Spatial analysis of logging on steep slopes across Special Water Supply Catchment areas in the Central Highlands of A summary of a submission provided to the audit of VicForests’ logging operations against the FSC Controlled Wood Standard for Forest Management Enterprises

December 2019

Chris Taylor and David Lindenmayer The Australian National University Fenner School of Environment and Society

Recommended citation: Taylor C and Lindenmayer DB. (2018) Spatial analysis of logging on steep slopes across Special Water Supply Catchment areas in the Central Highlands of Victoria. Fenner School of Environment & Society, The Australian National University, Canberra.

Cover photo: Coupe 318-512-0009 in the Upper Goulburn showing the slope we measured at 33° and the largest area cut exceeding 30° in slope (Photo: C. Taylor). Table of contents

1. Introduction ...... 1 2. Methods ...... 3 2.1 Study area 3 2.2 Code of Forest Practices for Timber Production 4 2.3 Data inputs 5 2.4 Analysis 6 2.5 Field inspection 7 3. Results ...... 9 3.1 Upper Goulburn Catchment 9 3.2 Thomson Catchment 15 3.3 Catchment 20 3.4 Catchment 21 3.5 and Catchment 25 3.6 McMahons Creek Catchment 27 3.7 Starvation Creek Catchment 30 3.8 Catchment 33 3.9 River Catchment 35 4 Discussion ...... 37 4.1 Comparison with previous submission 37 4.2 VicForests rebuttal 37 4.3 Forest Audit Program under the Code of Forest Practices 38 4.4 Implications for forest management 39 4.5 Implications under the FSC Standards 40 5 Conclusion ...... 40 Acknowledgements ...... 41 References ...... 42

i Figures Figure 1. Location of Special Water Supply Catchments analysed in this study 3 Figure 2. Slope raster derived from 10m DTM 7 Figure 3. Areas identified above 30⁰ within previous clearfell logged coupes 8 Figure 4. Coupe areas classified into percentage of net areas logged exceeding 30⁰ 8 Figure 5. Net coupe areas showing extent of Code of Forest Practice (CFP) exclusion zones logged 9 Figure 6. Upper Goulburn West Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 30⁰ 10 Figure 7. Upper Goulburn East Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 30⁰ 11 Figure 8. Coupe 318-512-0009 in the Upper Goulburn showing the slope we measured at 33⁰ and the largest area cut exceeding 30⁰ in slope 11 Figure 9. Another slope we measured on site at 34⁰ in Coupe 318-512-0009 12 Figure 10. Coupe 318-512-0010 in Upper Goulburn featuring a slope measured on site at 31⁰ and we estimated around 2.9ha exceeds 30⁰ 12 Figure 11. Coupe 320-502-0021 in the Upper Goulburn Catchment was checked and a slope within analysed area measured on site at 36⁰. We estimate around 2.9ha exceeds 30⁰ 13 Figure 12. Coupe 320-501-0024 Upper Goulburn Catchment and two sites measured on site at 37⁰ and 38⁰ 13 Figure 13. Upper Goulburn West Special Water Supply Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 14 Figure 14. Upper Goulburn East Special Water Supply Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 14 Figure 15. Coupe 320-512-0026 featured 10.4 ha of CFP exclusion logged, equating to 33% of net area logged 15 Figure 16. Thomson Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 30⁰ 16 Figure 17. Coupe 458-508-0011 where we estimated around 4.6 ha cut exceeded 30⁰, the largest area detected in the Thomson Catchment 17 Figure 18. Thomson Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 18 Figure 19. Coupe 457-504-0005 featured 5.7 ha of CFP exclusion logged, equating to 36% of net area logged 19 Figure 20. Tanjil Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 30⁰ 19 Figure 21. Steep slopes exceeding 30⁰ in coupes 459-503-0000, 459-503-0001, 459-503- 0003 and 459-503-0010, where the combined area cut exceeding 30⁰ was estimated to be 7.1 ha 21 Figure 22. Tanjil Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 21 Figure 23. Tyers Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 30⁰ 23 ii Figure 24. Tanjil Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 24 Figure 25. Loch Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 30⁰ 26 Figure 26. Loch River and Deep Creek Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 26 Figure 27. McMahons Creek Catchment and logging 2004-2019 showing coupes with slopes > 25⁰ 28 Figure 28. McMahons Creek Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 29 Figure 29. Starvation Creek Catchment and logging 2004-2019 showing coupes with slopes > 25⁰ 31 Figure 30. Starvation Creek Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 32 Figure 31. Tarago Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 30⁰ 34 Figure 32. Tarago River Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 34 Figure 33. Bunyip Special Water Supply Catchment and logging 2004-2019 showing coupes with slopes > 25⁰ 36 Figure 34. Catchment and logging 2004-2019 showing coupes where CFP exclusions were logged 36

Tables Table 1. Extract of requirements specified in Appendix 3, Table 11 of the Management Standards and Planning Procedures 4 Table 2. Number of Coupes containing areas of slopes > 30° in Upper Goulburn Catchment 9 Table 3. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Upper Goulburn Catchment 10 Table 4. Number of Coupes containing areas of slopes > 30° in Thomson Catchment 15 Table 5. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Thomson Catchment 17 Table 6. Number of Coupes containing areas of slopes > 30° in Tanjil Catchment 20 Table 7. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Tanjil Catchment 20 Table 8. Number of Coupes containing areas of slopes > 30° in Tyers Catchment 22 Table 9. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Thomson Catchment 22 Table 10. Number of Coupes containing areas of slopes > 30° in Loch Catchment 25 Table 11. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Loch Catchment 27

iii Table 12. Number of Coupes containing areas of slopes > 30° in McMahons Creek Catchment 27 Table 13. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in McMahons Creek Catchment 27 Table 14. Number of Coupes containing areas of slopes > 30° in Starvation Creek Catchment 30 Table 15. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Starvation Creek Catchment 30 Table 16. Number of Coupes containing areas of slopes > 30° in Loch Catchment 33 Table 17. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Thomson Catchment 33 Table 18. Number of Coupes containing areas of slopes > 30° in Starvation Creek Catchment 35 Table 19. Number of Coupes containing areas cut assigned as Code of Forest Practice Exclusion Zones in Starvation Creek Catchment 35

List of Abbreviations FSC Forest Stewardship Council DELWP Department of Environment, Land, Water and Planning DSE Department of Sustainability and Environment IFA Institute of Foresters

iv 1. Introduction In November 2019, the Victorian Government announced logging across the state’s native forests would close by 2030 (1). Following on, the Victorian Government’s logging business, VicForests, was assessed by accredited auditors against the Forest Stewardship Council’s (FSC) Controlled Wood Standard (2). The FSC is widely recognized as a leading forest certification scheme, on the basis that it enjoys support from a wide range of environmental, social and economic interests (3). The FSC label has grown considerably across the world (4), with leading brands featuring the FSC logo on many of their products (5). VicForests has recognized this market push and it has made several unsuccessful attempts to meet FSC Controlled Wood Standard for Forest Management Enterprises (FSC-STD-30-010 V2.0) (6) as well as the more rigorous FSC forest management certification standard (7). In November 2019, VicForests made another attempt at meeting FSC-STD-30-010 V2.0, which requires forest management companies to not illegally log forests, to not violate civil or traditional rights, not threaten high conservation value forests, not convert native forests to plantations or other non- forest uses and to not use genetically modified trees (6). It was audited by SCS Global Services, an accredited FSC certification body. In the lead up to this FSC Controlled Wood audit, we prepared a submission detailing where logging had occurred on steep slopes across declared Special Water Supply Catchments in the Central Highlands of Victoria. We argued that this practice compromises the integrity of these catchments. Under the FSC system, we argue that these forests would qualify as High Conservation Value (HCV) forests. Under HCV Category 4 (HCV4), the FSC Australia HCV Evaluation Framework states that a forest can be classified as high conservation value if it provides basic ecosystem services in critical situations, including where forests protect water catchments and control erosion of vulnerable soils and slopes (8). The Framework listed an ecosystem service is considered to be ‘critical’ where a disruption of that service is likely to cause or pose a threat of severe negative impact on the welfare, health or survival of local communities, on the environment or on other High Conservation Values (8). The FSC-STD-30-010 V2.0 Standard requires that forest management operations maintain and not threaten these and other high conservation values. The logging of forests on steep slopes risks the occurrence of erosion, which is simply the transport of soil constituents by natural forces, primarily water and wind (9). Soils on steep slopes are vulnerable to erosion due increased flows of water across the surface and the increased effect of gravity. As the slope becomes steeper, the effect of gravity on soil particles to move downslope increases (10). Disturbed forest areas are also vulnerable to increased erosion. Soil erosion rates across undisturbed forested catchments may be around 0-1 t/ha/year. In contrast, erosion rates following a disturbance, such as a fire, may range between 10-50 t/ha/year (11). In their High Conservation Values Management Systems document, VicForests sought to address management around the critical nature of water catchments, whereby it had: ….identified and lists [sic] potential HCV 4. Many catchment studies have been undertaken which demonstrated the criticality of well managed and timed forestry practices in water supply catchments. In these situations, there are additional requirements on forest managers through codes of practice, licenses and requirements from catchment management authorities (12 p. 14). Here, VicForests relied on the Code of Forest Practices for Timber Production in ensuring that High Conservation Values around water catchments were not threatened. In its accompanying assessment of HCV forests across its land tenure, VicForests summarized the Code requirements and

1 made the claim of protecting steep slopes exceeding 30⁰ from logging as a demonstration of HCV4 being maintained: It is beyond the scope of this assessment to identify each specific location that provides protection from erosion within the eastern FMU. However, VicForests has identified the area of forest within the FMU that has a slope of 30 degrees or more. VicForests protects forest areas on slopes greater than 30 degrees and applies specified variable width buffers and filter strips around waterways to the minimise impact of erosion from water runoff. These topographic exclusions together with riparian zone exclusions can result in significant additional ‘reserve areas’ being created within the FMU (in accordance with Code of Practice for Timber Production 2014) (13 p. 38). The Code of Forest Practices for Timber Production 2014 is a normative document upon where all logging across native state forests must comply (14). It has an incorporated document titled Management Standards and Procedures for timber harvesting operations in Victoria’s State forests, which provides restrictions around logging on steep slopes and logging within Special Water Supply Catchments (15). These water catchments are areas declared under Division 2 of Part 4 or otherwise listed in Schedule 5 of the Catchment and Land Protection Act 1994 or subject to any relevant amendments or revocations published in the Government Gazette (14). There are currently 134 Special Water Supply Catchments gazetted under the Catchment and Land Protection Act 1994 across Victoria (16), Under this Act, these areas are officially recognised as designated catchments for water supply purposes and include catchments supplying water to Melbourne, its surrounding urban areas (17), as well as regional Victoria (16). In our submission to the FSC audit of VicForests operations against FSC-STD-30-010 V2.0, we alleged that logging was occurring on steep slopes within the Special Water Supply Catchments that exceeded the limits imposed by the Management Standards and Procedures for those catchments. To demonstrate our allegation, we initially conducted a preliminary spatial analysis whereby we used a SRTM derived Digital Elevation Model (DEM) raster to generate a slope raster across multiple Special Water Supply Catchment areas where logging occurs (18). We overlaid recent logging history (19) and satellite land imagery (20) to identify where slopes had exceeded limits specified under the Management Standards and Procedures. The DEM we used had a resolution of 1 arc second (18), which provided a broad indication where logging on slopes exceeding limits imposed by the Management Standards and Procedures had occurred. We carried out field assessments with a clinometer to validate the spatial analysis, We initially found that logging of steep slopes had occurred on 252 coupes since 2004, the year VicForests began operating (21). Following our submission to SCS Global Services, our preliminary results were published in a media report shortly thereafter (22). VicForests rejected our preliminary findings, arguing that they determined the steepness of slopes by using Light Detection and Ranging (LiDAR) and claimed it to be almost 30 times better in resolution than methods used in our preliminary analysis (23). Access to LiDAR data was not available via the DELWP public data library. In its place, we accessed and used the VicMap Elevation 10m Digital Terrain Model to generate a slope raster for our analysis (24, 25). This greatly enhanced our spatial analysis to determine the extent of logging occurring on slopes exceeding limits specified under the Management Standards and Procedures. We also carried out a spatial analysis of where logging had occurred within areas mapped as Code of Forest Practice (CFP) exclusion zones (26). Defined as VicForests Reserves under VicForests Ecologically Sustainable Forest Management Plan, CFP Exclusion zones are forest areas to be excluded from logging (27). These exclusion areas are mostly based around streamside buffers and

2 steep slopes (28). The inclusion of this analysis allowed for confirmation of forest areas on slope exceeding specified limits under the Management Standards and Procedures being cut. 2. Methods 2.1 Study area Our analysis covered nine special water supply catchments across the Central Highlands of Victoria (Figure 1) covering an area of 454,951 hectares. The catchments we analysed consisted of the Upper , , Tanjil River, Tyers River, Loch River, Tarago River, McMahons Creek, Starvation Creek and Bunyip River Catchments. The majority of these catchments in area consist of state forest and logging is permitted in all of these catchments (15, 29, 30). The Thomson River, McMahons Creek and Starvation Creek Catchments provide water to Melbourne and its urban surrounds (17). The Thomson is the largest of all Melbourne’s water supply catchments by area and yield (29). The Tarago River Catchment supplies water to the , which in turn supplies water to the Westernport and Mornington Peninsula regions (31). The remaining catchments mostly supply water regional areas of Victoria, particularly agricultural production areas.

Figure 1. Location of Special Water Supply Catchments analysed in this study The Goulburn River Basin covers 2,431,655 hectares and the combined Goulburn Broken Catchment region provides 11% of the Basin’s stream flow (32). The basin extends from the near Woods Point, to the in the north-west near (33). The Upper Goulburn River Catchment has been declared a Special Water Supply Catchment and covers an area of 279,143 ha (34). It mostly forested with some cleared agricultural land across low elevation areas. The Thomson River catchment is entirely forested and supplies water to the Thomson Reservoir, the largest in the Supply system. This reservoir has a capacity of 1,068 billion litres, comprising 59% of Melbourne's total water storage capacity (35). The Thomson Reservoir receives the highest streamflow compared to other reservoirs throughout the Melbourne water supply

3 system, including the closed water catchments (29). The catchment covers a combined area of 48,371 ha (36). The Tanjil River and Tyers River catchments are mostly forested with small areas of used for agricultural production in low lying areas. These catchments cover areas of 50,702 ha and 31,969 ha, respectively (36). The Loch River catchment is mostly forested with sections of it used for plantations and agricultural production (37). It covers an area of 11,897 ha (36). The Tarago River catchment is mostly forested with its eastern periphery used for agricultural production. It covers an area of 11,067 ha (36). The Starvation Creek and McMahons Creek catchments are small forested catchments supplying water to Melbourne. They cover areas of 3,646 ha and 4,426 ha, respectively (36). The Bunyip River catchment is enitrely forested and covers an area of 3,976 ha (36). 2.2 Code of Forest Practices for Timber Production Logging within the special water supply catchments are subject to specific provisions under the Code of Forest Practices for Timber Production (14). This Code is a prescribed legislative instrument that sets standards for logging operations in Victorian state forests. Compliance with this Code is required under the provisions of the Sustainable Forests (Timber) Act 2004. The Secretary to the Department of Environment, Land, Water and Planning (DELWP) is responsible for ensuring compliance with this Code is met across state forests. The Code of Forest Practices features a requirement addressing water quality, river health and soil protection, which is addressed under Section 2.2.1.1: Planning and management of timber harvesting operations must comply with relevant water quality, river health and soil protection measures specified within the "Management Standards and Procedures (14 p. 32). The Management Standards and Procedures for timber harvesting operations in Victoria’s State forests (Management Standards and Procedures) is also a regulatory document that is incorporated in the Code. As with the Code of Forest Practices, logging in Victorian native state forests must comply with the Management Standards and Procedures (14). It provides specific compliance measures addressing water quality, river health and soil protection (15). Under Sections 3.4 and 3.5, logging on steep slopes are addressed. There are two sections under the Management Standards and Planning Procedures covering slopes. The first under Section 3.4 General slope restrictions, features the following requirements: 3.4.1.1 Exclude timber harvesting operations from slopes over 30 degrees. 3.4.1.2 Up to 10% of the net harvest area of any coupe can contain areas greater than 30 degrees, where the risk of mass soil movement has been managed accordingly (15 p. 30). However, there is a special category under Section 3.5 for water supply protection areas, which provide specific prescriptions for special water supply catchment areas in the following clause: 3.5.1.1 Apply the slope limits, seasonal closures, buffer and filter strip widths and other relevant management actions specified in Appendix 3 Table 11 (Water supply protection areas) for timber harvesting operations and associated roading and regeneration in water supply protection areas (15 p. 30). The prescriptions detailed in Appendix 3, Table 11 are detailed below in Table 1 for the special water supply catchments we analysed. Where logging is not to comply with clause 3.5.1.1 of the Management Standards and Procedures, VicForests are required to obtain approval from the now Minister for Energy, Environment and

4 Climate Change1 or an appointed delegate. This process is to be carried out in accordance with section 1.4 of the Management Standards and Procedures, whereby an Approval Request Form and any other required or supporting information is to be submitted to the Minister or appointed delegate. An exemption or temporary variation to the Management Standards and Procedures is to be sought. The Minister or appointed delegate is then required to consider the request, seeking additional information where required, and respond by providing a signed approval request form or rejection with justification to VicForests. The Minister or appointed delegate is to maintain a register of the outcomes for all exemption or temporary variation requests.

Table 1. Extract of requirements specified in Appendix 3, Table 11 of the Management Standards and Planning Procedures (15) Catchment Status Slope Seasonal Stream Filter Comments Limit Closure Buffers Strips Upper SWSC 30⁰ 20m 10m Goulburn Thomson SWSC & 30⁰ 1 May – 40m 10m Subject to additional regulations River SAP 30 Nov under the Forests Act 1958 which includes limitations on access, camping, hunting with hounds and horse riding. Average 150 ha Ash and 15ha MS on rolling average. Tanjil River SWSC & 30⁰ 1 June – 20m 10m Closure applies north of Icy Creek SAP 31 Oct – Mt Baw Baw Road. Tyers River SWSC & 30⁰ 1 June – 20m 10m Applies above 650 m ASL. SAP 31 Oct Harvesting restrictions on land above 1220 m. Buffer within 200 m of Moondarra Reservoir foreshore. Buffer of 40 m on Jacobs Creek up to the Walhalla Road. Loch River SWSC 30⁰ 1 July – 20m 10m 30 Sept Starvation Restricted 25⁰ 1 May – 40m 10m A maximum of 30% is to be Creek 30 Nov harvested over a 10 year period McMahons Restricted 25⁰ 1 May – 40m 10m A maximum of 30% is to be Creek 30 Nov harvested over a 10 year period Tarago River SWSC & 30⁰ 1 May – 20m 10m Average 55 ha Ash and 23 ha MS SAP 31 Oct on rolling average. Bunyip River SWSC & 25⁰ 1 May – 20m 10m 60 m buffer upstream of weir SAP 30 Nov Notes: SWSC – Special Water Supply Catchment; SAP – Special Area Plan; Restricted - restricted access catchments managed by agreement between Melbourne Water and DELWP 2.3 Data inputs We used data consisting of the VicMap Elevation 10m Digital Terrain Model2 (DTM) (25) to generate a slope raster, spatial records of recent logging activities (19) to map the extent of logging history over our analysis period and Sentinel 2 Land Imagery (20) to update and amend the spatial records of recent logging activities. Our study boundaries were defined by the extent of the special water supply catchment areas (34).

1 Listed in the Code of Forest Practices as “Minister for Environment and Climate Change”. 2 A DTM is a representation of continuous elevation values over a topographic surface by a regular array of z-values, which represents the earth’s terrain.

5 The VicMap Elevation 10m DTM raster dataset we used was developed as a joint project through the National Action Plan for Salinity and Water in conjunction with then Department of Sustainability and Environment (DSE) and Sinclair Knight Merz (24). The development methodology of this dataset used both ANUDEM and Triangulated Irregular Network (TIN) processes and it included inputs from Vicmap Elevation, Vicmap Hydro, LiDAR and Photogrammetry derived DTMs and contours, Survey Marks Enquiry Service, Reservoir Supply Levels, Lake Heights and Shuttle Topography Radar Mission (SRTM) Digital Elevation Models (DEM). Each 10m raster pixel in the dataset represented the average elevation of the pixel. The datum used in the construction and maintenance of Vicmap Elevation DTM 10m is the Geocentric Datum of Australia. The data is held in Vicgrid94 (eastings/ northings) computed in terms of the GDA at 01 January 1994 (GDA94) (24). Our analysis of recent logging history across the special water supply catchments was in part derived from the dataset LOG_SEASON and represented the spatial extent of the most recent logging activity recorded (19). It featured the details of the last time an area was known to be logged, the tree species logged and the logging method used. It represented a consecutive overlay of all logging seasons, from 1961-62 season to the most recent season. We selected the seasons between the years 2004 and 2019, which is the historical extent of VicForests’ operations (38). We grouped the silvicultural methods of clearfelling, seed tree, regrowth retention and clearfelling salvage under the generic term clearfell logging, because these type of logging were similar in their respective disturbance intensities (39) and they were widely used across the study region (40). We used land imagery sourced from the Sentinel-2 Satellite (20) to update and amend the logging history where needed. The imagery was derived from the Sentinel-2 mission, which is a land monitoring constellation of two satellites providing 10m resolution optical imagery. Two tiles covering the study region were obtained for the date 18 May 2019. We generated true colour imagery and near infrared imagery for the study area. We updated logging disturbance boundaries where required. Special water supply catchment boundaries were selected from the dataset Designated Water Supply Catchments (34). This layer identified areas designated as domestic Water Supply Catchments subject to a Land Use Determination or a Land Use Notice. There are 134 special water supply catchment areas across Victoria (16). These catchment areas are declared under the Catchment and Land Protection Act, 1994. We selected the areas for Upper Goulburn River, Thomson River (stages 1,2 and 3), Tanjil River, Tyers River, Loch River and Deep Creek, Starvation Creek, McMahons Creek, Tarago River and Bunyip River catchments. For our analysis of Code of Forest Practice Exclusions zones, we sourced spatial data from FMZ100_V_ZONE (26). This dataset provides a description of forest management zones across state forests, including General Management Zones (GMZ), Special Management Zones (SMZ), Special Protection Zones (SPZ) and Code of Forest Practice (CFP) exclusions. We isolated areas defined as CFP exclusions and overlaid these across the special water supply catchment areas. 2.4 Analysis We generated a slope raster derived from the VicMap Elevation 10m DTM (25) raster using ArcGIS 10 (41) (Figure 2). We used the native projection for the VicMap Elevation 10m DTM, Vicgrid94 - Geocentric Datum of Australia – 1994 Adjustment (GDA94) (24) and a default Z-value of 1, as the 10m DTM projection was based in metres. From the slope raster, we identified areas that exceeded 30⁰ (and 25⁰ for the Bunyip River, Starvation Creek and McMahon Creek Catchments) in slope and isolated these areas where they occurred on logging coupes cut between 2004 to the current year of assessment, 2019 (Figure 3). We then calculated the area of slope exceeding 30⁰ (and 25⁰ for the Bunyip River, Starvation Creek and McMahon Creek Catchments) across the net logged areas and classified each logged coupe under the following categories:

6 1. Slope =< 30⁰ 2. <5% of Coupe > 30⁰ 3. 5-10% of Coupe > 30⁰ 4. >10% of Coupe > 30⁰3 This identified coupes with much larger areas exceeding 30⁰ from those with smaller areas (Figure 4). The analysis of CFP exclusion zones was also classified into the following corresponding categories: 1. No Code Exclusion 2. <5% Coupe Code Exclusion 3. 5-10% Coupe Code Exclusion 4. >10% Coupe Code Exclusion This identified coupes with large areas of the net area logged consisting of CFP exclusion zones cut from those with smaller areas (Figure 5).

Figure 2. Slope raster derived from VicMap Elevation 10m DTM (25)

3 For the Starvation Creek, McMahons Creek and Bunyip River Catchments, the slope limit was set to 25º.

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Figure 3. Areas of slope greater than 30 ⁰ within net areas previously clearfell logged

Figure 4. Coupe areas classified into percentage of net areas logged with slopes exceeding 30 ⁰

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Figure 5. Net coupe areas showing extent of Code of Forest Practice (CFP) exclusion zones logged 2.5 Field inspection We carried out field inspections of multiple coupes within the Upper Goulburn catchment. We used on-site methods described in the VicForests’ Utilisation Procedures (42). We measured approximately six sites using a Clinometer (Clino). Measurement consisted of two people, where one person took a view through the sighting hole of the Clino to a second person of equivalent height up or down the slope that was measured. The first person lined cross line in the sighting hole in the Clino with the eye level of the second person and recorded the measurement. Both people stood on the ground clear of snig tracks and other major soil disturbance. Slope measurement was measured in degrees. 3. Results 3.1 Upper Goulburn Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 30⁰ for the Upper Goulburn catchment. Since the commencement of VicForests operations in 2004, we detected 214 coupes having been cut in the catchment. Of these, we estimated that 160 coupes or 75% of total coupes cut between 2004 and 2019 contained areas exceeding 30⁰ in slope (Table 2, Figures 6 and 7). Of these, 33 coupes or 15% of the total coupes cut between 2014 and 2019 featured >10% of the respective net area exceeding 30⁰. The largest area exceeding 30⁰ to be cut on a coupe consisted of estimated at 10.96 hectares. This occurred on coupe 318-512-0009 (Figure 8) and equated to around 30% of the net logged area. We measured on site slopes exceeding 30⁰ at Coupe 318-512-0009, with angles of 33⁰ and 34⁰ being recorded (Figures 8 and 9). The adjoining coupe 318-512-0010 featured 9.3 ha exceeding 30⁰, equating to around 32% of net area logged. We measured on-site a slope of 31⁰ (Figure 10). We measured two other coupes in the Upper Goulburn: We measured a slope of 36⁰ logged at coupe 320-502-0021, where 3.4 ha exceeding 30⁰ was logged, equating to 19% of net area (Figure 11). The steepest slopes we recorded on-site were at coupe 320-

9 502-0024, where we measured 37⁰ and 38⁰ across two sites (Figure 12). We estimated that 2.7 ha exceeding 30⁰ was logged at this coupe. We found 155 coupes or 72% of total coupes logged containing areas mapped as CFP exclusions (Table 3, Figures 13 and 14). Of these, 34 coupes or 16% of total coupes logged featured >10% of the respective net area as CFP exclusion zones. The largest area of CFP exclusion logged occurred on coupe 318-512-0026, with 10.4 ha consisting 33% of net area logged (Figure 15).

Table 2. Number of Coupes containing areas of slopes > 30⁰ in Upper Goulburn River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 30⁰ Slopes =< 30⁰ 54 25% 0.0 < 5% of Coupe > 30⁰ 95 44% 27.3 5-10% of Coupe > 30⁰ 32 15% 32.0 >10% of Coupe > 30⁰ 33 15% 93.2 Grand Total 214 100% 152.5

Table 3. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in Upper Goulburn River Catchment Code Exclusion Category No. of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 59 28% 0.0 <5% Coupe Code Exclusion 92 43% 34.8 5-10% Coupe Code Exclusion 29 14% 39.0 >10% Coupe Code Exclusion 34 16% 87.9 Total 214 100% 161.7

Figure 6. Upper Goulburn River West catchment and logging carried out between 2004 and 2019 showing coupes with slopes > 30⁰

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Figure 7. Upper Goulburn River East catchment and logging carried out between 2004 and 2019 showing coupes with slopes > 30⁰

Figure 8. Coupe 318-512-0009 in the Upper Goulburn River catchment showing the slope we measured at 33⁰ and the largest area cut at 10.96 ha exceeding 30⁰ in slope.

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Figure 9. Another slope we measured on site at 34⁰ in Coupe 318-512-0009.

Figure 10. Coupe 318-512-0010 in Upper Goulburn River catchment featuring a slope measured on site at 31⁰ and we calculated around 9.3ha exceeding 30⁰ in slope.

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Figure 11. Coupe 320-502-0021 in the Upper Goulburn River Catchment was checked and a slope within analysed area measured on site at 36⁰. We calculated around 3.4ha exceeding 30⁰ in slope.

Figure 12. Coupe 320-501-0024 Upper Goulburn River Catchment and two sites measured on site at 37⁰ and 38⁰. We calculated around 2.7ha exceeding 30⁰ in slope.

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Figure 13. Upper Goulburn River catchment West and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

Figure 14. Upper Goulburn River catchment East and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

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Figure 15. Coupe 320-512-0026 in the Upper Goulburn River where we calculated around 10.4 ha or 33% of net area logged as CFP exclusion zone. 3.2 Thomson Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 30⁰ for logging across the Thomson special water supply catchment. Since the commencement of VicForests operations in 2004, 141 coupes have been logged in the Thomson catchment. Of these, we estimated that 101 coupes or 72% of total coupes cut contained areas exceeding 30⁰ in slope (Table 4, Figure 16). Of these, we calculated 21 coupes or 15% of the total coupes logged containing >10% of the respective net area exceeding 30⁰ in slope. We calculated the largest area exceeding 30⁰ was logged on coupe 457-504-0005 and this consisted of 4.8 ha, equating to 30% of net area logged. We detected around 10.2 ha exceeding 30⁰ logged on an aggregation of coupes 458-508-0010, 458- 508-0011 and 458-508-0014 (Figure 17). We calculated 76 coupes or 54% of total coupes logged as containing areas mapped as CFP exclusions (Table 3, Figures 18). Of these, 17 coupes or 12% of total coupes logged featured >10% of the respective net area as CFP exclusion zones. The largest area of CFP exclusion logged occurred on coupe 457-504-0005, consisting of 5.7 ha or 36% of net area logged (Figure 19).

Table 4. Number of Coupes containing logged areas of slopes > 30⁰ in Thomson River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 30⁰ Slopes =< 30⁰ 40 28% 0.0 < 5% of Coupe > 30⁰ 65 46% 18.6 5-10% of Coupe > 30⁰ 15 11% 15.6 >10% of Coupe > 30⁰ 21 15% 55.4 Grand Total 141 100% 89.6

15 Figure 16. Thomson River Catchment and areas logged between 2004 and 2019 containing slopes > 30⁰

16

Figure 17. An aggregation of coupes (458-508-0010, 458-508-0011 and 458-508-0014) where we calculated around 10.2 ha cut exceeding 30⁰ in slope in the Thomson River catchment.

Table 5. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in Thomson River Catchment Code Exclusion Category No. of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 65 46% 0.0 <5% Coupe Code Exclusion 46 33% 10.8 5-10% Coupe Code Exclusion 13 9% 17.6 >10% Coupe Code Exclusion 17 12% 52.1 Grand Total 141 100% 80.5

17

Figure 18. Thomson River catchment and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

18

Figure 19. Coupe 457-504-0005 where we calculated 5.7 ha of CFP exclusion logged, equating to 36% of net area logged

Figure 20. Tanjil River catchment and areas logged between 2004 and 2019 showing coupes with slopes > 30⁰

19 3.3 Tanjil River Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 30⁰ for logging across the Tanjil River catchment. Since the commencement of VicForests operations in 2004, 105 coupes have been logged in the catchment. Of these, we estimated that 67 coupes or 64% of total coupes contained areas exceeding 30⁰ in slope (Table 6, Figure 20). Of these, 6 coupes or 6% of the total coupes logged featured >10% of the respective net area exceeding 30⁰ in slope. The largest area exceeding 30⁰ to be logged consisted of around 5.6 hectares occurring on coupe 459- 501-0004. We calculated aggregated coupes 459-503-0000, 459-503-0001, 459-503-0003 and 459- 503-0010 together featured to have around 6.6 ha of slopes exceeding 30⁰ logged (Figure 21). We calculated 55 coupes or 52% of total coupes logged containing areas mapped as CFP exclusions (Table 7, Figures 22). Of these, 4 coupes or 4% of total coupes logged featured >10% of the respective net area as CFP exclusion zones. The largest area of CFP exclusion logged also occurred on coupe 459-501-0004, consisting of 5.1 ha or 15% of net area logged.

Table 6. Number of Coupes containing areas of slopes > 30⁰ in Tanjil River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 30⁰ Slopes =< 30⁰ 38 36% 0.0 < 5% of Coupe > 30⁰ 48 46% 15.3 5-10% of Coupe > 30⁰ 13 12% 20.9 >10% of Coupe > 30⁰ 6 6% 17.6 Grand Total 105 100% 53.9

Table 7. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in Tanjil River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 50 48% 0 <5% Coupe Code Exclusion 43 41% 15.1 5-10% Coupe Code Exclusion 8 8% 8.8 >10% Coupe Code Exclusion 4 4% 12.2 Grand Total 105 100% 36.0

20

Figure 21. Aggregate coupes 459-503-0000, 459-503-0001, 459-503-0003 and 459-503-0010 where the combined area cut exceeding 30⁰ was calculated to be 6.6 ha.

Figure 22. Tanjil River catchment and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

21 3.4 Tyers River Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 30⁰ in the Tyers River Catchment. Since the commencement of VicForests operations in 2004, 69 coupes have been cut in the Tyers River catchment. Of these, we calculated that 27 coupes or 39% of total coupes cut between 2004 and 2019 contained areas exceeding 30⁰ in slope (Table 8, Figure 23). We found 2 coupes featured >10% of the respective net area exceeding 30⁰ in slope. The largest area logged exceeding 30⁰ in slope occurred on 482-501-0054 consisting of 1.5 hectares. We found 22 coupes or 32% of total coupes logged contained areas mapped as CFP exclusions (Table 9, Figure 24). Of these, 2 coupes featured >10% of the respective net area logged as CFP exclusion zones (Figure 24). Coupe 484-504-0009 featured the largest area of CFP exclusion zone, consisting of 1.7 ha or 22% of net area logged.

Table 8. Number of Coupes containing areas of slopes > 30⁰in Tyers River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 30⁰ Slopes =< 30⁰ 42 61% 0.0 < 5% of Coupe > 30⁰ 21 30% 4.1 5-10% of Coupe > 30⁰ 4 6% 2.0 >10% of Coupe > 30⁰ 2 3% 2.8 Grand Total 69 100% 8.9

Table 9. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in Tyers River Catchment Code Exclusion Category Number of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 47 68% 0.0 <5% Coupe Code Exclusion 18 26% 3.7 5-10% Coupe Code Exclusion 2 3% 1.0 >10% Coupe Code Exclusion 2 3% 3.0 Grand Total 69 100% 7.6

22

Figure 23. Tyers River Catchment and areas logged between 2004 and 2019 showing coupes with slopes > 30⁰

23

Figure 24. Tyers River Catchment and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

24 3.5 Loch River and Deep Creek Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 30⁰ for the Loch River catchment. Since the commencement of VicForests operations in 2004, 77 coupes have been cut in the catchment. Of these, we calculated that 53 coupes or 69% of total coupes logged between 2004 and 2019 contained areas exceeding 30⁰ in slope (Table 10, Figure 25). Of these, 5 coupes or 6% of the total coupes cut featured >10% of the respective net area exceeding 30⁰ in slope. We calculated the largest area exceeding 30⁰ to be cut occurred on coupe 462-503- 0015, with around 5.0 hectares or 26% of the net area logged. We calculated 58 coupes or 75% of total coupes logged containing areas mapped as CFP exclusions (Table 11, Figure 26). Of these, 13 coupes featured >10% of the respective net area as CFP exclusion zones, equating to 17% of total coupes logged. Coupe 462-503-0008 featured the largest area of CFP exclusion, with 6.8 ha logging or 22% of total net area logged (Figure 26).

Table 10. Number of Coupes containing areas of slopes > 30⁰ in Loch River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 30⁰ Slopes =< 30⁰ 24 31% 0.0 < 5% of Coupe > 30⁰ 39 51% 14.2 5-10% of Coupe > 30⁰ 9 12% 11.0 >10% of Coupe > 30⁰ 5 6% 18.0 Total 77 100% 43.2

Table 11. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in Loch River Catchment Code Exclusion Category Number of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 19 25% 0.0 <5% Coupe Code Exclusion 38 49% 12.2 5-10% Coupe Code Exclusion 7 9% 8.4 >10% Coupe Code Exclusion 13 17% 35.4 Grand Total 77 100% 56.0

25 Figure 25. Loch River Catchment and areas logged between 2004 and 2019 showing coupes with slopes > 30⁰

Figure 26. Loch River catchment and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

26 3.6 McMahons Creek Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 25⁰ for the McMahons Creek catchment. Since the commencement of VicForests operations in 2004, 14 coupes have been cut in the McMahons Creek catchment. Of these, we calculated that 12 coupes or 86% of total coupes cut between 2004 and 2019 contained areas exceeding 25⁰ in slope (Table 12, Figure 27). Of these, 5 coupes or 36% of the total coupes cut featured >10% of the respective net logged area exceeding 25⁰ in slope. The largest slope area exceeding 25⁰ was around 4.9 hectares on coupe 344-505-0004. We found 10 coupes or 71% of total coupes logged containing areas mapped as CFP exclusions (Table 13, Figure 28). Of these, 6 coupes featured >10% of the respective net logged area as CFP exclusion zones, equating to 43% of total coupes logged. The largest area of CFP exclusion logged occurred on coupe 344-504-0009, consisting of 2.2 ha or 27% of net area logged.

Table 12. Number of Coupes containing areas of slopes > 30⁰ in McMahons Creek Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 25º Slopes =< 25⁰ 2 14% 0.0 < 5% of Coupe > 25⁰ 3 21% 0.8 5-10% of Coupe > 25⁰ 4 29% 7.1 >10% of Coupe > 25⁰ 5 36% 13.3 Grand Total 14 100% 21.1

Table 13. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in McMahons Creek Catchment Code Exclusion Category No. of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 4 29% 0.0 <5% Coupe Code Exclusion 4 29% 1.6 5-10% Coupe Code Exclusion 0 0% 0.0 >10% Coupe Code Exclusion 6 43% 18.5 Grand Total 14 100% 20.1

27 Figure 27. McMahons Creek Catchment and areas logged between 2004 and 2019 showing coupes with slopes > 25⁰

28

Figure 28. McMahons Creek Catchment and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

29 3.7 Starvation Creek Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 25⁰ for the Starvation Creek catchment. Since the commencement of VicForests operations in 2004, 13 coupes have been cut in the catchment. Of these, we calculated that 9 coupes or 69% of total coupes cut between 2004 and 2019 contained areas exceeding 25⁰ in slope (Table 14, Figure 29). Of these, only one coupe featured >10% of the respective net logged area exceeding 25⁰ in slope, which occurred on coupe 344-511-0005. We calculated 2.8 ha exceeding the slope limit was logged. We found 6 coupes containing areas mapped as CFP exclusions (Table 15, Figure 30). Of these, only one coupe featured 5-10% of the respective net area as CFP exclusion zone, also occurring on coupe 344-511-0005 and 0.8 ha of CFP exclusion zone logged. There were no coupes under the >10% CFP exclusion logged category for the Starvation Creek catchment.

Table 14. Number of Coupes containing areas of slopes > 30⁰ in Starvation Creek Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 25º Slopes =< 25⁰ 4 31% 0.0 < 5% of Coupe > 25⁰ 2 15% 0.3 5-10% of Coupe > 25⁰ 6 46% 4.2 >10% of Coupe > 25⁰ 1 8% 7.3 Grand Total 13 100% 21.1

Table 15. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in Starvation Creek Catchment Code Exclusion Category No. of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 7 54% 0.0 <5% Coupe Code Exclusion 5 38% 1.2 5-10% Coupe Code Exclusion 1 8% 0.8 >10% Coupe Code Exclusion 0 0% 0.0 Grand Total 13 100% 2.1

30 Figure 29. Starvation Creek Catchment and areas logged between 2004 and 2019 showing coupes with slopes > 25⁰

31

Figure 30. Starvation Creek Catchment areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

32 3.8 Tarago River Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 30⁰ for the Tarago River Catchment. Since the commencement of VicForests operations in 2004, 41 coupes have been cut in the catchment. Of these, we calculated that 18 coupes or 44% of total coupes logged between 2004 and 2019 contained areas exceeding 30⁰ in slope (Table 16, Figure 31). Of these, only coupe 464-501-0008 featured >10% of its respective net logged area exceeding 30⁰ in slope, consisting of around 2.1 ha. We found 31 coupes or 76% of total coupes logged containing areas mapped as CFP exclusions (Table 17, Figure 32). Of these, 6 coupes featured >10% of the respective net area as CFP exclusion zones. The largest area of CFP exclusion logged occurred on coupe 464-501-0024, consisting of 2.6 ha 11% or total net area logged.

Table 16. Number of Coupes containing areas of slopes > 30⁰ in Tarago River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 30⁰ Slopes =< 30⁰ 23 56% 0.0 < 5% of Coupe > 30⁰ 16 39% 3.0 5-10% of Coupe > 30⁰ 1 2% 2.1 >10% of Coupe > 30⁰ 1 2% 2.1 Total 41 100% 7.2

Table 17. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in the Tarago River Catchment Code Exclusion Category Number of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 10 24% 0.0 <5% Coupe Code Exclusion 18 44% 5.5 5-10% Coupe Code Exclusion 7 17% 8.8 >10% Coupe Code Exclusion 6 15% 9.7 Grand Total 41 100% 24.0

33 Figure 31. Tarago Special Water Supply Catchment and areas logged between 2004 and 2019 showing coupes with slopes > 30⁰

Figure 32. Tarago River Catchment and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

34 3.9 Bunyip River Catchment Table 11 in Appendix 3 of the Management Standards and Procedures specifies a slope limit of 25⁰ in the Bunyip River Catchment. Since the commencement of VicForests operations in 2004, 16 coupes have been cut in the catchment. Of these, we estimate that 10 coupes or 63% of total coupes cut between 2004 and 2019 contain areas exceeding 25⁰ in slope (Table 18, Figure 33). Only one coupe featured >10% of its net logged area exceeding 25⁰ in slope, which consisted of around 3.4 hectares, occurring on coupe 350-510-0002. We found 12 coupes containing areas mapped as CFP exclusions (Table 19, Figure 34). Of these, 2 coupes featured >10% of their respective net logged areas as CFP exclusion zones, with the largest also occurring on coupe 350-510-0002. We calculated that 5.3 ha of CFP exclusion zone was logged on this coupe.

Table 18. Number of Coupes containing areas of slopes > 30⁰ in Bunyip River Catchment Slope Category No. of Coupes % of Total No. Coupes Area (ha) > 25⁰ Slopes < 25⁰ 6 38% 0.0 < 5% of Coupe > 25⁰ 9 56% 1.2 5-10% of Coupe > 25⁰ 0 0% 0.0 >10% of Coupe > 25⁰ 1 8% 3.4 Grand Total 16 100% 4.6

Table 19. Number of Coupes containing Code of Forest Practice Exclusion Zones logged in Bunyip River Catchment Code Exclusion Category No. of Coupes % of Total No. Coupes Area (ha) cut of code exclusions No Code Exclusions 4 25% 0.0 <5% Coupe Code Exclusion 8 50% 3.0 5-10% Coupe Code Exclusion 2 13% 1.2 >10% Coupe Code Exclusion 2 13% 7.9 Grand Total 16 100% 12.1

35 Figure 33. Bunyip Special Water Supply Catchment and areas logged between 2004 and 2019 showing coupes with slopes > 25⁰

Figure 34. Bunyip River Catchment and areas logged between 2004 and 2019 showing percentage of area as CFP exclusions.

36 4 Discussion Our spatial analysis has found that the logging of slopes exceeding the limits set under the Management Standards and Procedures is extensive. We estimated that Upper Goulburn River special water supply catchment featured the highest number of coupes with at least part of the net logged area exceeding specified slope limits at 160 coupes. Of these, 33 coupes were estimated to have >10% of the net area logged exceeding specified slope limits. The Thomson River catchment was found to have the next highest number at 101 coupes. We calculated that 21 of these coupes featured >10% of the net area logged exceeding specified slope limits. In total, this equated to 153 ha and 90 ha of area logged exceeding specified slope limits for the Upper Goulburn River and Thomson River catchments, respectively. Across all nine special supply water catchments analysed in this study, we estimated that 388 ha of area exceeding specified slope limits were logged. This pattern was similar to the areas of CFP exclusions zones logged across these catchments. The Upper Goulburn River catchment featured 155 coupes where CFP exclusion zones were logged, with 34 of these coupes having >10% of the net area logged mapped as CFP exclusion zones. The Thomson River catchment featured 76 coupes with CFP exclusions zones logged, with 17 of these coupes featuring >10% of their areas as CFP exclusions zones. This equated to 162 ha and 81 ha of CFP exclusion areas logged for the Upper Goulburn River and Thomson River catchments, respectively. Across all nine special supply water catchments in this study, we estimated that 400 ha of CFP exclusion zones were logged. 4.1 Comparison with previous submission The area logged exceeding specified slope calculated in this analysis was higher than the draft submission we forwarded to SCS Global Services (21) in their audit of VicForests logging operations against FSC-STD-30-010 V2.0, which was also reported in recent media (22). In our previous analysis, we generated our slope raster using an STRM-derived DEM, which had a lower resolution of 1 arc second (18). This lower resolution effectively underestimated the extent of slopes exceeding the limits specified under Management Standards and Procedures. The value of a raster cell in the DEM is the average height above sea level across that cell. As the majority of the landscape across the catchments is less steep than the slope limits specified under the Management Standards and Procedures, the larger raster grid cells may be weighted towards less steep slopes. With the higher resolution contained in the VicMap Elevation 10m DTM (25) raster used in this analysis, we were able to detect localized steep slopes in this analysis otherwise missed in the previous analysis. 4.2 VicForests rebuttal Following the media coverage of our first submission, VicForests rejected our allegations of logging occurring on slopes exceeding the limits specified under the Management Standards and Procedures for the special water supply catchments, based on a number of assertions. The first concerns an interpretation of the Management Standards and Procedures, whereby the acting CEO of VicForests, Ms Monique Dawson, stated: ……the Code for Timber Production [sic] allowed harvesting on slopes in water catchments, provided no more than 10% of a coupe’s harvestable area exceeded the slope limit (23). This provision is permitted under the requirement general slope restrictions under Section 3.4 of the Management Standards and Procedures. It states that up to 10% of the net logged area of any coupe can contain slopes greater than 30⁰, where the risk of mass soil movement has been managed accordingly (15). However, the VicForests Procedures Regulatory Handbook further states that additional slope restrictions must be applied to the special water supply catchments (43). This is covered under Section 3.5 of the Management Standards and Procedures, where specific slope limits

37 for each special water supply catchment are provided. These range between 30⁰ for most catchments, with the remainder being 25⁰. No provision to exceed the specified slope limits by 10% in area is provided under Section 3.5 for the special water supply catchments. There are also problems with VicForests’ inference of general slope restrictions under Section 3.4 applying to Section 3.5. It would effectively permit 10% of a logged area exceeding a slope limit of 30⁰ in a special water supply catchment where a 25⁰ slope limit had been imposed. It is not clear how such an inference could be translated into compliant action in the forest under the Management Standards and Procedures. In its media release, the acting CEO of VicForests also stated that it determined slopes by using: …..the latest LiDar (light detection and ranging) technology, which has almost 30 times better resolution than the methods cited in recent media reports (23). We have not been able to access the LIDAR data to compare against our analysis. However, in response to this criticism, we used the VicMap Elevation 10m DTM (25) for this analysis, which revealed a greater net area logged exceeding the slope limits specified under the Management Standards and Procedures than we previously estimated. Whilst LiDAR would provide greater resolution of steep slope areas, we find it inconceivable that the VicMap Elevation 10m DTM as well as our on field measurements would differ so significantly to VicForests’ LiDAR data, given that our analysis has found that multiple coupes featured >10% net logged areas exceeding slopes >30⁰. Many of these coupes also featured >10% of the respective net areas consisting of CFP exclusions. The VicForests media release continued to state that: ……VicForests did very little harvesting in catchments, where restrictions are in place (23). Historically, this has not been the case. Since it began operating in 2004, VicForests have clearfell logged 10,034 ha across the nine special water supply catchments (19). This includes 1,837 ha in the Thomson River Catchment and 3,264 ha in the Upper Goulburn River catchment. Since 1965, 34,188 ha have been clearfell logged across the nine water catchments by VicForests and its predecessors. In the Thomson Catchment, around 42% of the ash forest extent has been clearfell logged since the 1940s (29). The special water supply catchments have been targeted to supply industry with pulplogs and sawlogs. MBAC consulting found that Melbourne’s water supply catchments, including the Thomson River and Tarago River catchments, provided over 35% of sawlog output for the Central and Dandenong Forest Management Areas (FMA) for the years 2004-05 (44). 4.3 Forest Audit Program under the Code of Forest Practices Each year, the Department of Environment, Land, Water and Planning (DELWP) commission an environmental audit (Audit) to measure compliance of commercial logging operations against the Code of Practice for Timber Production 2014 and the Management Procedures and Standards under its Forest Audit Program (FAP) (45). In 2017-18, DELWP commissioned Jacobs Group (Australia) to carry out the Audit, where water quality, river health and soil protection and the conservation of biodiversity being one of two main focus areas (46). Compliance was determined by assessing specific aspects of forest management against the Code of Forest Practice and the Management Procedures and Standards, which included logging not taking place in excessively steep areas. An average slope of 15° or greater across logged areas formed one of five characteristics for the selection of logging coupes assessed in the Audit. The method of on-site slope measurement used by Jacobs Group (Australia) was based on visual observation and a clinometer was used where required (46). From a small selection of 30 coupes across Victoria, report of the Audit concluded:

38 Risks associated with harvesting in steep areas and soils with higher erosion hazard were generally well managed, with steep areas (20-30° and >30° slope) typically marked on the coupe operations map and/or noted in the forest coupe plan (FCP). Where required by the MSPs and/or dictated by practical constraints, steep areas were generally found to have been excluded from harvesting (46 p. 22). Selection of coupes in the Audit was based on risk and the auditors advised that these coupes could not be taken as being statistically representative of VicForests’ operations (46). However, the Audit found one logging coupe in the Upper Goulburn River special water supply catchment where slopes >30° were logged: Coupe marking included a small area of land mapped as having slope exceeding 30° in 7 Machikichori [317-508-0003]. The post-harvest map for the coupe shows that some of this area was harvested. Ordinarily, up to 10% of the net harvest area may be harvested in areas with over 30° slope. However, the coupe is located in the Upper Goulburn designated water supply catchment and according to Table 11 of the MSPs, the slope limit for harvesting is 30° and there is no minimum area qualification. Harvesting in the small area that was mapped as having over 30° slope in the coupe was therefore assessed as a non-compliance, with minor potential environmental impact (46 p. 22). The Audit’s interpretation of Section 3.5 of the Management Standards and Procedures aligns with our interpretation presented in this analysis, where 10% of net logged area exceeding 30° in slope allowed under Section 3.4 does not apply to the special water supply catchments. As a consequence of this breach, the Audit issued a non-compliance against VicForests. However, VicForests argued this as an interpretation issue and that it should not be a non-conformance. In response, the Audit further stated: The non-compliance is based on the auditor’s interpretation of the MSP [Management Standards and Procedures]. MSP 3.4.1 contains general slope restrictions, with the reference to specific restrictions for granite derived soils in in 3.4.1.3 and for water supply protection areas in Table 11 in MSP 3.5.1.1. These latter clauses do not reference the 10% of the net harvest area “exemptions” (subject to management of soil mass movement) of MSP 3.4.1.2. It is agreed that clarification on the meaning of the MSPs at this point is required, hence recommendation D6 (above) (46). The Audit recommended that DELWP review the Management Standards and Procedures with respect to the application the slope limits specified under Section 3.5 (Recommendation D6). DELWP advised that it would develop a common understanding in the form of a guidance note/clarification statement, which would be communicated to VicForests (47). DELWP also advised that slopes limits specified under Section 3.5 would also be considered as part of the review of the Code of Practice for Timber Production 2014, to have commenced 1 July 2019. However, this review was later withdrawn by the Minister for Energy, Environment and Climate Change (48) and it is unclear as to whether any guidance note/clarification statement on the logging of steep slopes under Section 3.5 has been issued. If DELWP were to allow for 10% of net logged area to exceed 30° in slope across special water supply catchments, we argue that this would equate to a weakening of the Management Standards and Procedures and therefore the Code of Forest Practices. 4.4 Implications for forest management Steep and rugged terrain is economically marginal at best and one has to question why such forest is being logged at the risk of compromising important water catchment values for the wider community. It presents a higher risk for forestry workers and contractors on site (49). We have been

39 advised that the increased risk as well as the construction of snig tracks and cuttings required on steep and rugged terrain increases cost compared to logging carried out on less rugged terrain. The Victorian Government has struggled to meet previously committed log yields to industry. In recent years, we have seen a reduction in log yields resulting from previous overcutting and recent bushfires (50). The Victorian Government is also bound under the Forests (Wood Pulp Agreement) Act 1996 to provide set volumes of pulplogs to Australia’s largest paper manufacturer until the year 2030 (51) (coincidentally the year that the government plans to phase out native forest logging (1)). We can only conject that such long-term log supply arrangements are placing remaining forest areas allocated to logging under increasing pressure. 4.5 Implications under the FSC Standards The logging of steep and rugged terrain risks the integrity of the special water supply catchments. This is recognized under the Code of Forest Practice and the Management Standards and Procedures in the specification of steep slope restrictions (15). The extensive logging of steep slopes presents concerns around compliance with the FSC Controlled Wood Standard for Forest Management Enterprises (FSC-STD-30-010 V2.0) whereby it requires that critical water supply catchments not be threatened by logging operations (6). Forests provide a critical and vital role in protecting steep slopes from erosion. Remove the forest on a steep slope, the catchment becomes compromised. VicForests claims that the HCV values concerning critical water catchments under HCV4 are protected by logging not occurring on slopes exceeding 30° and that these areas form part of a protected area (13). Our analysis revealed that this is not the case. Furthermore, the media release issued by VicForests rejecting our allegations indicate that VicForests may knowingly log slopes exceeding 30⁰ across special water supply catchments by its reference of the general slope restrictions under Section 3.4 of the Management Standards and Procedures. This is in part confirmed by a media release issued by the Institute of Foresters Australia (IFA) where it stated: The very small areas of steep slopes that have been harvested as indicated in this report are unlikely to have any long term negative impact on catchment values (52). It is not clear how the IFA can provide assurance that the logging of steep slopes is unlikely to have negative impacts on the special water supply catchments. However, both media statements do not deny that slopes exceeding the limits specified under the Management Standards and Procedures are being logged. 5 Conclusion Our spatial analysis has revealed that widespread logging has occurred across nine special water supply catchments on slopes exceeding limits specified under Section 3.5 of the Management Standards and Procedures. This includes Melbourne’s largest water supply catchment, the Thomson. The logging of these steep contrasts with VicForests’ High Conservation Values Assessment of its land tenure where it claimed that slopes exceeding 30⁰ were not logged but protected under the Code of Forest Practices. This logging in effect risks the integrity of these special water supply catchments. This raises concerns around VicForests’ audit against the FSC Controlled Wood Standard for Forest Management Enterprises (FSC-STD-30-010 V2.0). The Forest Audit Program assessing compliance of logging against the Code of Forest Practices interpreted the applications of slope limits specified under Section 3.5 similarly to the interpretation presented in our analysis, which does not allow for 10% of the net logged area to exceed 30° in slope for special water supply catchments. This interpretation was to be reviewed by DELWP, yet it is unclear whether any formal advice on it has been issued. If DELWP were to allow for 10% of net logged area to exceed 30° in slope, we argue that this would equate to a weakening of the Code of Forest Practices. In summary, the logging of steep and rugged terrain must cease in order to protect special water supply catchments.

40 Acknowledgements Claire Shepherd & Tabitha Boyer assisted in editorial and other aspects of production of this report. The Authors wish to acknowledge the Gunaikurnai, Taungurung and Wurundjeri Peoples, upon whose respective lands this study was conducted and upon which their Sovereignty was never ceded. We wish to acknowledge their Elders past, present and emerging.

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