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Cool Temperate Rainforests

October 2006 Strzelecki Rainforest announcement: Key rainforest catchments to be immediately protected include; Agnes River, Franklin River, College Creek, Jack River, South Middle Creek and Merrimans Creek. As well as logging being stopped in these catchments, buffer zones of 60m and 100m will be granted on rainforest in the Morwell River and Albert River catchments. May 30 2008 Strzelecki Rainforest Announcement (making the October 2006 announcement redundant) now means bugger all protection for rainforest outside of Gunyah Gunyah.

Google Earth Image of Morwell River East Branch, highlighting cool temperate rainforest (in green). Rainforest buffer destruction on a catchment scale. All of the logging of rainforest buffers in this image has occurred post FSC certification. Morwell River East Branch Rainforest is regionally significant, College Creek is a site of state significance for its rainforest attributes and national conservation significance for its conservation attributes. This kind of practice would not be allowed elsewhere in Victoria.

Rainforest and Cool Temperate Rainforests of Victoria

"Rainforest is protected throughout Public Land in Victoria, either by inclusion in the formal conservation reserve system or by a range of measures, including zoning and prescriptions.

Sites of significance have been delineated, described and rated (Peel 1999, Cameron 1990) and contribute towards he design of Reserve systems within all Forest Management Area Plans. These have been assessed by considering the following attributes: ecological integrity and viability, floristic composition, biogeography, and representation. They have been ranked according to their National, State, Regional or Local significance. Core zones which may contain Rainforest stands, have been identified. These have been updated in the Strzelecki Ranges by Hill and Timewell 2001.

Areas of rainforest MUST be defined and a strategy for their management MUST be included as part of planning for conservation of flora and fauna in Forest Management Plans and / relevent prescriptions.

In the absence of detailed strategies within an approved Forest Management Plan, which address Regional characteristics, the following minimum prescriptions will apply.

*Stands of lesser significance 40m buffers

* Stands >20% Nothofagus buffers of 60m

*Sites containing Nationally significant Rainforest, generally subcatchment protection.

Forest Management Plans have been prepared for Otways, East Gippsland, Central Highlands and Gippsland.

In the Strzelecki Ranges, Rainforest occurs on Public Land licensed to Hancock Victorian Plantations. HVP is working with Department of Sustainability and Environment, Trust for Nature and community groups to develop and implement a management framework to ensure the long-term protection of rainforest on their land and to establish habitat links on adjoining land."


Strzelecki Cool Temperate Rainforest (in red)

Click here for: Rainforest Hotspots Jeeralang Creek East Branch Morwell River East Branch

Peer Review of Proposed Rainforest Best Management Practice (October 2005/April 2006)

Smartwood/FSC Audit Results 2004 - 2005 - 2006 - 2007

Cores and Links Reserve and Rainforest Map

Private land and Cool Temperate Rainforest

Public Lands Native Forest

Private land native forest and all plantations

Forest Management plan for Gippsland

Conservation Guideline Cool Temperate Rainforest and Warm Temperate Rainforest

Working definition of rainforest Ecological Vegetation Classes in Gippsland

Rainforest Indicator Species


Draft Flora and Fauna Action Statements

Slender Tree-fern Cyathea cunninghamii (including references to skirted Tree-fern Cyathea X marcescens)

UPDATE - Myrtle wilt
Strzelecki Cool Temperate Rainforest (Red). Approximate Hardwood Reforestation in Yellow.

Smartwood/FSC Audit Results

2004 Audits

March 2005: FSC auditors, working for Smartwood about to enter cool temperate rainforest at Morwell River East Branch. Photo & Caption: Hancock Watch

CAR#1: CAR1-2004 Reference Standard#:6.1, 9.1

For full copy of audit see here

Applicable finding from Monitoring Report (June 2004): "During the orginal assessment, SmartWood raised concerns that the then proposed minimum buffers (e.g.40 metres) proposed for the protection of rainforest might be inadequate. Some stakeholders and experts believe that the new draft BMP may provide even less protection (e.g. a nominated 10 meter buffer that could be one quarter of the width required by the Code of Forest Practices in native forests for stands of rainforest with lesser significance, i.e less than National conservation significance). There are also inconsistencies with the recommendations for the conservation of rainforest identified in the Strzelecki Ranges Biodiversity Study (a minimum of two tree heights or about 100 meters). Currently, until the BMP is complete, HVP is actively seeking stakeholder input and consultation on the design of buffers, though some stakeholders are increasingly uncomfortable with this approach - they would like to see the BMP completed and thus the design of buffers handled completely by HVP staff, based on technically sound guidance." (page 6)

"Ultimately, based on SmartWood experience worldwide, it is likely that a strict quantitative buffer (e.g. 100 meters) will not be the appropriate solution; rather a technical solution that varies the buffer, possibly based on forest composition and structure, slope or other variables. These issues are of such importance and urgency that they heighten the importance of completing the BMP for rainforest management as soon as possible, but at the same time ensuring that a high quality, technically sound product results, with strong independent peer review and stakeholder input. Until this BMP process is completed, on-the-ground management activities by HVP are expected to take a strongly "precautionary" approach, erring on the side of larger, rather than smaller, buffers. Also HVP should continue to seek stakeholder input for the design of current buffers, as it has done recently, though other mechanisms should be explored as some stakeholders may not be able to continue to provide such inputs under the current system". (Page 6)

September 2004: Strzelecki Ranges North Face (Parish of Jumbuk - Crown Leasehold): Morwell River East Branch Rainforest off Lawless Track. Hancock have logged within 15 metres of cool temperate rainforest at this site. The person holding the tape in the gully is standing next to a Myrtle Beech tree. Rainforest of regional significance occurring in State Forest is granted at least 40 metre buffers. Yet Hancock at this site has granted 25 metre less than what is warranted in State Forests. This has occurred despite Hancock being granted FSC certification. Photo & Caption: Hancock Watch

"During the audit it was clearly noted (discussed under Criterion 9.3) that the then proposed minimum buffer of 40 meters proposed for the protection of rainforest was inadequate. The BMP appears to have been revised since to provide even less protection for this HCVF. The nominated 10 metre buffer for rainforest identified by the BMP will probably not survive any acceptable peer review. The nominated 10 metre buffer is one quarter of the width required by the Code of Forest Practices (in native forests) for stands of (rainforest) with lesser significance (less than National conservation significance). It is also inconsistent with the recommendations for the conservation of rainforest identified in the Strzelecki Ranges Biodiversity Study (a minimum of two tree heights or about 100 metres). (page 16)

Corrective Action Request: The Rainforest Management BMP shall be completed by 1 March 2005 including and independent peer review and further stakeholder input. The current accepted practice of stakeholder involvement in boundary marking is to continue with coupes where HVP harvests plantations adjacent to any areas of Cool or Warm Temperate Rainforest.

Timeline for Compliance: By March 1, 2005

Audit Findings 2005

April 2005 Strzelecki Ranges Ryton Junction - Coupe located in the Albert River catchment between Minottis and Waack Track. Gutting of cool temperate rainforest gully. A buffer of 20 metres had been granted at this coupe to Myrtle Beech within this gully, effectively leaving no rainforest buffer at this site. This site was logged during or just after the most recent audit of Hancock's operations carried out by FSC certifier Smartwood. Photo & Caption: Hancock Watch

Audit findings: At the time of the annual audit in March 2005 and by the time of completion of the draft audit report on June 2005, HVP had developed a substantial series of documents that integrate to form the Rainforest BMP (RF BMP).

These include Rationale for the rainforest BMP, Company rainforest policy, Procedure for management of rainforest on Company land, Operating standard for the evaluation of conservation significance of rainforest on Company land, and Operating standard for the protection of rainforest on company land.

At the time of the audit, HVP had not completed the RF BMP. The primary outstanding items required in the CAR to be met by March 1, 2005 were independent peer review and further stakeholder input. At the current audit, the draft RF BMP available during the SW monitoring audit from June 2004 had been revised, but was not completed in a form ready for external peer review. The draft had been reviewed internally by some HVP staff and by a company director who is also a professor at the University of Melbourne with expertise in rainforest identification.

At the time of the annual audit, HVP anticipated that the document required some additional revisions but was very close to being ready for external peer review. One potential peer reviewer had been contacted. A second peer reviewer had been identified, but had not been contacted. The potential date for completion of peer review was unclear and depended very much on the availability and time requirements of suitable peer reviewers to review it. In May 2005, HVP advised the audit team that the document had been sent to one of the identified peer reviewers but the company had not received any comments. The second peer reviewer could not complete a review in a reasonable time and HVP was searching for another potential reviewer. Further communications with HVP indicated that the company was steadily progressing and seriously engaged in efforts to contract suitable peer reviewers with the requisite ecological background and availability to complete the peer review in a timely manner.

At the time of the annual audit, written terms of reference for peer review were not given to the audit team and the auditors were left in doubt as to the scope and methodology to the peer review. Since the audit, HVP have shared with SW staff the letters being sent to potential peer reviewers. These letters were not a formal TOR and would benefit from being more complete and explicit in defining the brief for the peer reviewer.

At the time of the audit, HVP had not made clear plans for how it would go about "further stakeholder input" once peer review was completed and addressed by the company. HVP did plan to take an internal cost analysis of the results of the peer review process to the Board for review before making any further commitments in regard to the BMP.

Overall, while the company had compiled the core documents of the RF BMP in a draft state that would be suitable for peer review, not at the time of the audit, but a few months afterwards, the process and the timetable for completing the peer review were not clear to the audit team during their inspection. Subsequent communications indicated that the timetable appeared to be on the order of at least six months after March 1.

In addition, during the annual audit, the state government indicated its intention to release a draft "Faunal and Flora Action Statement" on cool temperate rainforests of Victoria for public comment, which HVP receive on May 12, 2005. In May 2005, HVP advised the audit team that they had received a first draft of three Action Statements related to cool temperate rainforest and were reviewing those document to see how they would affect the HVP BMP.

The second requirement of the CAR was that "the current accepted practice of stakeholder involvement in boundary marking is to continue". The practice of including a stakeholder in boundary marking only happened in one coupe and stopped soon after the audit in June 2004 when the individual involved no longer wished to participate. No stakeholders have participated in any boundary marking since that time and HVP has not found a replacement person or sought to establish an alternative procedure in the interim while the RF BMP remains unfinished.

Representatives of the shires told the audit team that the width of rainforest buffers is a highly contentious public issue, but that HVP has not sought public input. HVP stated that the company would welcome such input provided that the shires referred enquiries directly to forest managers who could coordinate safe visits to coupes. The audit team considered the lack of stakeholder involvement in boundary marking a serious breach of the CAR. However, there are stakeholders who communicated to SmartWood in the past that it was not feasible or realistic to expect stakeholder involvement in coupe layout.

It is the opinion of SmartWood that the process of finalizing the RF BMP would be the best means to resolve these issues, even though the company should remain open to stakeholder involvement in RF boundary issues in coupes, should it be requested, provided it was done in a safety-conscious manner.

Since the last audit, HVP has established RF boundaries based on the existing internal policy and procedures, which the team understands provide for 20 meters from the defined edge of the rainforest. The auditors visited one coupe where it was clearly precisely 20 meters but where trees had been felled into and removed from that 20 metre buffer causing some damage to the buffer and to rainforest trees. HVP representatives told the audit team that numerous other coupes are laid out with similar 20 metre buffers.

This is not consistent with the comments of the SW auditors in the June 2004 Monitoring Audit Report. That report states "Until this BMP process is completed, on-the-ground management activities by HVP are expected to take a strongly "precautionary" approach, erring on the side of larger, rather than smaller, buffers" and that a proposed minimum buffer of 40 metres proposed for the protection of rainforest was inadequate". Certainly, a number of differences remain unresolved between independent experts and stakeholders on one hand, and the company on the other, regarding what is to be considered appropriate buffer width.

For three reasons: 1) an unfinshed RF BMP and external peer and public review process, 2) the discontinuation of stakeholder participation in boundary marking, and 3) current boundaries that are much less than 40 metres - the team concludes that HVP has not met the requirements of this CAR.

The audit team concludes that there is a major non-compliance with the requirements of the CAR. In these circumstances, FSC requires that a Major CAR with a deadline of 3 months be imposed. In the audit team's opinion, a 3 month deadline to complete a BMP following peer review and further stakeholder input that includes appropriate buffer widths is impossible to meet.

SmartWood proposes a MAJOR CAR to require completion of the BMP with peer review and external public review, including review of proposed buffer widths, by the end of 2005.

The assessment team proposed a MAJOR CAR to require HVP to immediately do either:

- Cease operations in all coupes that are adjacent to rainforest; or

- Put in place a minimum two tree height (100 metre) buffer on all rainforest sites where active operations continue while the BMP is being completed.

In review of this proposed CAR, SmartWood disagreed with the team's suggestion to impose a more prescriptive CAR to address the original, yet unmet, CAR 1/2004. As this original CAR was clearly justified and defined to meet an identified nonconformance, then SmartWood procedure would be for the unmet CAR to have been classified as "OPEN" and then to raise the noncompliance to a Major CAR with 3 month, or in exceptions, 6 month timeline to meet the main elements of CAR 1/2004.

Status: The requirements of the CAR had not been met. One MAJOR CAR was imposed.

Follow-up Action: MAJOR CAR 9-2005 By the end of 2005, HVP shall complete the Rainforest BMP with peer review and external public review, including review of proposed buffer widths, and be implementing the BMP.

September 2005 - Strzelecki Ranges: Morwell River East Branch. Allotment 57 Parish of Wonyip. Ex Australian Paper Plantations Leasehold, which Hancock purchased the logging rights for in 2001. The southern portion of this logging coupe, logged in June/July 2005 has rainforest buffers of 15 metres. This could well be the worst case of rainforest mismanagement in Victoria and the operation has been certified by the Forest Stewardship Council!!! Much of this coupe should never have been logged at all. Photo & Caption: Hancock Watch

2006 Smartwood Audit (August 22, 2006)

Audit Findings:

Following the 2005 audit, HVP selected and engaged two experts to review the companies' draft Rainforest BMP, including the proposed widths of buffers. The review was completed and was submitted to the Company in October 2005. It is a lengthy and very detailed review that addresses many considerations and issues related to the management of cool and warm temperate rainforest in HVP holdings. The audit team recognizes that HVP undertook this review in a very significant way and sought out two respected experts in this field. It is clearly an expert review, rather than a peer review. HVP provided substantial resources and assistance for the reviewers and they received a very thorough, well-documented and well-reasoned 32 page report in return. The fundamental conclusion of the two experts is that the buffers in the draft BMP for both cool and warm temperate rainforest are "inadequate", particularly where, as in FSC Principle 9, a precautionary approach is required.

HVP responded to the review report in early November 2005 by sending the reviewers an annotated version of the report containing a substantial number of points where HVP disagreed with the report. At the time of the audit in March 2006, HVP provided the audit team with an expanded list of points, but these additional points had not been sent to the two expert reviewers. Since the HVP response in November, there has been no other communication between HVP and the experts and the draft BMP has not been completed or revised.

September 2006: Hancock still leaving only 20 metre rainforest buffers atSmiths Creek.

The audit team reviewed the experts' report and the HVP response and interviewed both experts and the HVP staff who were directly involved. The two experts told the team that they consider their report to stand on its merits. They acknowledge some of the points raised by HVP but dispute others, and do not feel that any of the points change the fundamental conclusion of the report regarding the width of rainforest buffers. HVP told the team that they would like the expert report to be revised to address their disagreements but acknowledge they have not pursued this request since November. The team concluded that while there are disagreements over some points of detail in the review, HVP has not disputed the major conclusion of the review that the existing BMP is inadequate to meet the requirements of Principle 9 of the FSC Standard.

Despite the conclusions of the expert review, HVP has taken no action to revise and complete the BMP. They provided the audit team with a 5-page outline of the company response to the expert review, but it does not appear that any of the proposed responses have been undertaken and the responses do not include revisions to the buffer widths or acknowledge the conclusion that they are "inadequate". HVP has also not sought any outside public review of the draft BMP, as required by the MAJOR CAR, and has also not sought any outside public review of the draft BMP, as required by the MAJOR CAR, and has not made the report of the expert reviewers, or HVP's proposed response, available to anyone outside the company. No external public review has been initiated or completed at the time of the audit.

The team notes that HVP has also not taken any actions to contact the two experts to follow up on their initial response in November 2005. The rainforest BMP remains in the same draft form it was at the time of the 2005 annual audit.

Finally, HVP is continuing to apply the same, or in some cases narrower, buffer widths as in 2002 and 2004 when the original SmartWood assessment report and the monitoring audit described those buffers as "inadequate" and imposed CAR-2004 to establish a process to determine adequate buffer widths. That CAR was not met in 2005 and led to MAJOR CAR 9-2005 being imposed then.

The team concludes that for the three reasons above - failure to complete the BMP, failure to engage in external public review, and failure to implement revised buffer widths for rainforest when the expert review describes the current widths as "inadequate" - HVP has not met the requirement of the MAJOR CAR. Essentially, from an auditing point of view, this is where the matter finishes. Guidance to auditors from FSC and SmartWood states that a MAJOR CAR must be closed out or the certificate will be suspended. In this case, the team concludes that the MAJOR CAR is not closed and the failure to meet it is significant. The team does not accept that there are major extenuating circumstances that contributed to the delay in responding to the expert review which was completed in October 2005. Those delays, since October 2005, were internal within HVP. SmartWood and FSC policy therefore requires that, until the BMP meets the requirements of Principle 9, the Company's continuing certification should be suspended.

December 2006: Chainsawed Myrtle Beech - Morwell River East Branch

The Company makes the case that this CAR cannot be considered in isolation. Application of the BMP has serious implications to the Company's resource availability in the Strzelecki area of its operations because many of its plantation stands are contiguous with cool temperate rainforest. For example, part of the Company's resource (the 'Cores and Links') has been under a voluntary moratorium on harvesting because of these associated values. Recent modelling of woodflows from the whole GRP resource has shown that future contracted commitments cannot be met without harvesting of plantation stands within the Cores and Links. While the audit team accepts this connection, the presentation on resource availability made to the audit team did not demonstrate that buffer width on rainforest was a 'go' or 'no go' variable in meeting commitments. In fact the modelling demonstrated that the Company would have to implement both the exisiting (inadequate) BMP and harvest almost all the plantation in the Cores and Links to meet its contracted commitments.Thus, the shortfall and Cores and Links situation does not give the Company any reasonable excuse to avoid its commitment to deal with the expert review of the BMP. The only way out of the resource impasse would be to find alternative sources for woodflows so that the resource can meet commitments when the BMP is modified to meet the requirements of the expert review.

In addition, the company is concerned that a Draft Action Statement on Temperate Rainforest is under public review and it does not want to take action in advance of the finalization of that Action Statement. The audit team does not accept that this is a reason to delay implementation of provisions to meet FSC requirements in Principle 9.

Following the field audit, further information and evidence was provided to SmartWood that resulted in a determination that this MAJOR CAR had technically been met, however due to the poor wording of the CAR the intent has not been met. Thus, this CAR is closed out and a new MAJOR CAR2-2006 has been added that will be audited in February 2006 for completion. HVP has been advised that failure to meet the MAJOR CAR within that time frame will result in suspension of their certificate based on requirements of FSC.

February 2007: Rainforest indicator species found within mere metres of cut stumps - Morwell River catchment.

Status Closed:

Follow-up Action: MAJOR CAR2-2006. Within five months, HVP shall demonstrate the following:

*A technically rigorous and thorough revision of the current Rainforest BMP has been completed; this revision should incorporate the specific recommendations of the peer review and other technically sound inputs gathered through public review, and, where applicable, a clear rationale as to why specific recommendations proposed by peer review or other inputs have not been accepted by HVP;

*A revised BMP is provided to all HVP staff and contractors involved in their implementation;

*Full implementation of the revised BMP has formally started; and,

*A specific monitoring programme related to the Rainforest BMP is in place that will be able to provide systematic information on HVP performance in attaining Rainforest BMP conformance.

Observation 2-2006: The team recommends that HVP do either or both of:

*finding alternative sources of wood flows or alternative treatment regimes so that the resource can meet commitments when the BMP is modified to meet the requirements of the expert review; or

*approaching the company needing supply from the Strzelecki area to determine if there is any possibility of restructuring the current supply agreement based on results of the current models.

2007 Smartwood Audit (26 November 2007)

p10-13 Assertions about the Heads of Agreement for the Cores and Links, inadequate buffers along coll temperate rainforest and breaches in the Strzeleckis

During the audit, several stakeholders raised concersn about the Heads of Agreement (HoA) in regards to inadequate buffers along Cool Temperate Rainforest (CTR) and breaches of the HoA from two harvested coupes within the 'Harvest Area'. SW accepts that the HoA is a major development from the previous annual audits, and the rationale behind the proposal has been summarised in the 2006 annual audit. This annual audit focused on evaluating HVP's compliance with Corrective Action Requests that SW has imposed in past audits, and evaluating HVP's compliance with the FSC standard (as set out in the SW standards for Australia). SW will investigate correspondence and consider matters in regards to the HoA, as the outcome of the HoA is likely to have a significant bearing on issues that are important to HVP's FSC certification i.e protected areas, High Conservation Value Forests (see discussion of Principle 9 below), and rainforest buffers. However, the audit team considers that much of the discussion and controversy that the HoA is generating is between the parties to the agreement, and not directly related to the FSC standards. Therefore this annual audit report does not provide any findings about any concerns for the process of completing the Heads of Agreement.

Some specific issues raised by stakeholders in regard to the HoA relate to harvesting within Radburn Road and Grey Gum Track 2. The audit team visited both of these coupes to investigate the alleged breaches and also interviewed HVP staff in regards to these matters. The HoA sets out specific arrangements and agreements including harvesting regimes, minimum buffer requirements for mapped CTR, consultation etc, in order to establish Harvest Areas and Reserve Areas and to harvest within Custodial Land and Harvest Areas (p3 and 4, HoA).

Rainforest Gully off Radburn Road Jan 07: Hancock is redefining rainforest out of existence in order to log all eucalypt buffers.

At Radburn Road, stakeholders alleged that part of the Cool Temperate Rainforest (CTR) buffer in the coupe, which the HoA states should be a minimum of 60 meters, had been harvested. However, based on discussions with HVP their interpretation of the situation was that the buffer width is based on the Company's CTR Best Management Plan (BMP), which is 30 metres. As was evident from this example there appears to be a misunderstanding and/or disagreement between what is or isn't CTR, and what buffer width is or isn't applied to unmapped CTR. If CTR is identified by HVP staff, but not shown on the mapped attached to the HoA, then HVP are using the buffer width stated in the Company's CTR BMP, rather than the HoA. Contrary to this, the stakeholders believe that any CTR remnants (regardless of 'mapped' status) in the HoA area should be afforded a minimum of a 60 meter buffer. It should be noted that is was agreed by all parties, that where CTR in the Heads of Agreement occurs on the ground, a 60 meter buffer would be applied.

The audit team examined one location within this coupe where rainforest was present, and the buffer was greater than the buffer stipulated in the Company's CTR BMP, but not as wide as the HoA minimum buffer width. However, the investigation of one site is not considered a sufficient sampel size and therefore, no conclusions can be drawn from this examination.

At Grey Gum Track 2 and adjacent land, it was alleged that known (previously mapped) areas of CTR had been removed from the mapped attached to the HoA, HVP maps and coupe plans, and therefore areas of CTR buffer were being harvested and CTR was not being afforded the protection agreed to in the HoA. However, based on discussions with HVP staff their interpretation of the situation was that the vegetation of the land was not CTR, based on ground-truthing by their staff and consultants, and therefore some of the previously mapped CTR areas had been removed. Further, HVP susggested that one of the mapped CTR polygons was the result of a mapping eroor from previous data transfer. Once again it was evident from this example that there appears to be a misunderstanding and/or disagreement between what is or isn't CTR.

The defintiion of what is or isn't CTR and where the CTR boundary lies in relation to other forest communities is not a recent contentious point. In the past, on public land, similar issues have also been expressed. In recognition of this the 'differential species' technique has been devised by the State Government's CTR expert, which aims to eliminate any doubt in CTR EVC identification and boundary locations. Both HVP and stakeholders have participated in CTR training in the Strzeleckis (on some occasions both parties were in attendance), which was undertaken by the CTR expert. Three important modifications were expressed during training, along with the standard differential species technique. All are to be considered when applying the differential species' technique for use in the Strzeleckis, in comparison to other CTR remnants across the State.

These modifications, which were developed to assist with the definition of CTR in the Strzelecki, include:

1) the requirement for a number of CTR individuals or a population of a certain species to be present i.e. not just an individual of a certain species;

2) the earliest life forms i.e. seedlings are not included; and,

3) the presence/absence of CTR cannot be determined at recently distrurbed sites and/or grossly modified sites i.e. after a recent fire or a recent gap in the canopy.

Further, several species were added or removed from the species lists for CTR and for other forest communities, in order to 'fine tune' the technique for the Strzelecki.

All parties need to be abreast of these modifications and to apply them in a standard manner. Based on an interview with the State Government CTR expert, if they applied as instructed during training, then there should be no discrepancies between any parties for CTR EVC identification and locations of boundaries.

The audit team examined one location within Grey Gums Track 2 where unmapped rainforest was present, and the buffer was greater than the buffer stipulated in the Company's CTR BMP, but not as wide as the HoA minimum buffer width. However, the investigation of one site is not considered a sufficient sample size and therefore no conclusions can be drawn from this examination. It should also be noted that mapped CTR was identified on the harvest plan for Grey Gum Track 2, and the site diary notes that 60 meter CTR buffers were marked in the field. Although the audit team did not examine all the CTR buffers, the site diary does indicate early on that HVP checked the CTR buffere with the Latrobe Shire and they were 'happy'.

In summary, based on submissions to Smartwood during the audit, it is apparent that there are still some significant misunderstandings and disagreements among the parties about details related to the application of the provisions of the HoA for buffers along Cool Temperate Rainforest. This is not unexpected in a draft agreement but will need to be worked out between the parties in the coming months, and will be reviewed in the next annual audit.

Observation 4/07: The audit team recommends that HVP consult with all stakeholders associated with the HoA, prior to removing any mapped CTR from maps in the future, and clearly define potentially contentious isssues in the HoA, such as how mapped and unmapped CTR remnants are treated.

p22 CAR 2 - 2006 Reference Standard #:9.1

Description of Non-compliance: "For three reasons: 1) an unfinished RF BMP and external peer and public review process,

2) the discontinuation of stakeholder participation in boundary marking, and

3) current boundaries that are much less than 40 metres - the team concludes that HVP has not met the requirements of this CAR." Annual Report, 2006.

Corrective Action Request: HVP shall demonstrate the following:

* A technically rigorous and thorough revision of the current Rainforest BMP has been completed; this revision should incorporate the specific recommendations of the peer review and other technically sound inputs gathered through public review, and, where applicable, a clear rationale as to why specific recommendations proposed by peer review or other inputs have not been accepted by HVP;

*A revised BMP is provided to all HVP staff and contractors involved in their implementation;

*Full implementation of the revised BMP has formally started; and,

*A specific monitoring programme related to the Rainforest BMP is in place that will be able to provide systematic information on HVP performance in attaining Rainforest BMP conformance.

Timeline for Compliance: Within five months of the finalization of this annual audit.

Audit findings:

At the beginning of this audit, HVP gave the audit team a revised Rainforest BMP (policy and procedures, and operating standards) along with a Rainforest BMP rationale, a Field Determination of the Boundary of Rainforest document, the peer review of the HVP response, an eight page document which details how the Corrective Action Request (CAR) has been addressed, and sveral sheets detailing the preliminary results of the rainforest monitoring.

In regards to the first dot point of this CAR, HVP consulted two rainforest experts in 2005 to peer review the companies' draft Rainforest BMP. This peer review report was submitted in October of that year. This review was a lengthy and detailed analysis of the draft Rainforest BMP, and generally concluded that the Companies' protection measures for rainforest were inadequate. HVP responded to the peer review in early November 2005, and during October 2005 and April 2006 minor amendments were made to the peer review, but the Rainforest BMP was not completed. Thus the MAJOR CAR was imposed.

During this audit, the audit team interviewed one of the authors of the peer review report and HVP staff involved with the Rainforest BMP, and confirmed that no further revisions in response to the peer review had been discussed with the authors of the peer review since April 2006. However, HVP have now produced a revised Rainforest BMP, which has incorporated some of the comments from the peer review (e.g. monitoring and some buffer widths) and where HVP deemed these comments to be inappropriate, they have produced a 'clear rationale' (e.g measuring 30 meter buffer widths for most regional/local remnants of rainforest, from the mid point of the ecotone and other operational procedures). There is also evidence that several stakeholders were sent the draft Rainforest BMP and responses were provided, although it is stated in a document provided to the audit team that 'no information which had not already been considered was received'. HVP also provided evidence that approximately 40% of the Rainforest on Company land will be buffered by a conservation reserve if the Cores and Links agreement progresses and a further 30% of Rainforest interface with Custodial Land.

Therefore, the first requirement of the CAR has been met, as a revision of the Rainforest BMP has been completed and some comments incorporated from the peer review. Where comments from the peer reviewers have not been incorporated, a rationale has been provided. Further, in a letter dated 16th October 2006, the revised Rainforest BMP has been reviewed by staff (not one of the peer review authors) from the Department of Sustainability and Environment (DSE), and HVP's approach to the management of rainforest has been endorsed by DSE as "being consistent with the outcomes sought in the draft Rainforest Action Statement".

The audit team has some technical concerns with the revised BMP. These include how buffer widths are measured (i.e. are they measured in the horizontal plane?), how buffer widths are determined for steep terrain and the adequacy of the buffers for some stands of rainforest. At the time of the audit, there are no references to the first two issues in either the BMP Rationale or the Operating Standard, and buffer widths are still considered "inadequate" by the experts who conducted the peer review.

These issues are particularly pertinent when considering the 'precautionary approach' of Principle 9, and both the nature of rainforest remnants in the Strzeleckis and the steep topography of the Strzeleckis. Consideration of these points would also make the Company's rainforest rationale become more aligned with rainforest management strategies for public land, and definitions under the Application of the Code - Plantations, as described in the Code of Forest Practice for Timber Production, Draft for Public Comment, February (DSE 2006). The audit team concluded that the first requirement of this MAJOR CAR has been met but the Rainforest BMP and the requirements of Criterion 6.2 are further discussed in Appendix 111. CAR 2/07 is imposed there.

In regards to the second dot point of the CAR, the revised Rainforest BMP has been distributed to all HVP staff, but not yet physically to contractors. HVP provided two valid reasons for this. They wish to progress the BMP further before distributing it to contractors and, operationally, contractors only require the coupe plans, which are supervised by HVP staff. During this supervision any information related to the Rainforest BMP are relayed by HVP staff to the contractors. The team concluded that this was sufficient to close this part of the CAR. However, the audit team belives that the requirement to distribute the Rainforest BMP to contractors has merit and should be undertaken in the near future. This has been included as Observation 8/07.

In regards to the third dot point of the CAR, interviews with HVP staff, both in Melbourne and in Gippsland, indicates that the implementation of the revised BMP has formally started.

In regards to the fourth dot point of the CAR, the audit team was informed by HVP staff that monitoring had begun on two coupes with remnant CTR present. This had been undertaken in June 2006 and February 2007. One is the Tarra-Bulga coupe and the other is Pattinson Road coupe. Parameters being assessed include buffer disturbance/integrity and the incidence of Myrtle Wilt, as per the recommendations of the peer review.

In summary, the audit team does not agree with all the suggested rationales where HVP has not accepted suggestions or comments of the peer reviewers, and feels that the recommendations from the peer review should be incorporated further into the BMP (including how buffer widths are measured, how buffer widths are determined for steep terrain, and the adequacy of buffer widths. These are discussed further in Principle 6 and CAR 2/07 is imposed there). However, it is evident that HVP have met the key objectives of this MAJOR CAR i.e they have undertaken the peer review, they have provided a rationale where they differ, and they have begun a monitoring program. Therefore the audit team has concluded MAJOR CAR 2-2006 is met and closed.

Status: Closed

See Observation 8/07

See CAR 2/07 and rationale in Criterion 6.2 in Appendix III


Strzelecki Rainforest and Proposed Cores and Links Reserve


The area between the Grand Ridge Road and Stronach's Road has been set aside as a reserve. This area is flatter than most rainforest areas within the Strzeleckis and the rainforest tends to extend in a wide band along each of the tributaries. Because of the width of the rainforest, mature and old-growth mountain ash can be found within the rainforest as well as on the spurs.

There are many examples of very old myrtle beech and sassafras and numerous skirted and slender tree ferns.

The rainforest also extends along those tributaries south of the reserve, between Stronach's Road and Red Hill Track and between Red Hill Track and Clay Track at the eastern headwaters of these tributaries.

Cool Temperate Rainforest

The terrain of the Strzelecki State Forest had the perfect balance of altitude, rainfall and climate to support the mighty mountain ash forests, unique to select parts of Victoria and Tasmania. Coexisting with the wet sclerophyll mountain ash forest and dominating the gullies were cool temperate rainforests dominated by myrtle beech and sassafras.

Last century the Victorian State Government resisted moves to open up this mountainous, thickly forested region, but during the 1890's depression, the Government was persuaded to allow selectors to lease some of this land in the highest, most misty parts of the Strzeleckis.

Selectors attempted to clear the forest by widespread ringbarking and burning off. The subsequent fires which swept through the Strzeleckis in 1898 made clearing easier and soon much of the landscape was radically altered. However, the higher hills proved to be mediocre grazing land, and from those early days of selection through to the 1930's, much of the higher ranges were abandoned and reverted back to the Crown.

From the 30's onwards, the Government has bought back more of this country, a piece at a time, and converted many areas into plantations.

The recent change to clear-felling and a short rotation time of 25 years, has removed most of the remaining mountain ash forest (destroying the biodiversity of the region and endangering the remaining native fauna). Extending plantation right into gullies and removing buffer strips round rainforests is also seriously endangering the last tiny pockets of rainforest.

Cool Temperate Rainforest - relic of Gondwanaland

Rainforest is the most complex and diverse ecosystem on earth, home to more than half of the world's plant and animal species and a valuable source of cultivated plants, drugs and medicines.

Cool temperate rainforest contains some of the most ancient species of plants in Australia. Some of the smallest plants - the mosses, ferns and lichens - are amongst the oldest survivors in the plant world.

Many of the rainforest's ancestors grew in Antarctica, Africa, South America and New Zealand, when these continents were joined together as one huge landmass known as Gondwanaland. Cool temperate rainforest dates back more than 60 million years, well before eucalypts and wattles.

Composition of Strzelecki Rainforest

The cool temperate rainforest in the Strzeleckis differs from that in the Otway Ranges and East Gippsland. The rainforest in the Otway Ranges consists of Myrtle Beech only. The rainforest in East Gippsland consists of Southern Sassafras only. The rainforest in the Strzeleckis consists of both Myrtle Beech and Southern Sassafras.

The understorey is dominated by tree ferns with some Austral mulberry, Hazel Pomaderris and Blanket leaf. The ground stratum is dominated by ferns.

In almost all areas of rainforest there are also numerous Slender Tree Ferns and Skirted Tree Ferns - which are included in Schedule 2 of the Flora and Fauna Guarantee Act 1988.

Epiphytes are abundant on the trunks of trees and tree ferns. Among the epiphytes are two varieties of rare Tmesipteris (forked fern) Tmesipteris elongata and Tmesipteris parva, and the more common Tmesipteris obliqua. There are also numerous colonies of Weeping Spleenwort and Gypsy Fern.

Mosses and lichens are also abundant.

Extent of rainforest in the Strzelecki's

There are very few areas of cool temperate rainforest left in the Strzeleckis. Only two small areas of rainforest have been granted any official protection at this stage. These areas are the small areas of rainforest within the Tarra-Bulga National Park and a small section of the rainforest in the headwaters of the Franklin and Agnes Rivers at Gunyah Gunyah.

Most other areas of rainforest are situated within plantations. Rainforest in College Creek and Morwell East Branch are within AMCOR plantations.

Rainforest in the headwaters of Merriman's Creek, South Middle Creek, Jack River, Albert River, Dingo Creek and much of the rainforest in the Agnes and Franklin headwaters is situated in Hancock Victorian Plantations Pty. Limited.

Threats to rainforest in the Strzelecki's

Most of the remaining pockets of rainforest within the Strzeleckis are situated within plantations. These rainforests are very vulnerable to damage because of the lack of adequate care being taken by the logging companies to protect these forests from damage.

Buffer strips around rainforests are not being provided and clearing is carried out right into the edge of the rainforest.

Debris from logging is being pushed into rainforest, causing damage to rainforest trees.

A number of logging and access tracks have been created right on the edge of rainforest, and at times within rainforest and across rainforest tributaries. Debris from these tracks has been pushed into rainforest gullies causing damage to myrtle beech and blocking the flow of the stream.
Track maintenance and reopening of tracks for logging creates more damage and debris.

The future for the Strzelecki rainforest
There are a number of areas within plantations where myrtle beech and sassafras are regenerating vigorously after the rainforest has been damaged due to logging operations. If these areas are again cleared to extend plantations or reopen tracks, this vigorous young rainforest will be lost. The remaining pockets of rainforest are tiny, scattered and highly vulnerable due to their location within plantations, the use of clear felling, short rotation time, and the push to extend plantations to the limit. The rainforests are also increasingly vulnerable to myrtle wilt disease. The rapid spread of myrtle wilt over the last few years is more than enough to sound alarm bells about the viable future of the existing mature rainforests under present management techniques. The pockets of young, regenerating myrtle beech and sassafras could well be the key to future survival of these rainforests and need urgent protection.

Strzelecki Rainforest and pine plantations (brown)


Myrtle wilt
A major threat to the rainforest in the Strzeleckis is from myrtle wilt. Myrtle wilt was first described in Tasmania in 1973.

In Victoria there was no evidence of the disease during a study of Myrtle beech forests in 1968-72, but by 1980 an aerial survey showed the disease to be well established in the Otways. In 1991 further surveys indicated the disease was present throughout the range of Myrtle beech forests. By 1997 trees dying of myrtle wilt were evident in all pockets of rainforest in the Strzeleckis.

Myrtle wilt is endemic and is fatal for all infected Myrtle beech trees. It is dispersed by airborne inoculum.

The incidence of Myrtle wilt is exacerbated through wounding of root systems and tree stems. Track construction, harvesting, windthrow and land clearing are all factors that can increase disease incidence.

Vulnerability to myrtle wilt may have increased due to the Greenhouse effect, increasing the threat to the remaining rainforest.

Other Cool Temperate Rainforest Indicator Species

Lance Water-fern (Blechnum chambersii), Leathery Shield-fern (Rumohra adiantiformis), Austral Filmy-fern (Hymenophyllum australe), Veined Bristle-fern (Crepidomanes venosum), Weeping Spleenwort (Asplenium flaccidum subsp. flaccidum), Mother Spleenwort (Asplenium bulbiferum subsp. gracillimum), Ray Water-fern (Blechnum fluviatile).

Protection of Cool Temperate Rainforest in the Strzeleckis Bioregion.

Bergman and Ferguson(1995) state that it is important from a planning perspective that the processes that result in management decisions be transparent and repeatable, not least because it will improve confidence in the planning process. The level of description should provide the opportunity to evaluate critically the decision making process.

Myrtle Wilt

Until there is general agreement on the scale of the problem of the disease Myrtle Wilt, we need to undertake an objective cost effective scientific assessment (aerial survey) of the Strzelecki Bioregion in order to establish:

* The presence of the disease

*The extent and pattern of the disease

*Whether comparisons can be made with the Cool Temperate Rainforest in the Otways and Central Highlands.

A robust/rigorous methodology (to support the decision making process) was established during the Survey and monitoring of myrtle wilt within Cool Temperate Rainforest in Victoria, undertaken in 1991 (Cameron and Turner 1996).

In order to make meaningful comparisons with other regions studied, it is important to utilise the same team, for a consistent approach and, in particular, to eliminate operator error.

In the interim, it would be reasonable to request than an independent rainforest ecologist be commissioned, to determine adequate buffer widths taking into consideration - the unique disturbance history of the Strzelecki Bioregion plus the infectious nature and spread of the disease Myrtle Wilt.

"As stressed in the CSIRO interim report, given the uncertainty about the effectiveness of buffers providing long-term protection to rainforest, a cautious approach must be adopted. In particular the threat to Nothofagus from Myrtle Wilt needs to be considered, as does the effect of large trees penetrating the buffer following windthrow."

"Ideally, measures (including the degree of buffering) to protect rainforest should be varied regionally according to the degree of perceived risk, and specified in the FMA plans and local prescriptions. The suggested minimum buffer widths and/or modified strips proposed by CSIRO should be adopted as an interim measure, but be subjected to on-going review based on new information." (CSIRO 1996).

The following excerpts from (Bergman and Ferguson 1995) provide an eloquent summary of the points expressed above.

"In the absence of relevant information from Victorian ecosystems, the best that can be done is to infer the potential for impacts from studies undertaken elsewhere. This approach suffers from the uncertainty that responses in Victorian ecosystems may not be analogous to responses observed in other forests in other environments. The unusual composition and ecological dynamics, particularly the disturbance dynamics of Victorian communities, provides grounds for supposing that responses to disturbances may be unique."

The processes at work in Victorian rainforests that may affect the conservation status of rainforest communities include:

*Changes in natural fire regimes.

* The potential for increased disease incidence.

* The potential for ecotone disturbance from site preparation burns.

* Edge effects on ecotones and mature rainforest from windthrow.

*Changes in microclimate.

*Weed invasion and other floristic and faunal changes.

Some impacts represent change from which there is no recovery.

"The resolution of differences of scientific opinion and the implementation of management strategies that ensure adequate protection may only be made by the acquisition of empirical data. Until such data are acquired, it is incumbent on planners to treat rainforest threats cautiously, and to implement protection measures that will cope with the potential for long-term and landscape scale impacts."

"Management recommendations are made to mitigate the potential for adverse impacts of management on rainforest. Research recommendations aim to provide the information that is important for future management decisions as quickly and efficiently as possible."


Burgman, M.A., Ferguson, I.S. (September 1995) Rainforest in Victoria: a review of the scientific basis of current and proposed protection measures. Forest Service Technical Report 95-4 Department of Conservation and Natural Resources, East Melbourne.

Cameron, D.G., Turner, L.A. (September 1996) Survey and monitoring of Myrtle Wilt within Cool Temperate Rainforest in Victoria. Flora and Fauna Technical Report No. 145 Department of Natural Resources and Environment Melbourne.

CSIRO Forestry and Forest Products (November 1996) Review of the Code of Forest Practices for Timber Production. CSIRO response following the consultation phase of the review. Prepared for the Department of Natural Resources and Environment.

Suggested further reading;

Hill, A., Timewell, C., McCormick, S., Mueck, S. (2001) Strzelecki Ranges Biodiversity Study. A consultants report prepared for the Strzelecki Working Group. Biosis Research Pty Ltd.

Peel, B., (January 1999) Rainforest and Cool Temperate Mixed Forests of Victoria. Flora and Fauna Program Department of Natural Resources and Environment East Melbourne.

Mueck, S., (October 2002) Report for Gippsland Farm Plantations Inc. Regional Interpretations of the Code of Forest Practices: Conservation of Flora and Fauna, Management of Rainforest and Protection of Landscape Values. Biosis Research Pty Ltd.

Private land and Cool Temperate Rainforest

Please note that Hancock leasehold and private land are classed under the Code of Forest Practices as being "private land", meaning that the Public land definition of rainforest does not apply. We have included the public land definition in order to show the comparison between protection granted to state forest and private land. Note that private land protection for rainforest is much less than that for public forests. This was probably done to appease Amcor when the code Revision No. 2 was released in 1996. (Amcor, at the time owned Maryvale pulp mill and also owned/leased land in catchments containing cool temperate rainforest; most notably, Morwell River East Branch, College Creek, Tarra River and Jeeralang Creek East Branch). It would appear that someone lobbied very hard not to get private land cool temperate rainforest specifics written into the Code. Now who could that be? Hancock have inherited this history and are currently profiting from it. (see: Morwell River East Branch ).

Cool Temperate Rainforest Code of Practice Code of Forest Practices for Timber Production Revision No.2 November 1996 Department of Natural Resources and Environment

Public Lands Native Forest 2.3.7 p23

Goal: Rainforest* must be excluded from timber harvesting* and, because rainforest communities may be particularly vulnerable to adjacent disturbance, they should be surrounded by an appropriate buffer*.

Guidelines: - areas of rainforest must be defined, and a strategy for their management must be included as part of planning for conservation of flora and fauna in Forest Management Plans* and/or in the relevant prescriptions.

The most important rainforest areas should be accorded highest protection;

- in the absence of detailed strategies within an approved Forest Management Plan, which address regional characteristics, the following prescriptions will apply:

(i) for stands of lesser significance – 40 m buffers, or 20 m exclusion plus a 40 m modified harvesting strip (>40% of basal area retained, low machine disturbance, minimal burning);

(ii) for stands where Nothofagus makes up >20% of the canopy – buffers of 60 m, or 40 m buffer with 40 m modified harvesting zone (>40% of basal area retained, low machine disturbance, minimal burning);

- rainforest areas must be shown on the Forest Coupe Plan* and buffers identified in the field;

- buffers must be protected from damage caused by trees felled in adjacent areas.

Note: These protection levels may be adjusted prior to the next Code review depending on the results of further research into rainforest protection.

Private land native forest and all plantations

3.2.7 Management of Rainforest p50

Goal: Rainforest* should be protected by reserving both the rainforest and a surrounding buffer* from timber harvesting*.

Forest Management plan for Gippsland Department of Sustainability and Environment June 2004 P19

3.4 Rainforest

Warm Temperate Rainforest, Cool Temperate Rainforest, Gallery Rainforest and Dry Rainforest EVCs occur in Gippsland. Warm Tempeate Rainforest is the most extensive rainforest EVC in Gippsland. It generally occurs in the east of the region, near the Mitchell River, Tambo River and Big Creek although stands are also found in the Strzelecki Ranges in south Gippsland. Cool Temperate Rainforest generally occurs on the Nunniong Plateau and Strzelecki Ranges, with isolated occurrences in the headwaters of Freestone and Mount Useful Creeks. Gallery Rainforest and Dry Rainforest do not occur in State forest and therefore are not discussed in this plan A working definition for field identification of rainforest in Gippsland is provided in Appendix 1.

Strategy for the protection of rainforest

This plan establishes a detailed rainforest protection strategy in accordance with the Code of Forest Practices for Timber Production (the Code). The Code requires that all rainforest and a surrounding buffer be excluded from timber harvesting. It also provides guidelines for rainforest protection, which include increased protection measures for significant stands of rainforest and a consideration of regional characteristics when developing protection strategies in Forest Management Plans. This rainforest protection strategy is based on the protection of rainforest in conservation reserves and in State forest through Special Protection Zones, and Code of Forest Practices for Timber Production buffers, to exclude timber harvesting from the rainforest and surrounding buffer.

The Special Protection Zone buffers range from 60 m to 100 m depending on the significance of stands. A number of significant stands receive sub-catchment protection. These buffers are considered to adequately protect rainforest stands from increased exposure to light, temperature and wind as a result of timber harvesting operations outside the buffer. It is also considered to provide adequate protection against physical disturbance from forest operations, which is relevant to minimising the spread of Myrtle Wilt. Prevention of minimising the spread of Myrtle Wilt is discussed in Chapter 6 – Forest Protection.

DSE has identified all major patches of rainforest within Gippsland through a program of aerial photography and field reconnaissance. These patches were assessed using the flowing criteria: ecological integrity and viability, richness and diversity, rarity, representation of type, and scientific and education value. Some of these patches were considered to contain rainforest of regional, State or national significance. Sub-catchments that contain the regionally, State or nationally significant rainforest form a ‘Site of Significance for Rainforest’.

There are 29 Sites of Significance for Rainforest on public land in Gippsland (Peel 1999) (see Appendix J). Eleven of these Sites of Significance are entirely within conservation reserves, comprising 2 sites of national significance, 4 sites of State significance and 5 sites of regional significance. Eight sites of Significance for Rainforest cover both State forest and conservation reserves; these are a national site of significance, 2 sites of State significance, 2 sites of regional significance and a site of local significance. The 10 Sites of Significance for Rainforest that are entirely within State forest are 4 sites of regional significance and 6 sites of local significance. Other stands are considered to be locally significant. Within each Site of Significance for Rainforest considered as being State or national importance in State forest ‘priority areas’ identify the most important areas for rainforest conservation. These ‘priority areas’ are ranked according to their relative importance based on; - the size of individual rainforest stands or the highest concentration of stands within each Site of Significance for Rainforest; - stands with concentrations of rare or threatened flora; - areas with identifiable management boundaries such as sub-catchment divides, roads or topographic features.

Protection of rainforest stands in sites of national and State significance, and stands of regional and local significance are incorporated into the zoning scheme in line with the rainforest management guideline below. The rainforest management guideline and Appendix J provides further detail about the rainforest protection strategy in Gippsland. Appendix J lists the proportion of each priority area within each public land category for the Sites of Significance for Rainforest in Gippsland.

Conservation Guideline Cool Temperate Rainforest and Warm Temperate Rainforest

The width of rainforest buffers varies according to the significance of the rainforest stand and the priority area. The following minimum buffers apply.

- Sub-catchments for those rainforest stands where the priority area is substantially undisturbed or the conservation requirements of other species or values are coincident with rainforest values;

- 100 m for priority 1 and 2 areas within sites of national significance;

- 60 m for priority 3 and 4 areas within sites of national significance and for priority 1 and 2 areas within sites of State significance.

- 40 m for priority 3 and 4 areas within sites of State significance and all sites of regional or local significance.

Chapter 6 Forest Protection P71 Myrtle Wilt

Myrtle Wilt is caused by the pathogenic hypomycete, Chalara australis. It has been recorded in the Gippsland planning area in the Strzelecki Ranges, however, it has not been recorded in State forest covered by this plan. It appears to be a natural phenomenon but is a major cause of death of Myrtle Beech in other areas. Following infection the trees become attractive to the pinhole borer Platypus subgranosus, the presence of which serves as a useful, early indicator of the disease (Kile 1987). Human activity which results in artificially elevated levels of Myrtle Wilt with Nothofagus-dominated Cool Temperate Rainforest has been listed as a Potentially Threatening Process under the Flora and Fauna Guarantee Act 1988.

Myrtle Wilt develops through root or stem wounds via air – or water borne spores and through underground spread. The disease may also radically alter stand structure and in public access areas create trees that are hazardous for people and property. Further investigation should determine the occurrence and appropriate management for Gippsland stands of rainforest. Actions Investigate reports of Myrtle Wilt in State forest and, where necessary, develop management guidelines for the control of the spread of the fungus.

Appendix I p175 Working definition of rainforest Ecological Vegetation Classes in Gippsland

Rainforest can be defined as follows: Rainforest is defined ecologically as closed broadleaved forest vegetation with a more or less continuous rainforest tree canopy of variable height, and with a characteristic composition of species and life forms. Rainforest canopy species are defined as shade tolerant tree species which are able to regenerate below an undisturbed canopy, or in small canopy gaps resulting from locally recurring minor disturbances, such as isolated windthrow or lightning strike, which are part of the rainforest ecosystem. Such species are not dependent on fire for their regeneration.

Rainforest Character Species

Rainforest is recognised as forest where one or more of the following species contributes the highest proportion of foliage cover.

Cool Temperate Rainforest West/Central Gippsland

Pittosporum bicolour Banyalla

Atherosperma moschatum Sassafras

Nothofagus cunninghamii Myrtle Beech

Tasmania lanceolata Mountain Pepper

Acacia melanoxylon Blackwood

Warm Temperate Rainforest

Acacia melanoxylon Blackwood

Acmena smithii Lily Pilly

Elaeocarpus reticulatus Blue Olive Berry

Pittosporum undulatam Sweet Pittosporum

Tristaniopsis laurina Kanooka

Cissus hypoglauca Jungle Grape

Rapanea howittiana Muttonwood

Hancock Victorian Plantations Pty Ltd


OCTOBER 2005 1

Terry Walshe 1 and David Cameron 2

1 Centre for Excellence in Natural Resource Management, University of Western Australia, 35 Stirling Tce, Albany, WA 6330.
2 Threatened Species and Communities Program, Department of Sustainability and Environment, 123 Brown St, Heidelberg, VIC, 3084.
1 this version incorporates minor amendments in response to Company comment received between October 2005 and April 2006.


The brief for the conduct of this peer review requires a critique of the BMP with particular empahasis on the Rationale and Operating Standard for the protection of rainforest. More specifically, the brief requests:

*Examination of the ecological basis of the Rationale, in particular the description of the ecological processes for Cool Temperate Rainforest and Warm Temperate Rainforest and the analysis of elements of the risk profile.

*Comment on the strengths of weaknesses of the proposed protection measures, in particular the extent of buffering from a risk analysis perspective.

Central to this review is assessment of the extent to which the Company's proposed BMP is consistent with Principle 9 of the Forest Stewardship Council's Interim Standard for Assessing Forest Management in Australia. Rainforests occurring on HVP lands are considered 'high conservation value forests' under Principle 9 of the Interim Standard, which states: Management activities in high conservation value forests shall maintain or enhance the attributes which define such forests. Decisions regarding high conservation value forests shall always be considered in the context of a precautionary approach.

Although it includes no comment on the need for a precautionary approach, the intent of Principle 9 is essentially preserved in the goal of the Company's proposed BMP, which states: Protection measures will be developed to manage the risk profile for rainforest on Company land with the aim of ensuring no net loss in extent and quality of rainforest, consistent with Victoria's Native Vegetation Framework (emphasis added).

We saw the central task of our review to be assessment of the internal consistency of the BMP's Rationale and protection measures against Principle 9 and the Company's stated goal.

In general, we consider the BMP Rationale does a competent job in identifying hazards. We are less convinced of the arguements advanced in the Rationale regarding the magnitude of risk some of these hazards pose, and the associated imperative to manage those risks. In particular, we regarded the treatment of risks posed by weed invasion, buffer disturbances and edge effects, Myrtle Wilt, and wildfire to be deficient.

In relation to a goal of 'ensuring no net loss in extent and quality', the proposed BMP implicitly asserts that 20m (for locally and regionally significant rainforest) and 40m buffer widths (for state significant rainforest) will result in:

*No net increase in the incidence of weeds

*No net attrition in the viability of rainforest species through microclimatic stress beyond background levels

*No net increase in the incidence of Myrtle Wilt beyond background levels

*No net increase in the risk of fire beyond background levels

Our view is that, although scientific uncertainty constrains definitive rebuttal of these assertions, it is highly unlikely that proposed BMP protection measures will prove consistent with the Company goal. When a strict requirement for a precautionary approach is invoked, we consider buffer widths proposed in the BMP to be plainly inappropriate.

We draw the following conclusions in the context of Principle 9 of the Forest Stewardship Council's Interim Standard:

1. The Company's proposed protection measures for locally significant Cool Temperate Rainforest fall marginally within plausible bounds of scientific uncertainty for a goal of 'no net loss in extent and quality'. However, where a precautionary approach is stipulated, we regard protection measures to be inadequate.

2. If the requirement for a precautionary approach were to be relaxed, we consider specification of performance criteria and a rigorous monitoring program are needed in key areas of scientific uncertainty.

3. Protection measures for nationally, state and regionally significant rainforest are inadequate.

4. The proposal of no buffer for riparian stands of warm temperate rainforest is inadequate.

5. The field method for determining the boundary of Warm Temperate Rainforest on Company land requires further work.

We consider the BMP could be improved through adoption of the following recommendations: Include 'promote post-wildfire recovery' as a goal, and provide substance to the goal through stipulation of larger buffers around core rainforest, (e.g. at the confluence of two second-order or higher streams).

*Include 'contribute to prevention of Myrtle Wilt epidemic' as a goal, and provide substance to the goal through stipulation of larger buffers on all non-linear (>40m wide) Nothofagus-dominated stands.

*Monitor performance criteria describing thresholds for

-Weed invasion

-Abiotic microclimatic variables and the ecological impact

-Buffer disturbance

-The incidence of Myrtle Wilt

*Test the effectiveness of buffers as a risk management strategy for fire by monitoring fuel loads and fuel moisture in buffers or varying widths and varying stand age.

*Avoid exposure of more than one side of a rainforest patch to edge effects within any 5 year period through inclusion of a strict spatial constraint to this effect in harvesting scheduling.

Draft Flora and Fauna Action Statements


Harvesting in State Forest

Buffer Zone at least 60m in width around stands of Cool Temperate Rainforest where Myrtle Beech makes up >20% of canopy (Strzelecki's is a seperate case also depending on indicator species Field Manual). Wider buffers where slopes exceed 20 degrees or other factors significantly increase the risk of wounding.

Sites of national or state significance warrant higher levels of protection from infection. These buffers are specified in Forest Management Plans.


* Avoid road construction and maintenance activities that result in wounding of Myrtle Beech.

* Assess and manage weed invasion weed free areas to control key infestation sources and vectors to prevent the establishment of new, high threat weed species.

* Alteration to stream flows and increased siltation rates may impact on Rainforest communities in riparian environments.

Conservation Objectives

1. To maintain/enhance the extent and condition of Rainforest in Victoria.

2. To manage Rainforest in a way which maximises recovery from catastrophic events such as fire and outbreaks of Myrtle Wilt.

Appendix provides a descriptin NOT a definition and has been superceded by Cameron's Field Manual. The Strzelecki Cool Temperate rainforest is not listed, it is still combined with the Central Highlands Cool Temperate Rainforest. However it is still listed as Nationally threatened.

Burgman and Ferguson quantified the edge width as a general measurement of 100 metres.

Strzelecki Warm Temperate Rainforest highly depleted Nationally threatened. (Peel 1999).


Slender Tree-fern Cyathea cunninghamii (including references to skirted Tree-fern Cyathea X marcescens)

Listed under the Flora and Fauna Guarantee Act 1988

The relatively small size of Slender and Skirted Tree-fern populations and their contraction to gullies makes them particularly vulnerable to off-site catchment effects. The greater the level of fragmentation, the greater its vulnerability to edge effects.

As Slender Tree-ferns are associated with Myrtle Beech dominated communities threatened by myrtle wilt, it could experience significant secondary impacts due to habitat change.

Weed invasion pose serious threats to this community. with changed understorry conditions of weedy commuities which may result in reduced light and moisture for the germination of spores.

Conservation Objectives: To ensure Slender Tree-ferns can survive, flourish and retain its potential for evolutionary development in the wild.

Objectives of this Action Statement: Protect, maintain and enhance exisiting populations and their habitats. Protect existing and potential habitat so that re-colonisation can occur. Ensure that natural ecological processes are maintained with Slender-tree fern habitat with a minimum of human intervention.








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