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Historical perspective by
Friends of the Gippsland Bush (FOGB)

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Submission to the Gippsland Regional Forest Agreement by Friends of Gippsland Bush. March 2000.


Friends of Gippsland Bush (FOGB) is here today to register its protest against the exclusion of native forest on public land in the Strzelecki ranges from the Gippsland RFA.

We believe this exclusion has had negative repercussions for management of timber resources on public land in the mid-Gippsland region in general.

This exclusion has once again stripped away legislative protection from the considerable biodiversity assets of the area.

Our association believes that the decision to exclude the Strzeleckis emanates from the State governmentís refusal to accept a biological meaningful definition of native vegetation and plantations in the Strzeleckis.

The following submission gives an outline of how, in recent years legislative processes have failed to protect the biodiversity values of the Strzeleckis.

Executive Summary

Exclusion from any due process has left the biodiversity values of the Strzelecki Ranges in a perilous position.

Despite recommendations, warning of the serious consequences continued clearing of native vegetation would have on this bioregion, (from independent ecological surveys and ministerial panel reports), there is no effective legislative mechanism, which protects the important ecological assets of this region.

The percentage of land set aside in reserves in the Strzelecki Bioregion does not meet the requirements of the CAR Reserve System. Its exclusion from the Mid-Gippsland RFA has severely limited opportunities to ensure a proper level of protection for the biodiversity values of the region through the establishment of an adequate and representative reserve system.

Since its inception Friends of Gippsland Bush (FOGB) has attempted to highlight the rate at which native vegetation on public and private land is being cleared for plantation establishment.

The Agreement between, Australian Paper Plantations (APP Pty.Ltd). and FOGB provides the only framework for Ecologically Sustainable Forest Management Practices in the Strzelecki Ranges Private Forestry Operations.

The Agreement provides for careful compilation of coupe plans developed by the use of Environmental Care Principles and the application of The Code of Forest Practice.

This provides a model for ecologically sustainable forest management in the Strzeleckis.

There is no reason why this model should not be applied to harvesting plantations on public and private landholdings.

FOGB submits that the agreement of the State and Commonwealth Governments through the National Forest Policy Statement, that state and local governments will provide a planning framework that facilitates the development of large scale, industrial plantations by "ensuring that impediments to plantation development are minimal . . . " is fundamentally flawed.

The timber industry has NOT demonstrated a capacity to comply with the Code or the specific requirements of the planning scheme. In such circumstances any attempts to reduce the level of planning control, through such mechanisms as those proposed by the Gippsland Pilot Study Timber Harvesting (coupe) Plan Certification, cannot be justified at this time.

FOGB has for the past four years documented instances where serious breaches of The Code Of Forest Practices and municipal schemes have occurred and where the Responsible Authorities have failed to administer their duties as specified under section 14 of the Planning and Environment Act.

The activities of the timber industry pose threats to the biodiversity values of the Strzelecki Ranges.

In an area so depleted of its original vegetation cover there is an urgent need to protect any remnant ecological systems.

Historical Perspective

From a biodiversity perspective the history of land use in the Strzelecki Ranges, since European occupation, is not an enviable one. A number of mammal species, which include, the Tasmanian Bettong, the Red Bellied Pademelon and the Tiger Quoll are (presumed) extinct.

Australia is party to the 1992 International Convention on Biological Diversity and is thus committed to the conservation of biodiversity and to the sustainable use of ecosystems, species and genetic resources.

Unfortunately land use in the Strzeleckis is still mismanaged. The decline of the Regionís environmental values continues at an alarming rate.

The RFA process overlooks (presumed) extinctions in the Strzeleckis, the history of local extinctions and the impact on local ecologies. This is a major flaw in the RFA process with respect to managing for biodiversity values in timber production areas.

Failure of the legislative process to protect the biodiversity values of the Strzelecki Ranges.

Policy and legislation in Victoria provides clear direction for government to include concerns for biodiversity conservation in the decision- making process.

Section 14 of the Planning and Environment Act 1987 specifies the following, in the duties of a responsible authority:

(a) to administer and enforce the planning scheme; and (aa) to enforce any enforcement order or interim order relating to land covered by a planning scheme for which it is the responsible authority.

Section 4 of the Planning and Environment Act specifies that one of the main objectives of planning in Victoria is "to provide for the protection of natural and man-made resources and the maintenance of ecological processes and genetic diversity."

Section 6 (1) (b) further states that a planning scheme "may make provision which relates to the use, development, protection or conservation of land."

Clause 7-4.1 of the State Section of the Planning Scheme provides that a permit is required to remove, lop or destroy native vegetation.

Despite these requirements, over the past four years apparent breaches concerning native vegetation clearance have gone unchallenged by the two councils that are the responsible authorities for much of the Strzelecki Ranges.

The Code of Forest Practices for Timber Production- has been incorporated into the State Section of the Planning Scheme. The Code sets minimum standards for all timber operations in Victoria and provides guidelines and Statewide minimum standards of environmental care.

The Code emphasises that prescriptions will be primarily set at the local level in recognition of variable conditions across Victoria.

Clause 8-6.2 of the State Section of the Planning Scheme relating to timber production on Crown Land specifies that all requirements of the planning scheme apply to leased Crown land.

Clause 8-6.2 also provides that all timber production must comply with the Code to the satisfaction of the Responsible Authority. As set out in section 7 of the initial submission, both the 1996 AMCOR Panel and a report from an independent ecologist, (who was involved in the drafting of the Code of Forest Practice,) have questioned the extent to which the code, and therefore this requirement of the planning scheme, is being complied with.

Exemptions for Clearing of Native Vegetation.

While clause 8-6.4 of the State Section of the Planning Scheme lists exemptions from the requirement to obtain permits to clear native vegetation under Clause 7-4 if land is to be used for timber production, these exemptions apply only in certain specific and limited circumstances.

While it is understood by FOGB that Hancock Victorian Plantations claim that the native vegetation they are clearing is exempt under this clause, the specific exemptions do not apply in the instances raised by FOGB with the Shires.

Exclusion from the RFA

It seems that historically it has been difficult to gain a wide acceptance, in Government and Government instrumentalities, of the biodiversity values of the Strzelecki Ranges.

In 1999, in response to public pressure the State Government acknowledged that it was inappropriate that the Strzelecki Ranges be treated as a part of the Southern Fall Bioregion. The natural characteristics of the Strzeleckis were sufficiently distinct to warrant recognition of the area as a separate bioregion.

During 1995 the Commonwealth and Victorian Governments undertook a process of identifying Interim (or Deferred) Forest Areas to provide interim protection while the RFAís were being completed in Victoria. The then Strzelecki State Forest was identified as an Interim (or Deferred) Forest Area, the same forest that the Victorian Government privatised and leased in perpetuity to Hancockís.

The percentage of land set aside in reserves in the Strzelecki Bioregion does not meet the requirements of the CAR Reserve System. Its exclusion from the Mid-Gippsland RFA has severely limited opportunities to ensure a proper level of protection for the biodiversity values of the region through the establishment of an adequate and representative reserve system.

The Strzelecki Bioregion is more than a big tree farm made up of plantations and "degraded scrub". The Strzelecki Ranges contain extremely important, cultural heritage and environmental assets, including rare and threatened species.

Mapping Deficiencies

It is disappointing that the Ecological Vegetation Class mapping of State Forest for the Mid-Gippsland RFA was done predominantly at a scale of 1:100,000. Those areas mainly south of the Princes Highway that have been mapped at 1:25,000 are vastly superior in detail and accuracy. More funding is required so that further mapping can be undertaken at a scale of 1:25,000 north of the Princes Highway, to provide greater detail and accuracy for ground truthing.

Our association believes that the plantation maps presented by industry have areas of flawed methodology, and are a result of commercial expediencies rather than biological realities. For example industry maps exclude Riparian Vegetation Communities and Cool Temperate Rainforest.

To ensure a reasonable level of detection of Rainforest EVCís (that includes listed communities and species) funding needs to be made available for a project, mapping at a scale of 1:10,000.

This will clarify the boundaries of Cool Temperate Rainforest and surrounding plantation/native vegetation. Thus enabling better management of rare and threatened plant and animal species found in these communities

Despite the exclusion of the Strzeleckis from the RFA, areas mapped as EVC class Wet Forest in the Strzeleckis will have to be used to make up the percentage target for the pre-1750 distribution of this forest ecosystem, as required by national reserve criteria. The shortfall in the target percentage for the EVC Cool Temperate Rainforest a Rare Ecological Class (60%) will also have to met outside the public reserve system.

Outside the Central Highlands the most important sites for Mountain Ash Wet Forests and Cool Temperate Rainforest are those of the Strzelecki Ranges. The Agnes Reserve is registered on theNational Estate and College Creek has been designated a site of State significance.

The timber industry has superimposed its land use (plantation) maps onto the botanical map depicting the Strzelecki Ranges Wet Forest EVCís. (Refer to map 2 Extant Ecological Vegetation Classes).

The Strzelecki Ranges Old Growth Forest has been ignored on industry and RFA maps. The entire area being represented as Private land and land Leased for plantation purposes. (Refer to map 4 Old Growth Forest)

In contrast, the Draft Land Use Map 1 Gippsland RFA, only highlights (in purple) leased or licensed land for plantation purposes without clearly marking the amount of private land, owned by APP. If this area were included on the land use map, it would more accurately demonstrate that, the bulk of the areas of native bush in the Strzelecki Ranges are controlled by the timber industry.

These inconsistencies in the RFA maps stem from the failure of the State and Federal governments in consultation with industry to accept EVC mapping of the Strzeleckis based on biologically meaningful definitions

I would like to make a few general comments about the draft Car Reserve System (Map1 Gippsland RFA Draft Land Use). On the face of it there seems to be generous extensions to the Reserve System. Unfortunately many of these additions seem to be fragmented isolated patches.

To what extent has scientific knowledge of Reserve System Design been utilised in drawing these boundaries? (When making final decisions).

It is difficult to judge (without detailed scientific data) if these extensions are "useful", in conserving the ecological integrity of particular sites.

These concerns can be exemplified when viewing botanical data, from 1984, in the:

Mullungdung Forest- An area of 280-300 square km. was considered to be of Regional significance.

Gellions Run Ė An area of 25 square km. was considered to be of National Significance.

Hedley Range- An area of 20 square km. was considered to be of Regional Significance (to be considered in conjunction with Gellions Run).

One would expect the RFA process to consolidate these sites of significance to enhance their ecological assets. They were obviously considered to be of high significance to be added to the reserve extensions. However, for Mullungdung and Hedley Range the areas remain fragmented with the General Management Zones remaining in place.

It seems in some instances the logic for designating these reserves and boundaries has been driven by timber based values and not based on sound conservation principles.


A process like the RFA has offered the chance of introducing a level of accountability for protection of biodiversity assets, for the native forests on public land, in the Strzeleckis.

This valuable opportunity has been lost.

The State government has made a commitment to "Review "the situation in the Strzeleckis. The community will not be satisfied until the framework of that review is fully scoped and a firm time line set in place. The Government must give an adequate commitment from its budget to fund this process.

The time frame for the present Central Gippsland RFA should be extended, and not "signed off" until people are confident that due process has been followed and a balanced approach to land use has been achieved.

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