes were avoidable with better fire mitigation, including better fuel reduction, fire access tracks, firebreaks, earlier fire detection, more rapid initial response and unimpeded professional fire suppression methods30.

Fire suppression has been impeded and restricted by poor access and reluctance to employ containment lines and back-burning, violating the precautionary principle and the sanctity of human life.

Victoria has experienced increased mega bushfires over the last 20 years. In the 101 years to 1999, there were only two fires that exceeded a million hectares (1939 and 1944). In the last 20 years Victoria has had four mega fires with three exceeding 1 million ha, which combined burnt 4.7 million ha of the 7.8 million ha of public forest (Figure 13).

27 Data from Bureau of Meteorology. 28 Vicforests 29 C. Bryant (2008). Understanding bushfire: trends in deliberate vegetation fires in Australia. Technical and Background Paper No. 27. Australian Institute of Criminology, Canberra. 30 J. N. Cameron (2020) Victorian mega bushfires and government policy and practise. Submission to Royal Commission into National Natural Disaster Arrangements. Ecologically sustainable management of Victorian native forests – J N Cameron

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Figure 13: Location of very large bushfires in 2003, 2006, 2007, 2009, 2013, 2014 and 2019-20

These wildfires have caused substantial loss of assets, loss of life and widespread environmental damage. The 2019-20 East Gippsland and North East Victorian bushfires burnt about 1.6 million ha and have caused considerable ecological damage:

 Of the 104 parks managed by Parks Victoria, 34 were entirely burnt including Alfred National Park and Lind National Park in East Gippsland.  About 31% of the state’s rainforest, 24% of damp forests, and 34% of lowland forest may be burnt and the trim shield fern (Lastreopsis decompsita) may now be extinct in Victoria.  About 70% of the habitat of alpine tree frogs, green and golden bell frogs may be burnt.  An estimated 100% of the potential habitat of the East Gippsland Galaxis (a native fish) and over 70% of the Gippsland Water Dragon’s habitat have been burnt.  About 40% of the known habitat of the sooty owl, diamond python, long footed potoroo, long nosed bandicoot and brush-tailed rock wallaby have been burnt and about 25% of the state’s greater glider population is believed to have been lost. 3.8 IMPACT OF HARVESTING ON FLAMMABILITY OF VICTORIAN NATIVE FORESTS Logging in multiple use forests does not make them more prone to fire than unharvested forests in reserves. Regrowth forests are no more fire prone than older forests. The flammability of stands is explained by fuel accumulation and stand structure. Lindenmayer et al31 proposed that logging makes “some kinds of forests more prone to increased probability of ignition and increased fire severity.” A team of eminent Australian forest scientists lead by Peter Attiwill32 refuted the proposition as follows:

31 Lindenmayer, D.B., Hunter, M.L., Burton, P.J. & Gibbons, P. (2009) Effects of logging on fire regimes in moist forests. Conservation. Letters., 2, 271‐ 277 32 P. Attiwill, P. F. Ryan, N. Burrows, N. P. Cheney, L. McCaw, N. Neyland and S. Read (2013). Timber Harvesting Does Not Increase Fire Risk and Severity in Wet Eucalypt Forests of Southern Australia. Conservation Letters, A journal of the Society for Conservation Biology.

Ecologically sustainable management of Victorian native forests – J N Cameron

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We find no support for that argument from considerations of eucalypt stand development, and from reanalysis of the only Australian study cited by Lindenmayer et al. In addition, there is no evidence from recent megafires in Victoria that younger regrowth (<10 years) burnt with greater severity than older forest (>70 years); furthermore, forests in reserves (with no logging) did not burn with less severity than multiple‐use forests (with some logging). The flammability of stands of different ages can be explained in terms of stand structure and fuel accumulation, rather than as a dichotomy of regrowth stands being highly flammable but mature and old‐growth stands not highly flammable. Lack of management of fire‐adapted ecosystems carries long‐term social, economic, and environmental consequences. (Locking up forests in reserves has delivered lack of management).

Microclimate changes follow both logging and wildfire, with the reestablishment of the understorey, mid- storey, and over-storey layers. Immediately following logging, and particularly after clear‐felling and regeneration burning, soil becomes wetter with greatly reduced interception and evapotranspiration, and there is virtually no surface fuel. Experience in Western Australia (Figure 14) and Victoria is that up to age 10 years, regenerating eucalypt stands do not burn readily. Figure 14: Unburnt 10 y E. diversicolor (A) and burnt mature E. Diversicolor (B) & E. marginate (C)33

Dense regeneration less than 5 years old may not burn at all even under extreme conditions due to the absence of a continuous layer of surface fuel, and the presence of dense understorey that restrict the drying effects of solar radiation and wind on surface fuels, as shown in the photo following the Victorian 2009 Black Saturday bushfire (Figure 15).

33 Derived from Attiwill et al (2013). Ecologically sustainable management of Victorian native forests – J N Cameron

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Figure 15: Young unburnt regeneration (fore-/mid-ground) & burnt 70 year forest (background) 33

A 2016 study of over 1 million hectares burnt by wildfire in the 2003 Victorian Alpine fire, showed that fire severity across the landscape was driven by weather conditions, slope, aspect, fuel levels, atmospheric stability, and the scale of the fires. There was no discernible adverse impact of timber harvesting on fire severity at the landscape scale. Closing down native forest timber harvesting is likely to have a much greater impact on increasing bushfire severity and extent across the landscape than an increase in local fire severity claimed by the opponents of timber harvesting. A holistic, long-term and professional view of forest and fire management is needed rather than short-termed, single-issue perspectives.34 3.9 HARVEST REGENERATION CAN HELP AVOID ECOSYSTEM DECLINE FROM WILDFIRE At Connors Plain following the Victorian Great Divide Fire in 2007, young regrowth of E. delegatensis remained unburnt while mature E. delegatensis was killed (Figure 16). Figure 16: Unburnt young regrowth (foreground) & killed mature forest (background) 33

After the 2009 bushfires in Victoria, young regeneration comprised some of the only areas unburnt during the high‐intensity stages of the wildfire (Figure 17 - photo left, infrared image right). These unburnt areas provide some ‘green’ in a largely fire‐killed landscape, providing significant protection from a potentially even larger ecosystem loss from wildfire if without the regenerated areas. These young forests do not burn because the post-harvesting regeneration burn has removed the fine fuels, and the re-establishing regeneration does not generate sufficient fine fuels to carry a fire until at least five years and up to ten years.

34 K. Tollhurst & J. Vanclay (2020 IFA website). Does timber harvesting make forests more flammable? IFA Op Ed. Ecologically sustainable management of Victorian native forests – J N Cameron

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Figure 17: Young unburnt 5 year old regeneration near Marysville following 2009 wildfire

For the mountain ash forests of Victoria, fire is required some time in their seed‐bearing life if they are to be perpetuated. In some areas of our conservation reserves where there has been no management seeding, unsuccessfully regenerated areas (landscape traps) have eventuated after regeneration from the 2003 Alpine Fire was subsequently killed by the 2007 Great Divide Fires.

It has been advanced that maintaining a range of age classes, through appropriate harvesting and regeneration, may assist with the population of some native plant and animal species, given the changes in floristics, nutrition, food sources and protection as a forest ages. 3.10 IMPACT OF PRESCRIBED BURNING ON FOREST ECOSYSTEMS In Victorian forests, it is difficult to prevent fire for long periods over large areas. Attempts to exclude fire result in high fuel loads, increasing the probability of large-scale and high-intensity bushfires, which are costly and dangerous to suppress, pose a great risk to life and property and result in significant loss of economic and environmental assets. Landscape-scale analysis of actual fire records (not simulation) shows that the extent of planned fire has a strong inverse relationship to the extent of bushfire. Forest and shrubland ecosystems are resilient to a wide range of fire frequency (but clearly dependent on the fire intensity).35

Controlled fire regimes can assist in the regeneration of native vegetation and promote the germination of seed, the maintenance or modification of habitats, release nutrients, cycling of nutrients required for plant growth, enhance hydrology, and manage certain weeds, pests and diseases. Fire regimes characterised by an appropriate range and diversity of fire intensities, seasonality, frequency (return intervals) and spatial heterogeneity will facilitate biodiversity and therefore promote ecosystem health and vitality, thereby providing greater resilience to climate change. Fire regimes must also accommodate requirements for bushfire risk mitigation and facilitate the provision of various values, such as water and forest products36.

Jarrah forest plant communities displayed resilience to imposed experimental fire regimes. While many species changed in abundance over time, no species were lost as a result of the fire treatments and changes in vegetation assemblages were independent of fire regime. Within the fire frequency and intensity ranges investigated, there was flexibility in the application of prescribed fire to achieve management’s fire mitigation objectives without loss of plant diversity37.

35 Conservation Commission of WA (2013). Forest management plan 2014–2023. December 2013.

36 Conservation Commission of WA (2013). Forest management plan 2014–2023. December 2013. 37 N. Burrows, B. Ward, A. Wills, M. Williams and R. Cranfield (2019). Fine-scale temporal turnover of jarrah forest understory vegetation assemblages is independent of fire regime. Fire Ecology. Ecologically sustainable management of Victorian native forests – J N Cameron

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The biota of South West Western Australia demonstrates a high degree of resilience to a range of fire interval sequences in both shrubland and open eucalypt forest. Occasional shorter intervals that may result from unplanned fires affecting recently burnt sites are therefore unlikely to have serious adverse consequences for biodiversity38. 3.11 IMPACT OF PRESCRIBED BURNING IN A WATER CATCHMENT – CASE STUDY Two fires one in 2005 and another in 20018 started in the Mundaring Reservoir catchment under very similar fire weather conditions. Prescribed burning contributed to a significant reduction in the days to suppress the fire, area burnt, and impact of the 2018 fire on stream siltation, despite 100mm of rain immediately after the 2018 fire was suppressed (Table 2).

Table 2: Comparative impact of prescribed burning on fires in the Mundaring catchment WA39

3.12 IMPACT OF PRESCRIBED BURNING VERSUS WILDFIRE ON CO2 RELEASED

Plants use sunlight to convert CO2 from the atmosphere into solid carbon compounds which are subsequently broken down and returned to the atmosphere by decay, respiration by animals that brows plants and by combustion (or burning by fire). However, the amount of carbon released by fire and the time to sequester the carbon lost, is very dependent on the intensity of the fire. The amount of CO2 released by low-intensity prescribed fire is small and the store of carbon on the forest floor that is released in the burn is rapidly replaced. By comparison intense bushfires consume all the surface fuels including large logs, tree canopies and thousands of years of accumulated organic matter in the soil. It takes at least 100 years or more to 40 sequester all the CO2 released in a forest wildfire.

Wildfires make up about 5 to 10% of global CO2 emissions each year because they release massive amounts of CO2. The Black Saturday bushfire in 2009 released about 165 million tonnes of CO2 or 379t/ha, equivalent to approximately one-third of Australia’s annual carbon emissions.41

The amount of CO2 released by low intensity prescribed burning is small and the store of carbon on the forest floor is replaced as the fine fuels burnt re-accumulate over 5-10 years. Seven prescribed burns of 82 to 637kW/m intensity, across a range of forest types in South Eastern Australia, released an average of 23t/ha 42 CO2 into the atmosphere. By contrast CO2 released by Black Saturday wildfire in 2009 was 16.5 times higher. 4. RELEVANCE OF LEGISLATIVE FRAMEWORK ON FOREST MANAGEMENT This section deals with term of reference (b) - the adequacy of the legislative framework protecting Victoria’s environment including grasslands, forests and the marine and coastal environment, and native species. This report focuses on forests. Commentary is also provided on how a clumsy legislative framework could be streamlined where it impedes organisational effectiveness.

38 R. S. Wittkuhn, L McCaw, A. J. Wills, R. Robinson, A. N. Andersen, P. Van Heurck, J. Farr, G. Liddelow, R. Cranfield (2011). Variation in fire interval sequences has minimal effects on species richness and composition in fire-prone landscapes of south-west WA. Forest Ecology and Management 261. 39 F. Batini and M. Passoti (2018). A tale of two bushfires. LANDSCOPE 39. 40 R. Underwood, D. Packham and P. Cheney (2008). Bushfires, Prescribed Burning and Global Warming. 41 AFAC and FFMG (2015). Overview of Prescribed burning in Australia. Report for National Burning Project: Sub-Project 1 42 L. Volkova and C. J. Weston (2019). Carbon loss from planned fires in south-eastern Australian dry Eucalyptus forests. Forest Ecology and Management 336. Ecologically sustainable management of Victorian native forests – J N Cameron

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Excessive and overlapping legislation and overly prescriptive legislation can be serious impediments to efficiency and effectiveness of forest management organisations and are likely to be a ’handbrake’ on improved environmental, social and economic outcomes. Poor legislation and regulation can result in the use of excessive resources on measuring and monitoring to ensure compliance, to such an extent that insufficient resources are available to direct towards improved physical outcomes in the forest where it matters.

Victorian public lands are managed through a complex framework of legislation primarily based on land tenure (Table 3). Table 3: Key Victorian legislation applicable to public land management

Land Use Category Legislation Manager National and State Parks National Parks Act 1975 Parks Victoria Regional Parks National Parks Act 1975, Crown Land Parks Parks Victoria Victoria (Reserves) Act 1978 or Forests Act 1958 Nature Conservation Reserves Crown Land (Reserves) Act 1978 Parks Victoria State Forest Forests Act 1958 DELWP water production areas Catchment and Land Protection Act, 1994., Water Authorities Water Act 1989 Softwood production Victorian Plantations Corporation Act 1993 HVP as licensee

Threatened species are managed under the national Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), or State Flora and Fauna Guarantee Act 1988 (FFG Act). 4.1 LEGISLATION OF MANAGEMENT AND HARVESTING OF VICTORIAN NATIVE FORESTS Under the Sustainable Forests (Timber) Act 2004 (the Act), the Minister for Agriculture is responsible for allocating timber in State forests to VicForests for the purposes of harvesting and selling timber. The allocation to VicForests is made through an Allocation Order, intended to provide long-term access to Victoria's timber resources. VicForests may only harvest and/or sell vested timber resources in accordance with the Allocation Order.

The Gazetted Allocation Order specifies the maximum area available for timber harvesting in any five-year period, and the conditions VicForests must comply with. The conditions include compliance with all relevant Codes of Practice, including the Code of Practice for Timber Production 2014 and the Forest Management Zoning Scheme for Victoria comprising Special Protection Zones (SPZ), Special Management Zones (SMZ) and General Management Zones (GMZ). These zones to a large extent reflect the data assessed in the Comprehensive Regional Assessments (CRAs) that informed Regional Forest Agreements (RFAs).

VicForests is subject to multiple audit processes, including the annual DELWP Forest Audit Program (FAP), regular audits for the Responsible Wood (formerly the Australian Forestry Standard) and Forest Stewardship Council (FSC) certification programs, and periodic audits by the Victorian Auditor General’s Office (VAGO). VicForests has also commissioned independent reviews of aspects of its High Conservation Value (HCV) processes, including during the 2019 Assessment. Vic Forests has implemented corrective actions since the last HCV assessment relating to design, construction and rehabilitation of waterway crossings, old-growth identification and landscape-scale vegetation management15. The legislative and regulatory framework for VicForests is complicated.

The current modernised RFAs bolster protection for Victoria’s forest biodiversity and threatened species by15:

 Reinforcing existing protections of rainforests and protect all old-growth forests from harvesting.  Providing for more timely interventions to protect threatened species (through Action Statements).

Ecologically sustainable management of Victorian native forests – J N Cameron

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 Identifying and reviewing priorities for research to fill critical knowledge gaps, including the effectiveness of protections and management actions and to improve understanding of new and emerging threats to vulnerable species.  Strengthening the checks and balances through outcome-based reporting to inform five-yearly reviews, the ability to initiate Major Event Reviews, new audit provisions for evaluation of RFA performance and identification of remedial actions

The modernised RFAs also incorporate new commitments for the State government to work together with Traditional Owners to protect Country. Additionally, they provide continued access to the timber industry for the next 10 years under the phasing out of harvesting in native forests according to the Victorian ‘Forestry Plan’. 4.2 VICTORIA’S COMPREHENSIVE, ADEQUATE AND REPRESENTATIVE RESERVES Victoria’s native forests comprise ca. 4.8 million ha of dedicated conservation areas in the form of national parks and other conservation reserves and ca. 3 million ha of State forest that is managed in accordance with Victoria’s Forest Management Zoning Scheme (FMZ Scheme).

Victorian Regional Forest Agreements describe a Comprehensive, Adequate, Representative (CAR) reserve system for public forests using nationally agreed criteria. This reserve system comprises43:

• Dedicated reserves – forest areas established by legislation specifically for conservation purposes, where timber harvesting is excluded such as National parks, State parks, flora and fauna reserves • Informal reserves – areas of State forests and other public land that are set aside for conservation through the forest management zoning scheme such as Special Protection Zones (SPZ’s), as outlined in Department of Environment, Land, Water and Planning Forest Management Plans • Values Protected by Prescription – areas of State forests and other public land that are protected from timber harvesting and other productive uses via management prescriptions outlined in the Code of Practice for Timber Production 2014.

The ca. 3 million ha of State forest managed in accordance with Victoria’s Forest Management Zoning Scheme (FMZ Scheme) includes three main management zones43:

• Special Protection Zone (SPZ) - essentially permanently excluded from for timber harvesting. • Special Management Zone (SMZ) - rarely available for timber harvesting (special circumstances). • General Management Zone (GMZ) - managed for conservation and production of forest products, as well as maintenance of social and economic values. Almost all VicForests’ operations are conducted within ca. 450,000 ha of the GMZs.

By the completion of the Regional Forest Agreement process in 2000, 3.98 million hectares were dedicated and informal reserves were established in Victoria to meet the JANIS criteria.44 Over the last 20 years to 2020 ca. 780,000 ha of additional reserves have been established increasing Victoria’s native forest now protected within dedicated and informal reserves to ca. 4.8 million ha.43

In the Eastern Forest Area only 6% of the public land or 450,000 ha is available for timber harvesting after excluding reserved forest, VicForests Reserves, exclusions under the Code of Forest Practice for Timber Production 2014, and other parts of the forest estate that are not available or suitable for harvesting43. Currently the area harvested each year is under 3,000 ha pa30 or less than 0.04%, a tiny proportion of Victoria’s public forest land.

43 VicForests (2019). Forest Management Plan V3.2. 44 Commonwealth of Australia (1997), Nationally Agreed Criteria for the Establishment of a Comprehensive, Adequate and Representative Reserve System for Forests in Australia. Ecologically sustainable management of Victorian native forests – J N Cameron

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5. EFFICIENCY & EFFECTIVENESS OF NATIVE FOREST PROGRAMS This section deals with term of reference (c) - the adequacy, efficiency and effectiveness of government programs and funding to protect and restore Victoria’s ecosystems.

Evidence is presented to show that the efficiency and effectiveness of government programs are hindered considerably by DELWP’s poor organisational structure, strategy, style of leadership, systems, shared values (culture), skill, and staffing - DELWP has 53% of staff based in the Melbourne CBD and only 11% field staff. The fight against Covid are likely to be due to similar organisational deficiencies with DHHS. 5.1 STATE OF THE FOREST REPORT 2018 The Victorian State of the Forests (SoF) report is required under the Sustainable Forests (Timber) Act 2004. The State of the Forests 201845 is the first prepared by the Commissioner for Environmental Sustainability.

The State of the Forests report identifies the need for better assessment of economic and social impacts of decisions, clarity of roles, improved allocation of funding rather than new money, waste reduction, shifting focus, skill formation, delivering real outcomes and building community understanding. My submission presents information that supports these findings.

Victoria’s sustainable forest management is monitored and evaluated against 45 indicators under seven criteria, based on the Montreal Process. This is in addition to monitoring for PEFC and FSC accreditation against other criteria. The Montreal indicators were developed under the Framework of Regional (Sub- National) Level Criteria and Indicators of Sustainable Forest Management in Australia. The four recommendations in the State of the Forests 2018 report aim to leverage improvements to deliver on the government’s ‘forestry’ legislation, including the Forests Act 1958, Sustainable Forests (Timber) Act 2004, Flora and Fauna Guarantee Act 1988, Regional Forest Agreements and National Parks Act 1975.

The State of the Forest Report 2018 recommendations were broadly be grouped into the following strategic capabilities:

 Science impact – Knowing what we need to know and when in a format useful for scientists, regulators, managers, economists and the community; responding to systemic environmental challenges and emerging global megatrends, and developing government skills in environmental-economic accounting.  Coordination and governance – Improving the clarity of roles and responsibilities, and reviewing allocation of existing funding and accountabilities to deliver priorities. New money is not always needed: improving the coordination of existing resources, effort and investments will enable better outcomes.  Delivery – Comprehensive Government policy and action plans have been developed since 2014 and focus must now shift to delivery of this policy and better investment in adaptive management.  Data, monitoring, spatial information and analytics – More investment in skills and capabilities is needed from DELWP and portfolio agencies.  Citizen science and education – Building community understanding, participation and awareness can improve policy and environmental outcomes.

The recommendations of the State of the Forest 2018 were:

 DELWP maintain the Victorian Forest Monitoring Program (VFMP) and improve statewide understanding of the impacts of forest fragmentation on forest-dependent species and improve assessment of protected areas by conducting detailed research on the benefits of various types of IUCN-protected areas for target species.  DELWP develop its spatial information capability and database, and ensure it is regularly and routinely updated, to inform decision-making across the environment portfolio.

45 Commissioner for Environmental Sustainability, Victoria (2019) State of the Forest Report 2018.

Ecologically sustainable management of Victorian native forests – J N Cameron

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 DELWP establish environmental–economic accounting capability and deliver environmental-economic accounts for Victoria by 2022, consistent with the SEEA guidelines, the DELWP Valuing and Accounting for Victoria’s Environment strategy, and aligned with the national approach. The Commissioner for Environmental Sustainability report against Victoria’s environmental-economic accounts in State of the Forests reporting from 2023.  DELWP review the current criteria and indicators for State of the Forests reporting, especially sociocultural indicators, and align reporting with relevant Victorian legislation, policy and programs and the UN Sustainable Development Goals and targets. Identification of the knowledge gaps in monitoring the social benefits of forests will be critical for managing forests for all Victorians. 5.2 POLICY SHIFT FROM PRESCRIBED BURNING TARGET TO THE RISK REDUCTION TARGET In 2015 Lisa Neville, Minister for Environment, Climate Change and Water and Jane Garrett Minister for Emergency Services, introduced a new approach to bushfire risk, ‘Safer Together’,46 The Hon Lisa Neville said:

“Our new approach is about doing more to reduce the risk of bushfire, and knowing what we do is more effective. We will involve local communities in decision making, taking into account what people value in their local area.”

Clearly people value life and property and the ‘Safer Together’ approach failed to deliver that. The message that rural communities value their properties, lively-hoods and lives was not heard or considered less important than the views of those opposed to fuel reduction, of which prescribed burning is the most cost- effective.

Reducing bushfire risk through employing a substantial area of high intensity wildfire (Figure 7) is the antithesis of mitigating fire damage and the ‘Safer Together’ approach has clearly not been more effective.

Post 2019-20 fires, the ‘Risk Reduction Target’ is still supported by Forest Fire chief Chris Hardman47 “Victoria had chosen a risk-based approach rather than a hectare-based target”. “This approach was endorsed by an expert reference panel and it was adopted because it represented a more effective approach to reducing risk for life and property than a hectare-based target,” he said. “A risk-based target focuses our efforts on burning where we achieve the most successful outcomes instead of how many hectares are burned.”

The ‘Safer Together’ approach contributed to last summer’s State of Disaster. The residual risk reduction target of 70%, is far too high and entails a level of residual risk that Worksafe would not tolerate in other workplace or public settings. The 70% target was never endorsed by the expert reference panel (the panel were advised that the residual risk target was to be decided by the government).

Replacing the VBRC 5% target with the new risk reduction target resulted in only 2% prescribed burning, well short of the 5% VBRC target, and well below the 8% target preferred by the 2009 Royal Commission (VBRC) bushfire experts. Our most eminent bushfire experts, based on a large body of research on fire behaviour, believe the new approach did more to increase the risk of bushfire in Victoria and resulted in a disastrous outcome that was predictable. Former CSIRO bushfire expert Phil Cheney condemned DELWP’s 2015 move from a hectare target for fuel reduction to what the department calls “risk reduction” targets.

“It’s a confusion of the terminology, which I believe has been used to reduce the area recommended for prescribed burning by the royal commission, after the 2009 fires,” Mr Cheney said47. “The threat of a bushfire, when it occurs, is primarily dependent on the fuel. Mr Cheney said “state government environment departments had taken too much notice of ecological scientists with very little practical experience of bushfires”.

46 Victorian State Government (2015). Safer together, A new approach to reducing the risk of bushfire in Victoria. 47 Quoted by Rachelle Baxendale Australian 3/2/20, Bushfires: hazard reduction plan ignores Black Saturday inquiry targets.

Ecologically sustainable management of Victorian native forests – J N Cameron

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5.3 VICTORIA’S POOR RECORD AT MITIGATING WILDFIRE BUSHFIRES Differences in fire losses between Victoria and South West WA, indicate differences in forest fire policy, management and practise, have a substantial impact irrespective of climate change. Below is an analysis of sixty years of actual ‘real-world’ data across both entire forested estates, not based on experimental plots, nor based on computer simulations using assumptions subject to challenge by fire behavior experts.

Both forest estates have been subjected to similar climate change, drought, and extreme fire danger and abut communities and residential areas. Fuel reduction using low intensity prescribed fire saves ecosystems and lives, as evidenced by comparing the record for ca. 2.5 million ha of the South West Forest of WA with the record for ca. 7.8 million ha of Victorian forest. Over 60 years from 1962, Victoria (DELWP) prescribed burnt only ca. 1.6% pa of the forest and wildfire losses averaged 1.9% pa and 312 lives were lost. This compares unfavourably with South West WA prescribed burning ca. 9% pa of forest and their wildfire losses averaged only ca. 0.9% pa of the forest area and only two lives were lost (Table 4).

Over the last 21 years Victoria (DELWP) prescribed burnt only ca. 1.4% pa of the forest and wildfire losses averaged 3.3% pa and 185 lives were lost. This compares unfavourably with South West WA prescribed burning ca. 6% pa of forest and their wildfire losses averaged only ca. 1.7% pa of the forest area and only two lives were lost (Table 4). The 2009 Royal Commission recommended Victoria should prescribe burn at least 5% of the forest each year and the expert panel assisting the Royal Commission indicated 8% was preferred. Table 4: Prescribed burning, wildfire and deaths in Victoria compared to South West WA48

Region Forest Wildfire Prescribed Prescribed Wildfire Wildfire Bushfire area area burn area burn prop. area burnt proportion deaths total mean mean mean mean total (mill ha) (mill ha) (000 ha pa) (% pa) (000 ha pa) (% pa) (No) a) Over 59 years 1962-2020 Victoria 7.8 8.7 128 1.6% 145 1.9% 312 South West WA 2.5 1.4 231 9.2% 23 0.9% 2 b) Over the last 21 years 2000-2020 Victoria 7.8 5.5 107 1.4% 261 3.3% 185 South West WA 2.5 0.9 150 6.0% 42 1.7% 2 Large contiguous areas burnt by wildfire are a concern for ecosystems. Over the last 20 years individual wildfires have burnt large proportions of the forest estate (Table 5). High intensity and reduced interval between intense fires or areas burnt more than once within a decade or so are also concerning. Table 5: Some Victorian Megafires and Campaign Bushfires over the last 20 years48

Year Fire/ Location Wildfire area Wildfire area Houses lost Deaths (000ha) (% of estate ) (No) (No) 2002 Big Desert 181 2.3 2003 Victorian Alps 1,300 16.7 41 2005-06 Central Vic & Gippsland 184 2.4 57 4 2006-07 Great Divide 1,250 16.0 51 1 2009 Black Saturday 450 5.8 2,000 173 2013 Aberfeldy, Harrietville & 123 1.6 32 2 2014 East Gippsland - Snowy River 166 2.1 2018-19 Bunyip, Licola, Dargo 219 2.8 29 2019-20 East Gippsland & NE 1,600 20.5 396 5 Total 5,473 70.2 2,606 185

48 Derived from DELWP and DBCA reports, Bushfire Front Data and Cameron Consulting data. Includes the tragic deaths of two firefighters, Katie Peters and Steven Kadar killed on 13 February 2013, at the Harriet Fire when a tree fell on the fireground. Ecologically sustainable management of Victorian native forests – J N Cameron

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The increase in area burnt by wildfire including megafires is associated with the introduction of mega government Departments. (Table 6). Over the last couple of decades, mega departments have been created with too many unrelated functions combined into one large department headed by a Secretary unlikely to have a deep understanding of all functions and who reports to four Ministers defusing accountabily. Table 6: Increasing wildfire area coincides with move to mega government departments

Year Abrev. Organisation and responsibilities Area burnt (000ha/yr) 1951-83 FCV Forests Commission of Victoria 119 Forestry, Parks, Flora & Fauna, 1983-90 CFL Department of Conservation, Forests and Lands 55 Forests, Parks, Public land, Fisheries, Wildlife, Flora & Fauna 1990-92 DCE Dept. Conservation and Environment 35 Forests, Parks, Public land, Fisheries, Wildlife, Flora & Fauna 1992-96 CNR Dept. Conservation and Natural Resources 8 Forests, Catchments, Land, Parks, Flora & Fauna, minerals & petroleum, primary industries, water 1996-2002 DNRE Dept. Natural Resources & Environment 33 Forests, Catchments, Land, Parks, Flora & Fauna, minerals & petroleum, primary industries, water 2002-12 DSE Department of Sustainability and Environment 314 Forests, Heritage, Environment, Land, Water, Planning, Fauna & Flora, Conservation. 2012-14 DEPI Dept. Environment & Primary Industries 260 Agriculture, Forests, Land, Fire, Environment, Water, Natural resources, Regions, Desalination 2015--> DELWP Dept. Environment, Land Water & Planning 294 Environment, Climate change, Water, Catchments, Local government, Forests, Land, Fire, Environment, Infrastructure, Planning, Regions, Energy Under DELWP for example, the functions are headed by seven Assistant Secretaries who report to one Departmental Secretary who then reports to four Ministers two of which head two Ministries:

 Minister for Water, also the Coordinating Minister for the department and the Minister for Police and Emergency Services.  Minister for Energy, Environment and Climate Change, Minister for Solar Homes.  Minister for Planning.  Minister for Local Government.

These mega Government Departments are the public service equivalent of Conglomerates that industry moved away from years ago, because of their inability to deliver on the three core generic strategies of all organisations – focus, low cost or differentiation. DELWP has been unable to:

 Focus on effective management of forests fire, ecosystems or biodiversity. A focused forest and fire management organisation could have substantially reduced the area of the 2019-20 fire.30  Achieve ‘low cost’ prescribed burning costs and fire suppression costs.  Differentiate into a ‘best in class’ forest and fire manager. Management of Covid quarantine, testing and tracing, can probably be attributed to the mega Department of Health and Human Services. 5.4 DELWP’S UNFAVOURABLE PERFORMANCE AGAINST OPERATING TARGETS The Department of Environment, Land Water and Planning (DELWP) has not achieved the VBRC recommendations, nor its own targets, nor best practise fuel reduction. Over the last decade DELWP has only achieved fuel reduction on average of 152,000 ha pa (2%) against a VBRC target of 390,000 ha pa (5%). DELWP also has not met its 2018-19 objectives for retirement of powerlines in high bushfire risk areas, removal of safety risks posed by dangerous roadside trees, nor met its forest fire management cost target.

Ecologically sustainable management of Victorian native forests – J N Cameron

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DELWP failed to meet several key performance measures in 2018-1949:

 Fuel reduction was only 130,000 ha against the VBRC target of 390,000 pa. The bushfire risk rating of 67% against a target of 70% has little merit as it includes large areas burnt by past wildfire, the antithesis of bushfire mitigation. Replacing the VBRC target with the ‘risk-reduction target’ in 2015, most likely contributed to the 2019-20 mega fire.  Retirement of powerlines in high fire risk areas was not achieved - 693 km against a target of 770 km.  Management of dangerous trees on roadsides was not achieved - only 1,000 km against its target of 1,500 km. One fire fighter was killed in 2019-20 and two firefighters in 2013 by dangerous trees.  Fire management costs were $568 million or 42% above a target of $401 million. 5.5 FAVOURABLE OPERATING STRUCTURE AND PERFORMANCE OF VICFORESTS VicForests is a more focused organisation with fewer layers of management and has a record of operating efficiently and effectively in the management of the ca. 450,000 ha of its operating area. Vicforests trades profitably, makes a reasonable return on equity (Figure 18), operates with little no or debt and meets PEFC accreditation for its environmental performance.

Figure 18: Vicforests Normalised Profit before tax and Cashflow Return on Equity50

6 IMPROVING MANAGEMENT OF NATIVE FOREST ECOSYSTEMS This section deals with term of reference (d) - legislative, policy, program, governance and funding solutions to facilitate ecosystem and species protection, restoration and recovery in Victoria, in the context of climate change impacts.

Solutions to facilitate ecosystem and species protection do not necessarily require increased funding nor increased reservation, but require restructure and organisational change for DELWP to deliver improved management of the 94% of public forest land under its charter. Management of the remaining 6% of public forest by VicForests appears to be efficient and effective for ecosystems, timber and other multiple uses. 6.1 DELIVERING IMPROVED MANAGEMENT OF FORESTS & MITIGATING DAMAGE Delivering improved management of the forests ecosystems requires greater focus on mitigating damage:

 Reduce damage from wildfire through increased prescribed burning (the most cost effective fuel reduction available), improved road and firebreak maintenance/preparation, strategic clearing of dangerous vegetation around communities, earlier fire detection, rapid initial attack and mounting

49 DELWP Annual Reports 50 Derived from VicForests Annual Reports. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 39

suppression with sufficient force to reduce the frequency, severity and size of Victorian bushfires. Light planes with heat sensing, initial attack capability and surveillance capability can deliver earlier fire detection and initial attack.  Reduce damage from pest plants and animals and other causes (Figure 10 above). 6.2 ISSUES WITH THE ORGANISATION OF FOREST/ECOSYSTEM MANAGEMENT Policy issues with the management of forests/forest ecosystems in Victoria have contributed to a level of implementation of programs considered to be below ‘best practise’. Some of the policy issues are:

 A shift from proactive landscape scale fire prevention to reactive emergency management and localised property protection, has increased the risk of large high intensity wildfires considered to be the major threat to forest ecosystems in the State.  Forest policy has regressed from balanced multiple with conservation, to pursuit of single uses. Some policies are incompatible with saving the forest from mega fires, such as restricting prescribed burning and reducing timber harvesting, both of which increase spatial and temporal diversity and enhance biodiversity.  This has been based on a flawed appreciation of the favourable impacts of multiple use including timber production, importance of low intensity prescribed fire versus high intensity wildfire, or the mistaken belief that wildfires can be excluded without fuel reduction.  Some ‘protectionist’ or ‘lock up’ policies have delivered a wildfire outcome far worse than the ‘multiple use’ forest policies of the 1970-80’s, restricting maintenance of access roads and firebreaks, limiting effective use of fuel reduction, and constraints on ground attack.  The policy to substantially reduce, and from 2030, eliminate native harvesting will reduce the amount of young regeneration which is shown to not burn in wildfires and provide valuable refuge in wildfires. Misguided attempts to save every tree and animal has contributed to the destruction by wildfire of forests, and diminished populations of threatened and endangered species.  Victorian forest policies have failed to protect the forests, their ecosystems, and people’s lives from preventable mega bushfires, because the policies were inappropriate.  Forest policy decisions appear to have been based on political expediency such as the 2015 decision to replace the 5% prescribed burning target with a the ‘risk-reduction target’, against specific recommendations of a Royal Commission and expert advice. The 2015 review of prescribed burning should have been undertaken by people with skills on forest land management, not emergency management (The review was conducted under the provisions of the Emergency Management Act 2013 (Part 7) by the Inspector-General for Emergency Management).

These Victorian policies issues have contributed to poor implementation, particularly with respect to multiple use and mitigation of wildfire our most dangerous threat to forest ecosystems and other threats that can be mitigated (Figure 10 above). Examples include:

 Fire suppression costs in Victoria are far higher than they need to be because of the absence of ‘best practise’ management of forests including for bushfire mitigation.  Past policies have been poorly or only partly implemented – The Victorian Bushfire Royal Commission (VBRC) 5% prescribed burn target and DELWP’s own fuel reduction targets were not achieved despite generous increases in expenditure.  DELWP prescribed burning is well below best practise in terms of strategic location, extent, effectiveness, cost and economic impact  DELWP fire management costs have gone up over threefold over 20 years. Over 20 years, ‘excess’ expenditure on suppression of mega/campaign fires has been ca. $1,600 million, while expenditure on prescribed burning has been about $400 million or $20 million pa.  The East Gippsland wildfire could have been suppressed before the 8th of December, well before it became a megafire. There was a window between the 22nd of November and 8th of December 2019 Ecologically sustainable management of Victorian native forests – J N Cameron

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when the forest Fire Danger Index remained below 20 to 30, and sufficiently low to allow suppression, with prudent fuel reduction, adequate fire access, early detection and rapid initial attack with sufficient force.  Incident Management located remote from the fire, restricted preparation of containment lines and back-burning prior to 8th of December and this hindered suppression of the fire when conditions were conducive to effective suppression51.  Inability to make any demonstrated improvement in substantial reduction in pest plants and animals – appear to just be delivering mediocre containment.  Repeated delivery of disastrous outcomes suggests that there are some systemic issues associated with the organisation of DELWP. 6.2 RESTRUCTURE TO DELIVER BETTER FOCUS ON FOREST & ECOSYSTEM OUTCOMES A study of the last twenty years of annual reports of DELWP suggests there are issues with the structure, strategy, systems and staffing and the fire outcomes suggests serious issues with skill formation and possibly the style of leadership and culture. Some DELWP annual reports pay more attention to reducing the environmental ‘footprint’ of office activities, than the organisations impact on core outcomes in the forest land and forest ecosystems DELWP is supposed to be managing.

A restructure of DELWP is required to deliver better management of Victoria’s forest ecosystems:

 Legislate to demerge the Super Department DELWP and create a separate department ‘Forest and Fire Management Victoria’ responsible for management of State Forests, and fire mitigation on all forested public land including Parks and Reserves. Mega Departments DELWP and DHHS have overseen two disasters in six months, not surprising as business demerge conglomerates because they lacked focus, fail to capture synergies and perform poorly.  The new Department should report to only one Cabinet Minister for Forest and Fire Management solely responsible the new Department and charged with the objective of improving proactive management to prevent and substantially minimising the need for costly reactive disaster management.  Base most of the new ‘Forest and Fire Management Victoria’ staff in the regions and Timber Towns, close to the forests under management. Currently only 11% of DELWP employees are field staff and 53% of DELWP employees are based in the Melbourne CBD. There should be no more than the CEO and a small support team based in the CBD, with most people based in the regions with a stronger field component.  The new ‘Forest and Fire Management Victoria’ should be led by people capable of refocusing on the core business and improving real outcomes in the forest.  Streamline the organisational structure of the new ‘Forest and Fire Management Victoria’ with no more than about five layers from CEO to frontline employees, and with clearly defined roles and objectives heavily focused on actions to reduce mega fires and enhance biodiversity without reducing the area currently available for multiple use. Roles or layers of management that do not add sufficient value should be replaced with field workers on prescribed burning, road and firebreak maintenance, and ecosystem work to reducing major threats.  Ensure that the remuneration of all employees is aligned with real improvements in the field. A built- in overtime allowance may deliver earlier fire suppression, than paid overtime based on hours worked, which provides an undesirable financial incentive to contain rather than suppress fires.

51 G. Squires (2020). Submission to Inspector General for Emergency Management Inquiry into the 2019/20 Victorian Fire season. Ecologically sustainable management of Victorian native forests – J N Cameron

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7 OPPORTUNITIES TO INCREASE NATIVE FOREST ESD OUTCOMES This section deals with term of reference (e) - opportunities to restore Victoria’s environment while upholding First Peoples’ connection to country and increasing and diversifying employment opportunities in Victoria. This section focuses on socioeconomic outcomes including Gross Regional Product and employment.

Delivering improved management of existing reserved forest can avert ecosystem decline without locking up more forest, thereby continuing regional employment opportunities in forest management and wood processing industries (Table 7) such as Ash sawmill/Further Manufacturing at Heyfield and Opal Pulp and Paper mill at Maryvale near Morwell. Mills are already constrained by diminishing log supply. Table 7: Initial manufacturing, further manufacturing and end-products from native forest logs

Logs Initial Manufacturing Further Manufacturing End Products High grade sawlogs Appearance sawntimber Joinery Manufacture Doors & Fittings Stairs & Flooring High grade sawlogs Appearance sawntimber Furniture making Tables & Chairs Kitchens & Cupboards Sawlogs Structural sawntimber Drying, Planing & Dressing Houses Prefabricated Trusses Buildings Prefabricated Frames Renovations Sawlogs Structural sawntimber Engineered wood products Laminated beams Edge glued panels Low grade sawlogs Packaging sawntimber Fabricated Packaging Pallets, Crates, Boxes Pulplogs Pulp White papers Printing & Copy paper Packaging Papers Paper Boards & Bags Cardboard boxes Tissue papers Hygene products 7.1 VICTORIAN ‘FORESTRY PLAN’ The Victorian Government has developed the Victorian ‘Forestry Plan’ to exit native forest logging by 2030. The Victorian Forestry Plan is bad and the timing of the exit from native forest log supply is unfavourable and socioeconomically unjust:

 The Victorian ‘Forestry Plan’ will be extremely damaging to the forest/plantation based industries and agriculture displaced if there is investment in new planting – investment in new planting has ceased because of high land cost and because returns on new planting are insufficient to meet hurdle rates of return required by current plantation owners (institutional investors) and new entrants are scarce.  The ‘Forestry Plan’ is unlikely to deliver better management of the native forests removed from wood production – the main issue is better management of existing reserved conservation areas, not increasing the area under reservation.  Sawmilling businesses invested in value adding and remanufacture under the Timber Industry Strategy a couple of decades ago and that investment is about to become almost worthless.  The declining availability of native timber due to bushfires could have been substantially averted if prudent fire mitigation was employed as recommended by many Bushfire Commissions/Enquiries. This would have averted declining availability from ‘post-wildfire’ resource appraisals.  Loss of access as a result of increased reservation/protections has not been subject to rigorous assessment against all three pillars of ecologically sustainable development and has resulted in considerable adverse socioeconomic impacts.  Area and sustainable supply from hardwood plantations has declined considerably and for most solid wood products plantation timber is no substitute for timber harvested from native forests.

Ecologically sustainable management of Victorian native forests – J N Cameron

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The government claims for the ‘Forestry Plan’ abatement of 1.71 million tonnes of carbon dioxide-equivalent each year. By contrast the 450,000 m3 pa of native sawlogs currently supplied and converted into sawntimber will archive (sequester) ca. 183 million t pa of carbon dioxide-equivalent each year.

The ‘Plan’ has $120 million to provide the ‘certainty’ and ‘support’ workers, businesses and communities need. The only certainty is that the token amount is a small fraction of the economic loss that will be incurred and will be insufficient to ‘support’ the workers, businesses and communities who will suffer considerably.

The $120 million is for re-training programs, case management, employment assistance, back-to-work program, redundancy top-ups, business and job creation grants, community projects, funding for local infrastructure, assistance to retool to plantation timber and financial compensation. Insufficient assistance will hit the wallets of redundant workers, contractors and small business owners. There is virtually no unallocated plantation timber and the $120 million is probably insufficient to retool one large mill

VicForests will meet existing contractual obligations and negotiate new sawlog supply contracts for all mills to mid-2024. From mid-2024 to 2030 a competitive process will be used for timber allocation, with commercial native timber logging in state forests phased out by 2030. Currently sawlogs are competitively auctioned.

Australian Paper will be supported to transition to a full plantation-based supply, ensuring it operates until at least 2050 – supporting its almost 1,000-strong workforce and providing stability to its customers.

Funding of up to $25,000 per business is available to engage appropriate professional services to undertake a Business Diagnostic and or develop a Business Transition Plan.

To protect the future of the Greater Glider, Leadbeater’s Possum and more than 35 other threatened species, a further 96,000 hectares of forest across Victoria will be made exempt from logging in IPA’s at Strathbogie Ranges, Central Highlands, Mirboo North and East Gippsland (Figure 19). Figure 19: Location of 96,000 ha of Immediate Protection Areas (IPAs) under ‘Forestry Plan’52

52 Source: DELWP Aug 2020 webpage Timber harvesting and threatened species management Ecologically sustainable management of Victorian native forests – J N Cameron

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7.2 PAST REDUCTIONS IN VICTORIAN NATIVE FOREST TIMBER Since 2000 supply of logs from Victorian native forests has declined by ca. 1.6 million m3 to ca. 0.9 million m3 with the decline split roughly evenly between sawlogs and other logs principally pulplogs (Figure 20). Log supply in 2019-20 was impacted slightly by precluded access to areas burnt in the 2019-20 wildfire. Figure 20: Decline in Victorian native forest log supply over the last 24 years53

7.3 SOCIOECONOMIC IMPACT OF PAST REDUCTIONS IN NATIVE FOREST LOG SUPPLY In 2016-17 Victorian native forests produced 1,341,000 m3 of logs, generating Gross Regional Product of $644 million, 1,639 direct jobs in forestry, 2,819 type 1 jobs including manufacturing the logs into products and 4,792 type 2 jobs when consumption jobs induced by the forestry and manufacturing activity are included (Table 8). Gross Regional Product and employment per cubic metre have remained fairly similar over the last 20 years, given difficulty implementing productivity improvements under shrinking supply. Table 8: Victoria’s native forest log supply and Gross Regional Product and Jobs in 2016-1754

Socioeconomic Parameter Multiplier Total Volume Per m3 a) Gross Regional Product Units (No) ($M) (000m3) ($/m3) Gross Regional Product 644 1,341 480 b) Employment on Full Time Equivalent FTE basis Units (No) (No) (000m3) (No/m3) Direct Jobs 1.0 1,639 1,341 1.22 Type 1 - Direct + production induced Jobs 1.7 2,819 1,341 2.10 Type 2 - Direct + production & consumption induced jobs 2.9 4,792 1,341 3.57 The decline in native forest log supply over the last 20 years has resulted in an annual reduction in Victorian Gross Regional Product of $747 million pa and reduction in Victorian employment of ca. 3,270 jobs (Type 1 - Direct Employment + production induced) and ca. 5,559 jobs (Type 2 - Direct Employment + production induced + consumption induced) on a full time equivalent (FTE) basis (Figure 21). The cumulative loss of Victorian Gross Regional Product is conservatively estimated at $6.6 billion over 20 years.

53 Derived from ABARES (2018) Australian State of the Forests Report, Vicforests Annual Reports and Cameron Consulting data. 54 Derived from J. Schirmer, M. Mylek, A. Magnusson, B. Yabsley1 and J. Morison (2018). Socio-economic impacts of the forest industry in Victoria (excluding. the Green Triangle), Report for Forest and Wood Products Australia and Cameron Consulting log data. Ecologically sustainable management of Victorian native forests – J N Cameron

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Figure 21: Impact of reduced native forest log supply on Gross Regional Product & Employment55

Gross Regional Product (GRP) is the equivalent of Gross Domestic Product (GDP) and quantifies the value added by industry to the regional economy, of Victoria in this case. Only the value added component of the revenue of the sectors is counted. Results (Figure 21) are modelled on volume supplied from the Victorian native forests. Economic impacts were larger when modelled on area harvested rather than volume.

The native forest based industries are significantly more employment intensive than plantation counterparts. This employment intensity is imposed by greater regulation of native forest management and reductions in log supply that have negated efforts to introduce capital intensity in log/timber processing.

Investing in mill upgrades with improved technology and productivity, normally requires an increase in volume to capture scale economies. The only scale economies available have been through past industry rationalisation under the Timber Industry Strategy about 20 years ago. In recent times the industry has faced the prospect of diseconomies of scale due to shrinking supply of native hardwood and plantation hardwood and plantation softwood in Victoria. Mills such as Ash’s large sawmill and remanufacturing facility at Heyfield and Opal’s large pulp and paper mill at Maryvale (Figure 22) will continue to be constrained by declining log supply, exacerbated by the ‘Forestry Plan’. Figure 22: Ash sawmill at Heyfield and Opal (Australian Paper) pulp and paper mill at Maryvale56

55 Derived from Deloitte Access Economics (2015). Economic assessment of the native timber industry in the Central Highlands RFA Area. Report 1 for VicForests, J. Schirmer, M. Mylek, A. Magnusson, B. Yabsley1 and J. Morison (2018). Socio-economic impacts of the forest industry Victoria (excludes the Green Triangle), Report for Forest and Wood Products Australia and volumes from VicForests Annual Reports and Cameron Consulting data. 56 Source: Timberbiz. Ecologically sustainable management of Victorian native forests – J N Cameron

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7.4 PROJECTED DECLINE IN NATIVE HARDWOOD SUPLY – VICTORIAN ‘FOREST PLAN’ Victoria’s native forest log supply is forecast to decline from about 1 million m3 pa to nothing in 2031 with the sawlog percentage dropping from about 44% in 2021-25 to 37% in 2025-26 and the non-sawlog or pulplog component declining by about 120,000 m3 pa in 2025-26 (Figure 23). Figure 23: Projected decline in Victorian native forest log supply over the next decade57

7.5 SOCIOECONOMIC IMPACT OF VICTORIAN ‘FOREST PLAN’ The Victorian ‘Forestry Plan’ is expected to contribute to a further loss ca. $492 million pa in Gross Regional and the loss of another 3,660 jobs over the next twenty years (Figure 24). The cumulative projected loss of Victorian Gross Regional Product is conservatively estimated at $5.6 billion over 20 years. Figure 24: Projected ‘Forest Plan’ native forest log supply, Gross Regional Product & Jobs

57 Derived from Victorian Environmental Assessment Council - VEAC (2017). Fibre and wood supply assessment report. Ecologically sustainable management of Victorian native forests – J N Cameron

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8 PLANTATIONS ARE NO SUBSTITUTE FOR NATIVE FOREST SUPPLY This section deals with term of reference (f) - the ability of plantations to substitute for native forest timber.

It is demonstrated that plantation hardwood supply is no substitute for timber harvested from native forests. In Victorian and particularly Gippsland, plantation area and future Hardwood and Softwood plantation supply are declining. Efforts to increase hardwood plantations in particular, are seriously constrained by availability of suitable land within economic haul distance of mills, the high cost of farmland, returns and long lead time are insufficient to attract investment, limitation on available land due to planning restrictions, potential adverse impact on water yield in some catchments and adverse impact on the critical scale of agriculture.

Pushing the timber industry into supply from new plantations on farmland creates diseconomies of scale in the agricultural sector, and as we saw with the plantation expansion under the MIS schemes, pushes up land prices, further constraining expansion and scale economies of both agricultural and plantation enterprises. 8.1 DECLINING GIPPSLAND PLANTATION ESTATE Central Gippsland has been the source of most plantation hardwood supplied to domestic mills with most of the other Victorian plantations being beyond economic haul distance of mills and thus have supplied export markets, mostly as wood chips.

Since 2009, plantation area in the Central Gippsland National Plantation Inventory (NPI) Region has declined by about 12,000 ha with most of the reduction in Eucalypt plantation (Figure 25). The loss of area is likely to result in a reduction in sustainable supply of plantation hardwood of 180,000 to 240,000 m3/yr for the next 20 years, assuming a growth rate of 15 to 20 m3/ha/yr, depending on sites replanted to Eucalypt. The Central Gippsland NPI region is primarily the only NPI region within economic haul distance of most existing mills, particularly the large scale mills. Figure 25: Decline in the plantation estate in Central Gippsland NPI Region58

8.2 VICTORIAN PLANTATION HARDWOOD LOG SUPPLY HAS PEAKED AND WILL DECLINE The national hardwood plantation estate shrunk by 45,000 ha in the five years to 2015 and the trend is expected to continue.

Victorian hardwood log supply has peaked and is expected to decline in line with virtually no new planting and the conversion of thousands of hectares of Eucalypt plantations to softwood plantations (e.g. Gippsland) or farming (e.g. Green Triangle).

58 Derived from ABARES 2018 Australian State of the Forests Report and Cameron Consulting data. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 47

Most of the hardwood production has been chip export, with only about 300,000 m3 pa of pulplogs supplied to domestic mills, because most of the plantations are beyond economic haul of Maryvale pulp mill. Local sawmills have essentially ceased sawing plantation sawlogs because it has been unprofitable and supply of sawlogs to export markets has been small and sporadic (Figure 26). Figure 26: Victorian plantation hardwood log supply has peaked and will decline59

8.3 VICTORIAN SOFTWOOD SUPPLY HAS PLATEAUED AND MAY DECLINE Victorian softwood supply has plateaued and is likely to decline in the foreseeable future because of no new planting, impact of bushfires in 2009 and 2014 and the loss of ca. 10,000 ha burnt in the 2019-20 East Gippsland/North East bushfire (Figure 27). Figure 27: Victorian plantation softwood log supply has peaked and will decline

The Carter Holt sawmill at Morwell with a log input of about 350,000 m3 closured in 2017 due to a shortage of pine logs. This was blamed on bushfire losses in 2009 and 2014 which reduced HVP’s plantations by 15%. This caused the loss of 160 direct jobs and 496 jobs including production and consumption induced employment resulting from the mills operation. The closure occurred in the same year another 700 direct jobs or ca. 2,000 jobs (type 2) were lost with the closure of the neighbouring Hazelwood power station.

59 Derived from ABARE (2018) Australian State of the Forest Report and Cameron Consulting data. Ecologically sustainable management of Victorian native forests – J N Cameron

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The 2019-20 bushfires burnt 102,000 ha or 13% of the plantations in Victoria and across the border in Southern NSW (Table 9). This will cause a reduction in log supply over the next couple of decades of ca. 200,000 million m3 pa in Victoria and ca. c. 2 million m3 pa across both states. There will be no scope to make up the reduced Victorian supply by sourcing long haul logs from NSW because of that states ca. 1.8 million m3 pa fire loss. It comes as no surprise that WA incurred one of the lowest fire losses. That state employs world best practise fuel reduction in its native forest, which were the initial source of fire or point of entry of fire to the burnt plantations in the Eastern States. Table 9: Plantation area burnt in the 2019‒20 bushfires

State/Territory Burnt area Unburnt area Plantation Proportion area burnt (’000 ha) (’000 ha) (’000 ha) (%) Vic 9.8 408.7 418.5 2.3 NSW 92.1 301.1 393.2 23.4 SA 17.0 149.8 166.8 10.2 QLD 4.3 226.2 230.5 1.9 WA 4.4 355.5 359.9 1.2 Tas 2.5 307.2 309.7 0.8 NT 0.0 47.4 47.4 0.0 ACT 0.02 7.4 7.4 0.2 Total 130.1 1,803.3 1,933.4 6.7 8.4 PLANTATION PULPLOGS ARE NOT A PERFECT SUBSTITUTE FOR NATIVE PULPLOGS Most of the existing plantations in Victoria are generally suitable for pulping although wood, pulp and paper quality varies considerably with species, age and site, such that some species harvested before 20 years of age are inferior to Ash pulpwood currently supplied from Victoria’s native forests.

The new plantations required to substitute for native forest pulplogs will be unlikely to fill any supply shortfall before 2040 because:

 Rotations of about 20 years are required to reasonably match the pulp and paper properties of logs currently supplied from native forest – and thus achieve reasonable substitutability.  Twenty year rotations are required because one rotation of twenty years incurs considerably less cost and site disturbance than two rotations of ten years.  The Internal Rate of Return is higher for rotations closer to 20 years than 10 years for typical sites, growth characteristics and plantation cost structures. 8.5 PLANTATION SAWLOGS ARE NOT SUBSTITUTABLE FOR NATIVE FOREST SAWLOGS Virtually all the existing hardwood plantations in Victoria are unsuitable for sawntimber. This is because log size, defects, recoveries, density, durability, drying properties and stress profile of hardwood plantation logs from un-thinned and unpruned plantations are significantly poorer than logs currently harvested from native forests60.

Existing hardwood plantations have been established primarily to produce pulpwood and have not received the early pruning and thinning necessary to produce high quality sawlogs. The limited sawlogs that have been supplied from existing plantations contained more defects than sawlogs from native forest. When processed, the resulting sawntimber was generally unsuitable for appearance grade products and some structural sawntimber products. The smaller diameter and more defects including tension wood make plantation

60 J. Cameron and R. Meynink (2008). Feasibility of timber currently harvested from Melbourne’s water catchments. Phase 1 – Resource and Timber Properties. Report to Department of Sustainability and Environment. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 49 hardwood sawlogs difficult to saw and dry60. Local sawmills substantially reduced sawing plantation sawlogs in about 2010 when the old >30year old E. regnans plantations were liquidated (see Figure 26 above). 8.6 SPECIAL LONG-ROTATION PLANTATIONS ARE REQUIRED TO PRODUCE SAWLOGS To produce acceptable grade sawntimber from new plantations will require planting select species on high quality sites at high initial stockings, followed by pruning and non-commercially thinning to 150-250 sph at a young age (called a ‘direct sawlog’ regime) and then growing for 25-35 years to produce logs suitable for processing. Investment in large new sawmills (or reconfigured mills) will be required, including new technology to manage the different quality of plantation logs. These mills will require access to appearance, structural and industrial grade sawntimber markets. New direct sawlog plantations if located on good sites may then have the potential to produce some appearance-grade sawntimber preferably to supplement rather than replace Ash sawlogs from native forest. These new plantations are only likely to be economically feasible when the above is combined with appropriate incentives to reduce the impediments of high land cost, long lead time to returns and a return on investment insufficient to attract investors currently.60

A number of challenges need to be overcome for plantation sawlogs to substitute for sawlogs harvested from native forest beyond 204060:

 Plantation grown sawlogs, even grown under a ‘direct sawlog’ regime, are unlikely to be suitable for production of high appearance grade Ash sawntimber using quarter sawing under current mill configuration.  Investment in large new sawmills (or reconfigured mills) will be required, including new technology to manage the different grades or quality of plantation logs. These mills will require access to appearance, structural and industrial grade sawntimber markets.  Future sawmills for logs grown in ‘direct sawlog’ plantations will need to be large to capture essential economies of scale. Such mills will only be feasible with inputs of ca. 200,000m3 pa of sawlogs.  The area of new direct sawlog hardwood plantations for such mills will need to be far greater than simply that area needed to only produce the sawlog volumes required to substitute for the ‘native’ sawlogs, because a reasonable proportion of the logs will only be suitable for pulping. Assuming a 200,000m3 pa sawmill, growth rate of 20m3/ha/yr and a sawlog outturn of 50%, means a plantation estate of at least 20,000 ha would be required, plus a bit more to allow for fire losses.  Justifying investment in new plantation-based sawmills will require large areas of new plantations to have reached sufficient age to ensure a sustainable supply of sawlogs with low risks in terms of log quantity, log quality and deliver log price. These mean a large area of high quality land within ca. 100 km of the new large and high-tech sawmill with a market for pulplogs nearby.  Attracting the capital for such plantations will be challenging. Procuring sufficient land will require investors to overcome existing impediments to economic returns, including high land cost, community concerns, planning restrictions and possibly future demand for water in ‘plantation catchments’.

8.7 FINDING HIGH QUALITY LAND FOR NEW PLANTATIONS IS PROBLEMATIC The new direct sawlog plantations need to be established on good sites conducive to the production of quality timber with minimum degrade. This means relatively deep soils with moderate to high rainfall to produce quality timber with minimal degrade. Marginal sites have proved unacceptable even with special silviculture. Special silviculture includes planting at relatively high initial stocking and early non-commercially thinning and pruning

Gippsland has 1.23 million ha of cleared farmland. However, land price is prohibitive in Bass Coast, Yarra Ranges, Cardinia, Casey, Baw Baw and Mornington Peninsula LGA’s due to proximity to Melbourne’s urban growth. Also most of Gippsland’s dairy country is over-priced (overcapitalised) for plantations and most of the sheep and cropping country is too dry for commercial eucalypt plantations. For example, minimum

Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 50 rainfall constraints are > 800-900 mm pa for E. globulus and >1 000 mm pa for E. nitens to ensure growth rates above ca. 16-20 m3/ha/yr sufficient to meet modest return (IRR) hurdles.

A comprehensive study61 of availability of land in Gippsland suitable for plantations found only ca. 105,000 ha suitable for Eucalypt plantations after eliminating land that was too expensive, too poor, too steep or with unacceptable surface or groundwater stress. Only 28% of the 105,000 ha or ca. 30,000 ha was expected to deliver a growth rate above 20m3/ha/yr.

Ramping up supply of plantation grown sawlogs presents numerous challenges including declining (rather than increasing) plantation supply from existing plantations, very high land cost, large investment requirements, insufficient returns, higher risk than other investment asset classes and a raft of other impediments to plantation development. Impediments to new planting include the high cost of farmland, inability to reduce overcapitalisation by subdividing off the ‘house block’, restricted availability of land suitable for eucalypts, competition from other land uses and regulation. Regulatory impediments are planning restrictions (planting permit), native vegetation clearing guidelines that prevent the removal of a few scattered trees and road construction restrictions. Market impediments include lack of markets for environmental services and capital gains tax and stamp duty impediments to secondary markets for established plantations. 8.8 FARMLAND FOR PLANTATIONS IN VICTORIA PARTICULARLY NEAR MILLS IS EXPENSIVE Managed Investment Schemes (MIS) drove up land prices until the global financial crisis collapse of MIS which lead to soft land prices in Victorian ‘plantation regions’ until about 2016, when prices increased sharply again particularly close to Melbourne.

Cessation of land purchase for MIS contributed to a sharp fall in land prices in the South West but not Gippsland where high land price remains an impediment to new planting. Over 2001-2017 Victorian land prices have increased 6.7% pa ‘nominal’ (or 4.2% ‘real’). ‘Nominal’ increase ranged from 4.5% pa in Central to 8.9% pa in Gippsland (‘real’ increase ca. 2.1% pa to 6.4% pa respectively) (Figure 28). Gippsland is the epicentre all the pulping and most of the sawmilling. Figure 28: Increase in transacted prices of Victorian farmland over 2001 to 201762

61 J. Cameron and R. Meynink (2008). Feasibility of timber currently harvested from Melbourne’s water catchments. Phase 2 – Markets, supply, land and water. MBAC Report to Department of Sustainability and Environment. 62 Cameron Consulting data derived from analysis of thousands of transacted land prices from Valuer-General (2001-2017), A guide to Property Values. Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 51

9. ADVERSE IMPACT OF USING OTHER BUILDING MATERIALS This section also deals with term of reference (f) - the need to substitute the building materials with much poorer ecological sustainability for the timber harvested from Victoria’s native forests.

Native forest sawntimber harvested from sustainably managed native forests is one of the most sustainable building materials known to mankind. 9.2 ECOLOGICAL SUSTAINABILITY OF SAWNTIMBER Timber is a renewable raw material that is recyclable and whose manufacture into sawntimber consumes less energy and contributes less to air emissions than alternative building materials (Table 10). Table 10: Ecological sustainability of building materials (energy & emissions are in manufacture) 63

Material Renewable Recyclable Bio-degradable Energy used Air emissions (kWh/t) (kg/t) Sawntimber Yes Increasing Yes 1,600 ca. 0 Concrete No Increasing No 2,100 12 Steel No 50% No 7,400 45 Plastic No 50% No 28,000 Aluminium from ore 91,000 9.3 GREENHOUSE FRIENDLY ATTRIBUTES OF SAWNTIMBER AS A BUILDING MATERIAL Converting trees into sawntimber is greenhouse friendly. Production of sawntimber use less fossil fuel energy, releases less carbon in manufacture and stores more carbon in use. Carbon stored in mild steel could be about 30kg/m3 assuming 0.4% carbon by weight and basic density of mild steel of 7,860kg/m3 but this is still only about one eighth of the carbon stored in sawntimber (Table 11). Table 11: Greenhouse friendly attributes of Sawntimber as a building materials64

Material Energy in production Carbon released Carbon stored (MJ/m3) (kg/m3) (kg/m3) Sawntimber 750 15 250 Concrete 4,800 120 0 Steel 266,000 5,320 ca. 30 Aluminium 1,100,000 22,000 0 9.4 TIMBER HOUSE WALLS HAVE LOWER EMBODIED ENERGY THAN ALTERNATIVES The embodied energy in house walls of timber frames and timber cladding is about half that of alternatives despite the embodied energy incurred in maintaining the cladding by regular painting (Table 12).

Table 12: Timber house walls have lower embodied energy than alternatives65

Type of wall construction Initial embodied Maintenance 40 y Embodied energy (MJ) (MJ) (MJ) Timber frame & timber cladding, painted 31,020 24,750 55,770 Timber frame & brick cladding, unpainted 92,565 0 92,565 Double brick, unpainted 141,900 0 141,900 Steel frame, fibro cement cladding, painted 75,900 24,750 100,650

63 Adapted from Resource Assessment Commission Report 64 Adapted from RAC Report & I. Ferguson, B. Lafontaine, P. Vinden, L. Bren, R. Hateley, and B. Hermesec, B. (1996). Environmental Properties of Timber. FWPRDC Report PN005.95 65 I. Ferguson, B. Lafontaine, P. Vinden, L. Bren, R. Hateley, and B. Hermesec, B. (1996). Environmental Properties of Timber. FWPRDC Report PN005.95 Ecologically sustainable management of Victorian native forests – J N Cameron

LC EPC Inquiry into Ecosystem Decline in Victoria Submission 471 52

9.5 TIMBER HAS MUCH LOWER POLLUTION IMPACTS THAN OTHER BUILDING MATERIALS Manufacture of timber products is associated with lower emissions of carbon dioxide, carbon monoxide, sulphur dioxide and volatile organic compounds than the manufacture of steel. Forests act as a net sink for carbon dioxide, sulphur dioxide particulate matter. Manufacture of iron and steel results in about 40kg/t of carbon dioxide, sulphur dioxide and nitrous oxide emissions to the atmosphere. A by-product of Aluminium smelting is fully fluorinated compounds which are far more powerful greenhouse gases than carbon dioxide, because of their extremely long lives. Manufacture of Cement can produce up to 240g/t of sulphur dioxide and up to 6g/t of nitrogen oxides.

Large quantities of solid waste including some hazardous waste are produced during the manufacture of iron and steel. Millions of tonnes of toxic mud and red sand are produced as by-products of Aluminium production. Timber residues are usually recycled into other wood, pulp and paper products or used as fuel.

Very large quantities of contaminated water are produced with each tonne of steel with pollutants including hydrocarbons, sulphides, phenolic compounds, ammonia, cyanide, heavy metals, oil and grease. Each cubic metre of cement can generate over 1,500 litres of alkaline waste water.

Ecologically sustainable management of Victorian native forests – J N Cameron