Here's something anyone can do from their own homes. At the moment, Dingo Creek, a National Site of Significance is being logged. How can this happen? Because the laws protecting rainforest are weak. At the moment, there is a window of opportunity to make these laws slightly stronger. It may do nothing to stop the logging now, but may have an impact in the future to protect other rainforest areas from being logged (suspend disbelief for a moment, all you jaded submission- weary conservationists out there....).
The FFG approach sets out to "ensure that the whole rainforest estate is protected in Victoria". The draft FFG Action Statement fails to achieve this goal for the following reasons:
1. Fails to resolve the controversy surrounding the definition of what
constitutes rainforest.
Instead the draft AS defers this responsibility to the DSE (see Intended Management
Action 4, pg. 5). The DSE (and its predecessors) have persistently refused to
acknowledge scientific opinion. Cool Temperate Mixed Forest IS rainforest, meeting
the definition of Cool Temperate Rainforest as provided by the Rainforest Technical
Committee (1986) and included in the "Final Recommendation on a Nomination
For Listing" under the FFG Act, which says "rainforest includes closed
transitional and seral communities, with emergent eucalypts, that are of similar
botanical composition to mature rainforests in which eucalypts are absent".
Only the recognition of young or seral rainforests can ensure protection of
the "whole rainforest estate". Deferring the issue of rainforest definition
to the DSE simply leaves unresolved one of the most contentious and pressing
issues surrounding rainforest management today.
2. Fails to set out quantifiable additional rainforest buffers.
Intended Management Action 5, pg. 5 calls for "additional" buffers
to the minimum's set out by the code. This is a far too vague, unclear and ambiguous
management action that provides foresters with no firm guide of appropriate
additional buffering. Measurable buffers are necessary if they are to be effectively
implemented in the field, otherwise this represents a meaningless statement
that is difficult to enforce. Moreover, clearer guidelines are needed which
lay out less ambiguously the circumstances which warrant additional buffers.
For instance, the Myrtle Wilt Action Statement states "slopes greater than
20 Degrees" are considered steep. A similar list of measurable conditions
are needed to provided greater direction to planners and field officers alike.
3. The draft FFG Action Statement endorses the existing FMP Area Plans
for rainforest.
However, these area plans and accompanying maps have never been published or
subject to peer review. The summaries provided in the FMPs lack detail. For
instance, "Preference will be given to National, State and Regional sites"
is a meaningless statement if zoning priority maps are not available for review.
Similarly, "protection should be provided across the FMA" also lacks
accompanying documentation for verification. In addition, terms such as "should"
can weaken the effective implementation of the Area Plans. More detail is needed
if we are to have confidence in these Area Plans.
4. No guidelines for roading operations through rainforest are provided
despite the long term impacts roading operations do have on
rainforest.
Why did the draft AS overlook the government's own "Net Gain Policy"
in relation to destructive roading operations? Why not use the existing guidelines
on loss of vegetation of very high value? We suspect that this policy was not
applied to rainforest removal/disturbance because it would effectively rule
out ANY roading
operations through mature and irreplaceable rainforest stands.
5. Why only 90% protection for Mixed Forest, when it is even rarer
than Cool Temperate Rainforest?
100% of mixed forest can be protected. There is no scientific basis for the
90% target. This 90% target allows continued destruction of this rare rainforest
community until mapping is fully completed, which could be years if ever.
6. Timelines for implementation of
a. mapping
b. training
c. research and monitoring, are essential if this document is to go beyond the
"status quo" of rainforest mismanagement.
7. How and when will the DSE:
a) "Improve knowledge of rainforest ecology"
b) "Develop effective measures to mitigate effects of myrtle wilt, fire,
environmental weed invasion and other process ...."
c) assess the competency of field officers in identifying rainforest in the
field? An external accreditation system would help raise community confidence
in rainforest training schemes which currently have failed to deliver acceptable
results (as determined by EPA Coude Audits).
8. Fire effects need to include coupe sterilisation burns and Coupe Regeneration Burns. It is physically impossible for coupe Regeneration Burns to avoid rainforest gullies. Entire sub-catchments need to be avoided, rather than just assuming fires will go out around the edges of rainforest margins.
9. In relation to breaches of the FMP or Code of Practice the draft statement
states it is important to "ensure ...action is taken where breaches are
confirmed." We believe that a much more severe penalty than the reduction
of points is warranted. For instance, protecting an area of greater size than
that damaged needs to be permanently protected as compensation and financial
penalties applied to logging contractors and disciplinary action taken against
forest officer
involved.
10 The AS states it is necessary to "determine priority areas for rainforest restoration". What is left unsaid is the all important how, by whom, by when, and how it is to be funded.
11. Adequacy of current management prescriptions needs to be urgently reassessed and acted on, not just agreed that sometime it might be useful.
12. Protection of all remaining old-growth Wet Forests is required to ensure the protection of rainforest and was a consideration in the declaration of Sites of Significance.
Concluding comments:
The AS should be far more specific, provide measurable benchmarks for continuously improving rainforest outcomes, nor just saying that it needs to be done. To do otherwise is a simply wasting time and procrastinating with more weak and indeterminate reports. It is important to strengthen the policy of protecting Rainforest. EPA audit shows this isn't working. We cannot afford one mistake let alone dozens as the destruction wrought can't be undone. We need to treble the area of rainforest added to reserves to replace areas damaged. Such a policy will provide a clear incentive to protect rainforest values for future generations.
The Draft Action Statement is available to look at on the DSE website. Click on http://www.dpi.vic.gov.au/DSE/nrenpa.nsf/LinkView/69770772A2A1F48BCA256FB3000734324E9F3F3E22EC7A43CA256FE90026A339
If that link doesn't work try www.dse.vic.edu.au and type in "rainforest action" to find it.
Sudmissions close on 24 June 2005