West Victoria RFA Independent Panel
PO Box 502
East Melbourne Victoria 3002
RFA agreement consultation paper (January 2000)
PART 1. GENERAL COMMENTS
Quality of information supplied
The ridiculously short time-frame
for the production and evaluation of this report have obviously
caused many problems. Not the least of these are the many
errors that have arisen in the documents - e.g. the
EVC tables (Table 3.2b) were incorrect. There are also errors
in the maps e.g. Johnson Reserve SW of Woolsthorpe
is a Flora and Fauna Reserve but not shown as such on the
map. We suggest later that there may be some errors in the
EVC mapping, too. Were there also errors in calculating
the percentage representation in Reserves? The difficulty
in fully comprehending the meaning of all the data supplied
(errors included), and then responding to it, are further
problems that all have had to grapple with.
The inability of NRE Forests
Service to produce accurate (or any) information on resources
for the DRAFT is another major problem. To put the matter
bluntly, the material provided is biased and misleading.
There are serious omissions with respect to woodchips and
private forestry on farm land (see later), and probably
inaccurate estimates of sustainable yield of timber from
the forests. What a pity the appraisal and analysis of DRAFT
"4. FOREST INDUSTRIES" was not independent.
Further, there are deficiencies
in "threatened fauna" listings in the DRAFT, APPENDIX
3. These include no mention of Powerful Owl in the Dergholm
area, Masked Owl in Casterton area or Swamp Antechinus in
Cobbobboonee area. Heath Mouse and probably Swamp Antechinus
also occurs in Dergholm area.
More serious, though, has
been the fact that the RFA DRAFT has apparently been produced
with little or no notice being paid to any of the feedback
from the public meetings. This RFA process has obviously
been driven by the wants of the woodchip industry. This
is made clear on p. 85 of the Draft ("The current Commonwealth
export arrangements provide that, after 31 December 1999,
exports of hardwood woodchips from native forests will only
be permitted from areas covered by an RFA"). We conclude
that the RFA process is locking in export woodchipping of
NRE Forest Services has
been able to promote its interests to the exclusion of others
- they have obviously been partners with the Commonwealth
in writing the DRAFT - and therefore very little
of the public’s interests has found its way onto the DRAFT
map. Now we have the ridiculous situation where, for example,
a Minister will not halt logging in the disputed Riley Ridge
area of Otways because it "was not indicated in the
DRAFT"! Pardon us for believing that the RFA plan
was yet to be produced! It is this sort of behaviour
that has undermined the process. Our suspicions over NRE
actions in Portland FMA also appear to have been confirmed
- that NRE Forest Service wants to destroy any area of contested
biodiversity resource so that no serious case can be made
for its inclusion as a Reserve in the final plan.
The JANIS criteria and the process of
defining conservation and timber "reserves"
The maps & tables appear
to have been drawn up not on the basis of EVC’s but
on a more expedient basis, in contradiction to principles
of JANIS Reserve Criteria for establishing the CAR ("Comprehensive,
adequate and representative") Reserve System.
* Those with timber
interests have been consulted and "their" preferred
areas have first been preserved, after removal of a few
minor strips or marginal blocks
* Areas remaining have then been analysed
to see what the EVC distribution looks like.
How else can one account, for example, for
the shabby treatment suggested for the Cobbobboonee
area, where there is no adequate reserve for several
species that are endangered or at the limits of distribution?
We believe that there has been a sad lack of attention to
these factors when considering Cobbobboonee .
Incredibly, this apparently
cynical abuse of process is excelled in the treatment of
Plains Grassy Woodland areas (Yellow Box-Yellow
Gum -Red Gum grassy woodlands of the Black Range-Grampians-Rocklands).
We remind the panel that only 3% of the pre-settlement
distribution exists and only 1.03% is in existing and suggested
reserves, whereas 15% is required [see PART 2.2
of report, plus Appendix 1].
Other aspects are raised for Dergholm
area (see PART 2.3 & Appendix 2) and
other areas at Glendinning (Rocklands) and Weecurra
(west of Digby).
Aspects of the JANIS reserve recommendations
(p. 97 of DRAFT) have been ignored in some cases:
- Boundaries should be set in a landscape
context with strong ecological integrity
- The reserves should not consist
of fragmented strips - the boundary-area ratio should
- Large areas are preferable to
- Reserve design should aim to minimise
impact of threatening processes.
Thus, we reject the claim
made in the Executive Summary, that the Draft has properly
addressed the JANIS criteria in defining a CAR reserve system.
It clearly has not done so, as we will detail later.
JANIS criteria should be
fully implemented with regard to the EVC’s identified as
endangered, vulnerable or rare.
The conservation value of such EVC’s should be the primary
consideration in deciding their future status and management.
Any body wishing to impose a competing land use should be
obliged to demonstrate to an independent tribunal
why the conservation value should not prevail. Plainly,
that process has not happened here.
Sawlog pricing , future demand and allocation
* Sawlog pricing
NRE currently supplies
logs from native forests to the timber industry at subsidised
prices. This is clear from the KPMG (1999) report, and
from the Auditor General’s (1993) report. Indeed, NRE
admitted (p. 10 in the response to KPMG report) "Log
prices have not matched the costs of production".
The effect of this will be to discourage investment in
forestry for sawlogs on cleared agricultural land. What
the industry (and NRE Forest Service) is expecting is
a continued subsidy to log native forests, regardless
of conservation significance. NRE failed to mention
this in the Draft (Section 4). They also failed to acknowledge
that, as a consequence of the 22% of sawn timber being
kiln-dried for higher value products and therefore making
40% of the gross value of sawn timber sales, increased
value-adding by the industry in the future will actually
reduce the need for timber volume from the native
forest. NRE’s argument that value-adding and increased
processing of "residual logs" requires an increased
allocation of timber from public lands is spurious. Any
requirement for increased volume in the future could -
and should - come from plantations on cleared farmland.
For that to happen there is a need for Victoria to review
its royalty structure, to allow such development to be
* Woodchip production
that sawlog quality from the forests (particularly SW
Vic) is very poor, but it does not emphasise the
fact that woodchip extraction is driving the present industry
in the forests. NRE does not provide the information
that there will be over 60, 000 ha of blue gum plantations
in the SW by late 2000. About 20,000 ha were planted in
1999 and 10,000 ha in 1998, when the industry began here.
Clearly, the future market for woodchips from the forest
is not rosy.
NRE Forest Service
does not reveal that a major reason for wanting
woodchip from the native forests to continue is to fill
the 5-year gap before blue gum woodchip hits the export
market! Are they happy to lock all of our forests
up for the next 20 years and beyond just to achieve
that short-term objective?
We find this an appalling
situation. How can it be justified when biodiversity and
other factors have also to be considered? NRE appears
to be wanting the native forests to compete with
forestry on cleared agricultural land, where the risks
are borne by private industry!
* Allocations for
the Portland/Horsham FMA
15-year licence arrangements were introduced in 1987.
Some will run out soon, even with the present policy of
rolling these over every 5 years. That provides the opportunity
to rationalise the industry, something that NRE has never
sought to do. It is feasible to reduce the allocation
in order to produce a sensible biodiversity outcome.
The impression created in the Draft is that allocations
are sacrosanct. This is not so. Apart from the fact that
NRE has badly overestimated sustainable yields in some
areas (and has no reliable figures for the Portland or
Wimmera areas), there are funds available for restructuring
to allow a great many licences to be bought out. This
is an obvious need in the Horsham FMA, where no
reduction in the present log allocations were suggested,
despite the serious shortage of permanent reservation
of Plains Grassy Woodlands.
If we are to believe the
figures quoted in the consultative papers then the maximum
number of jobs likely to be lost in timber mills throughout
the West Region is 67 from a workforce of 315. This represents
the worst-case scenario. That is, if all the DRAFT
Reserves are adopted and there is no value-adding.
The latter is unlikely. Further, it is clear that 48 of
these estimated job losses are due to NRE’s revised estimates
of timber resource availability and have nothing to do
with biodiversity considerations. NRE has simply been
incompetent in the past and wishes to put the blame elsewhere.
How are these figures supposed
to indicate a huge socio-economic impact for the region?
Do these presumptive figures compare with the actual closing
in recent years of the abattoir at Portland, or the Regional
Veterinary Laboratory at Hamilton? No, they do not. Combined,
hundreds of jobs were lost there. And not a murmur from
Shires, politicians and companies now so vehemently pushing
the presumptive case of the logging industry. Valid alternatives,
controlled tourism and employment in the burgeoning blue
gum industry, is not even acknowledged by these people.
Obviously there will be
some flow on multiplier effect with a decline in logging
but the present remarkable growth of the plantation industry
in SW Victoria, and the growth of tourism, will absorb that
impact. We feel compassion for any person who losses employment
through no fault of their own – some of us have suffered
in that regard – but the existence of the Timber Industry
Re-adjustment plan should provide some compensation
to those affected while alternative long-term solutions
are worked out.
Security of management for biodiversity
Professor Ferguson indicates
that elements are in place for ecologically sustainable
management of forests. Some elements may be "in place"
but not active in some forest areas we are familiar
with. Ferguson concedes there is room for a lot of improvement.
Clear-felling systems which strive for maximum yield
from even-aged single-species stands are incompatible with
biodiversity. It is possible to make a case for single-tree
selection harvesting, provided that the practice of
culling habitat trees is dispensed with. NRE has been
unwilling to consider the option that previously operated
in this area, and which did not result in such disastrous
consequences to the wildlife. The shambles in ecological
management of the Cobbobboonee, or of the woodlands around
the Black Range, indicates that the NRE Forest Service has
no interest in biodiversity. We submit that any suggestion
that NRE will put biodiversity considerations above forestry
aims is laughable. Is there one instance concerning
the Fauna and Flora Guarantee Act that has
been acted on in good faith in respect to Cobbobboonee?
Sorry, but we have been
given no evidence of NRE Forest Service’s commitment
to biodiversity in forests, or it’s willingness to suspend
operations that clearly breach the Act. In short, the litany
of acts of bastardry by managers of the Portland FMA are
ample testament to future intentions. On the evidence
available over the last 3 years (see Appendix 3),
every effort has been made to reduce the ecological value
of the Cobbobboonee area before the RFA assessment
process began, and during the course of the study.
Either through incompetence, or by design, NRE has had no
Portland FMA management plan in place, so no management
guidelines could be broken!
According to the DRAFT,
no FMA management plan will be forthcoming for the Portland
FMA until after the RFA process is secured. How gullible
does NRE Forest Service think the public are?. Our information
is that NRE intends to continue by stealth the present destructive
process, to turn the forest into a single-species plantation
of Messmate- and finally rid the forest of the Powerful
Owl, Masked Owl, Barking Owl, Yellow-bellied Glider and
other species there. Any plan drawn up after the
RFA agreement is signed will certainly entrench present
NRE Forest Service prescriptions and generate massive discontent.
The Forest Management
Plan must be AGREED by all parties BEFORE the signing of
the RFA Agreement. We will not agree to having clear-felling
practices entrenched in this forest by this desperate delaying
tactic. At the very least we expect to see a return to single-tree
selection for harvesting, no woodchipping, no
culling of habitat or feed trees, and a return to the type
of sustainable logging methods used by the small mill operators
in the area.
NRE Forest Service has not
given us any confidence that they can manage any
critical area for multiple use. If it is important
for biodiversity then it must be reserved now. The
so-called "Special Management Zones" will not
be effective. They are a transparent ruse by NRE Forest
Service to continue present logging unhindered. On its record,
NRE Forest Service simply cannot be trusted to adhere to
the letter or spirit of an agreement. Perceived timber interests
always take precedence (see APPENDIX 3).
We expect a much greater
area of Cobbobboonee reserved for biodiversity. Failure
to do that will negate the whole basis of the RFA process,
which is to create a Comprehensive, Adequate and Representative
reserve system, and indicate that Victoria is in contempt
of the principles behind the RFA process.
PART 2. SPECIFIC AREAS
2.1 Black Range-Grampians - Plains
Grassy Woodland (EVC 55)
As outlined in the General
Comments, the treatment given to this area in the DRAFT
is disgraceful. As may be seen by reading Appendix 1,
the significance of this EVC, and its shameful neglect,
has long been known (or ought to have been known) by NRE.
This is classified as a "vulnerable and rare"
EVC, whose severe depletion requires that 100% of its present
distribution should be reserved.
Representation in Reserves
- only 1.03% of the pre-1750 extent will have been included
in Reserves if the DRAFT is adopted. This is clearly in
breach of the JANIS principles. It is "possible and
practical" to increase the amount to at least double
that presently suggested. Even that will only bring the
total in reserves to 2% of the historical presence. The
RFA process has failed to adequately deal with this ECV.
All areas of Yellow Box-Yellow
Gum-Grey Box whether currently being grazed or not must
be included in the Reserve system. There is no need for
any "review of grazing activities" - these
are well known and positively deleterious (see APPENDIX
1). Action is urgently required to link the Grampians
and Black Range Parks through two strips running east-west
below Cherrypool, to give permanent reservation
to a unique and severely under-represented vegetation alliance.
These areas are shown on the attached MAP.
These areas should have
been included years ago, were it not for the intransigence
or ignorance of the then Forests Commission. It will be
a travesty of biodiversity justice - a monument to ignorance
or prejudice - if things do not change. It should be noted
that these areas are basically not sought by the timber
industry and the failure to include them in a Reserve would
be a demonstration of incompetence.
Argument has been made (DRAFT
p.14) of the need to preserve the local red gum industry.
No reductions in timber availability for posts, poles
and firewood were suggested in the DRAFT. Clearly, as outlined
in our General Comments, it is possible and feasible
to make reductions. Some firewood and poles could be
produced for sale on farms, given a shortage of cheap material
from Crown Lands.
The DRAFT has suggested
that the objectives of conservation can be pursued in the
presence of logging, firewood gathering activities and grazing.
One weakness of that argument is that preservation of hollow
trees, prescriptions for maintaining a suite of grassland
species, and supervision of logging activities is dependent
on management by NRE. This is not available. There
are too few staff now to exert any substantial moderating
The RFA has obviously pandered
to the interests of the local industry to the exclusion
of biodiversity considerations. However, we concede that
selective logging and firewood gathering in at least
half of the Woohlpooer Red Gum forest should
be allowed to continue. We believe that a compromise
is to reserve the block which runs from the fork of the
Henty Highway and the Old Horsham Rd, west to meet the block
containing the Reference Area (see MAP) and north to the
reservoir. This will allow connectivity of Reserves and
conserve a reasonable area of almost pure River Red gum
woodland. The area near Woohlpooer itself is virtually a
plantation, having been allowed to regenerate from the 1920’s.
It has been ruthlessly grazed until recent times. We believe
that the current relief from grazing by sheep mentioned
in the RFA DOCUMENTS is only short-term, to allow some Red
If timber getting is permitted
to continue in the Woohlpooer block - and only there
- we would expect that all of the Yellow Box-Yellow Gum-Grey
Box-Red Gum alliance identified above will be included in
the Reserve system.
The DRAFT suggests that
phasing out firewood collection from the forest areas will
be difficult, however once the community knows that firewood
can be obtained from the one area there will be little problem.
2.2 Cobbobboonee Forest - Heathy
Woodland (EVC 48)/Wet Heathland
(EVC 8) & Lowland Forest (EVC 16)/Lowland
Forest-Heathy Dry Forest (EVC 20)
We have discussed this in
"General Comments". In summary, we believe that
the DRAFT plan is totally inadequate and that a serious
attempt must be made to include a substantial (if not
total) part of the Cobbobboonee forest in the Reserve.
The biodiversity implications of the DRAFT plan are such
that there is no secure future for the threatened
listed species. This area is also important for the conservation
of an example of old growth forest dominated by E. obliqua,
which has no reserve status in this area.
The Cobbobboonee Block
is a critical area. All of the area inside the present
DRAFT "fringe" must be incorporated into the Reserve,
effectively the lower half of the whole block (see our
- This area contains several Powerful Owls,
together with Masked Owl, Yellow-bellied Gliders and probably
the Spot-tailed Quoll. It is unthinkable that any serious
plan would disregard this factor, especially in the light
of the current mismanagement of the area by NRE.
- The area has a significant amount of
Old Growth forest and E.obliqua not found in Reserves
2.3 Other areas of Portland FMA that
should be included in the RESERVE.
- Block east of North-South Rd,
Nth of Annya Rd to Top Rd, plus the margin Nth
of Top Rd extending east to Savins Rd area. That, plus
the Sandy creek area, would complete the entire block
in the eastern half of Annya. There are four major reasons
for this reservation
- Yellow-bellied Gliders and Powerful Owls
are located in the forest east of North-South Rd
- This is one area that NRE has yet to
- The area Nth of Top Rd is mainly Damp
Sands Herb-rich Woodland (EVC 3) and this is under-represented
(10% only of previous area has been suggested for Reserves)
- The unit is then large enough to be viable
according to JANIS criteria, and to offer continuity for
- Jens Rd Block. This block must
be included for the following reasons:
- It has the under-represented Herb-rich
Foothill Forest (EVC 23), for which only 8% are currently
suggested to be in recognised Reserves.
- It is the known residence of Powerful
- Dunmore Rd Block – this entire
block should be reserved for following reasons:
- It contains the under-represented
Herb-rich Foothill Forest (EVC 23),
- It extends the boundary of Mt Eccles
NP, including a more diverse flora.
- Woolwash Rd Block at Mt Clay -
this block must be included in the Reserve. It has plainly
been excluded because it grows some good timber. Allowing
that narrow intrusion into the suggested Reserve is not
compatible with JANIS principles.
The Portland Field Naturalists
Club has made detailed representations on this Portland
FMA and we support the general arguments of the group’s
2.4 Dergholm-Brimboal Area - Heathy
Woodland (EVC 48); Heathy Herb-rich
Woodland (EVC 179); Damp Heathland (EVC 710)/Damp
Heathy Woodland (EVC 793); Damp Sands Herb-rich Woodland
(EVC 3); Sedge Wetland (EVC 136); Riparian
Scrub (EVC 191); Seasonally Inundated Shrubby Woodland
(EVC 195)/Plains Sedgy Woodland (EVC 283).
A significant block to
the West of Nolans Creek, which is SW of Brimboal State
Forest (Block 3002 on the DRAFT map) must be included in
the CAR Reserve System
- This block is the home range of Powerful
Owls.. They have been seen and heard twice by our
group, once 18 months ago and last in January of this
year, in the Nolans Creek area named above. Those records
have been made in the DNRE Atlas in January 2000. This
species has also been recorded in the State Park several
kilometres further north, as indicated in the "DNRE
Working Map Draft for the West Region, Comprehensive Regional
Assessment Volume 1 - Land tenure with threatened fauna
records" (1999). This is a pressing need for reservation
- The block contains some very large old
River Red Gums , Manna Gums, Yellow Gums, Swamp Gums and
Stringybark trees. These are in short supply in other
areas of the Park. It is difficult to understand how the
block could have been overlooked as it is also important
for nesting Red-tailed Black Cockatoos.
These live in the area, and have been observed seeking
nest sites and feeding in the Stringbarks. For further
information see APPENDIX 2.
- This block has a substantial component
of EVC 3 (Damp Sands Herb-rich Woodland), of which
only 8% of pre-settlement extent is contained within
Reserves, but the DRAFT suggests that only 2% be
included in Reserves. Why was this component of forest
excluded from the Reserve? More is required to
approach the CAR Reserve criteria.
- This block contains a stand of E.
leucoxylon, which does not appear to occur elsewhere
in the Youpayang area of the State Park, or the
areas suggested for inclusion in the Reserve.
- This block is mainly EVC 179 (Heathy
Herb-rich Woodland) which has one of the smallest representations
in Dergholm Youpayang Block, and the DRAFT has suggested
only a small reservation of this EVC in this part of the
region. Overall, this EVC has only 12% of pre-settlement
extent in current Reserves across the whole Western region,
with a further 11% suggested for inclusion in the DRAFT.
Another block is also required,
to link the Dergholm State Park and the eastern strip nominated
in the DRAFT plan. This would connect
with the Casterton-Chetwynd Rd (see our MAP). This
extra area consolidates the southern area, leaving
the northern part for forestry. The addition is required
to ensure long-term protection of the Red-tailed
Black Cockatoo and Powerful Owl habitat. Woodcutting
and uncontrolled fire has removed most of the large old
trees from the forest and provision must be made now
for the restitution of the biodiversity potential.
- Mooralla West Area - We agree
with the suggestions in the DRAFT for this southern
extension of the Black Range - but not for the apparent
reason suggested by the RFA map. We are
puzzled by the EVC mapping classification used. It appears
to be classed largely as EVC 792 (Stony rise Woodland/Stony
Knoll Shrubland). This area is not basaltic, although
it does contain areas of rhyolite, and is most infertile.
This looks very odd. Since the same type of rhyolite
outcrops are present NE and NW, yet have not been marked
as such, we can only conclude that an error has been
made on the map. The area contains parts of Plains
Grassy Woodlands flora , including some lovely stands
of Yellow Gum and Yellow Box woodland. It also
contains an area of Brown Stringbark (which is identified
on the DRAFT map) which has not been burned for over
Altogether, this area has
a most varied and interesting mosaic of vegetation. In
the interests of accuracy, we believe the EVC mapping description
should be re-assessed.
2.6 Glendinning Area -
We do not agree entirely with the suggestions in
the DRAFT. We are not able to follow the reason for not
including the Rocklands frontage area with the Claude Austen
area (to the west) as a new Reserve. This country includes
a varied range of habitat, including a large area of Yellow
Box -River Red gum woodland. These areas are not shown
on the DRAFT MAP. Neither are they shown as being present
in the SW part of the Claude Austen Reserve. We suggest
that the accuracy of mapping of this area should be reviewed
before the final RFA plan is produced. We believe that an
additional area to the east, fronting the Reservoir, should
be included in the RESERVE (see our MAP).
2.7 Weecurra Area -
We believe that a greater area should have been included
here for long-term security of Red-tailed Black Cockatoos.
A serious attempt must be made to increase their
resource base. There is ample opportunity to do this at
Weecurra, leaving a larger tract of Stringbark country that
can provide seed for food and, ultimately, produce hollows
for nesting. We have marked areas that we believe should
be added to the Reserve (see our MAP)
2.8 Other areas –
- Deep Lead -
We applaud the reservation of the Deep Lead area of Ironbark-Yellow
Box-Yellow Gum woodland.
- Lake Fyans – this is another deserved
area for reservation.
There are many small woodland
areas and larger patches of bush that we are not familiar
with. We particularly rely on other groups to comment on
the NW and extreme western areas.
1. HFNC submission to Parks Victoria on Black Range State
Park Draft Management Plan (April 1998)
are excerpts from this document that relate to RFA
Field Naturalists are well acquainted with this area - for
instance our members found the aboriginal art sites in the
1960's and we made detailed submissions on this area in
1976 to the then Forests Commission Victoria (Draft Management
Policies) and in 1981 to the LCC. We have visited the area
frequently, as it is an exceptional place for the winter
display of many heath species, acacias including Varnish
Wattle (A. verniciflua), and in other parts of the
Park, for experiencing the unique open Box-Gum woodland
It is with
some concern that we note, in reading the present Draft
Management Plan and relating that to our submissions in
1981, how little progress has been made in those 20-odd
years towards better nature conservation management practice
and in improving the representation of vegetation units
in the Park. We will allude to specific points in our submission.
that the Plan should indicate a plan for the incorporation
of the entire Black Range State Park area - and much of
the surrounding State Forest - into the Grampians National
Park. There are many reasons for this, as discussed
Range SP - supplemented by the adjacent "State Forest" area
- contains the most extensive area of Yellow Box woodland/grassland
in the State. The Grampians also contains some Yellow Box
grassland but the major areas are River Red Gum. This is
poorly represented in other National Parks or conservation
reserves. This fact is not acknowledged in the Draft Plan
and is a serious omission. Our club stressed this in 1981
and others (e.g. Lunt 1995) have noted the importance
of these grassy woodland areas, but management still appears
ignorant of the fact. Lunt makes the point that these areas
are managed as "grazing ecosystems" with no burning. Most
of these areas have been converted to agriculture. The fragments
that remain have undergone "ecological segregation", with
some species depleted or eliminated. Lunt states that "all
remnant grassy forests and woodlands have been grazed by
stock, so that at best the policy can only maintain the
impoverished remnants of 150 years of stock grazing". This
is, of course, true of the Black Range woodland which has
been unmercifully flogged by sheep up to the present day.
The Plan should make a major feature of the Yellow Box (E.
melliodora) and River Red Gum woodlands. This can hardly
be done whilst some of these areas continue to be treated
as sheep grazing runs. The Draft Plan needs to address this
vital issue - nowhere has the Draft indicated an awareness
of the conservation significance of this issue.
of the indigenous vegetation in the grassy forest and woodlands
in SE Australia has been destroyed, primarily as a result
of management practices that are detrimental to the species.
Lunt contends that a program of regular burning and grazing
by kangaroos (not stock) on parts of the grassy woodlands
should be the long-term aim to restore the species diversity
of these important relics. Archer (1997) reminds us that
the way this is done is important to the result: the traditional
aboriginal fire-stick methods created a mosaic of different
aged vegetation which had great diversity.
boundaries specifically exclude the Box-Gum woodlands
from most of the Park, thereby diminishing their status!
A glance at the Plan map, in association with a vegetation
map, shows that the significant area south of the road from
Cherry Pool to HGH Corner is not in the Park. Nor are the
very substantial areas north of Rees Road and the Black
Range Road. This is a major conservation concern that should
be addressed in any future plan for this area. Fire control
was once given as a reason for excluding these areas. That
has never been a reasonable excuse because there are a multitude
of kangaroos and wallabies in the area and sheep grazing
is not required for vegetation control in such an infertile
Forest areas north of Rees Road and the Black Range Road
should now be incorporated into the Park. It may have been
politically expedient to exclude them in 1981 but those
times are gone (see HFNC 1981). Action is required to plan
the conservation of species that are important to the State.
There are also important areas of Desert Banksia in part
of this zone that require protection from fire - as noted
in the Draft Plan for the Park.
It is interesting
to re-visit the HFNC submission to the LCC (1981), to see
that no action has been taken to re-dress obvious deficiencies
in the vegetation units represented in the Park ..."omission
of the Yellow gum/Yellow Box woodland from the proposed
park seriously diminishes the variety of habitats and plant
communities available for conservation of fauna, and also
seriously diminishes the proposed park's scenic values.
There is more to a National Park than rocks and scrub".
between the present Grampians NP and the Black Range SP
should also be combined together to link the area into a
single management zone - a corridor to preserve future
biodiversity. This action was also proposed and justified
by HFNC in 1981. It is time that some active and sensible
planning was done to rectify the mistakes that were made
in 1981 when this corridor was simply listed as State Forest
and treated as a grazing run. This area contains a stand
of Grey Box (E. microcarpa), a few Buloke (Allocasuarina
luehmanni) and many Yellow Gum (E. leucoxylon. The
first 2 species are notable for their rarity in the
area and Yellow Gum is also poorly represented in the Park.
The area south of Cherrypool (Djarabul) is particularly
Range State Park is presently under the same management
as the Grampians NP, and has the same fire plan, so there
do not appear to be any obstacles from a management point
W.R. (1997) "A variation on the view expressed in a
manuscript published in the Victorian naturalist relating
to fire and indigenous land management". The Victorian
Naturalist 114, 192-195.
I.D. (1995) "European management of remnant grassy forests
and woodlands in south eastern Australia". The Victorian
Naturalist 112, 239-249.
(1981) Second submission to the Land Conservation Council
on the Grampians Area: October 1981 (Hamilton Field
2. HFNC submission to Parks Victoria on Dergholm State
Park Draft Management Plan (April 1998)
are excerpts from this document that relate to RFA
values - Dergholm State Park (p.4) - yellow gum
(E. leucoxylon) and pink gum (E. fasiculosa)
woodlands should have been mentioned as major features.
These are not well represented in any other Park, yet
are one of the major features of the Bogalara
Block (a small patch of yellow gum also occurs in
State Forest on the SE edge of the Youpayang Block,
near the south end of Farley's track).
of red-tailed black cockatoo
observations in the area since 1996 indicate that the
Youpayang Block and adjacent State Forest is used extensively
by these birds. For example, on 6 April 98 approximately
140 birds were seen in the Brimboal State Forest. Part
of that flock stayed in the general vicinity for at
least a week, being seen or heard daily from 11-13 April
while venturing west near the State Park and then returning
in the evening. We first noted the birds in that area
in 16 Nov 96, 1 Jan 97, 2 Feb 97, 16 Feb 97, 12 Jul
97, 13 Sep 97, 7 Oct 97 and 30 Nov 97.
of the Youpayang Block for conservation - the
birds may prefer larger trees, which appear to be
in the Brimboal State Forest section. [Update
note - there are many very large old river red
gums in the State Forest east of Farley’s Rd (i.e.
west of Nolans Creek and Brimboal State Forest block)
which have no protection - timber cutters were active
in the area in 1999, cutting down dead trees for firewood.
Note also that this is in the centre of range of a
pair of Powerful Owls, an endangered species
of stringbark -years of harvesting appears to
have left few large trees and very few with hollows
for nesting. We have seen a stringybark in the Wilkin
area that is used as a nest tree - they do not only
depend on river red gums or yellow gums. Yellow gums
are now being cleared from the Edenhope-Dergholm-Casterton-Dartmoor
area to plant blue gum and pine. Some of this clearing
on farmland appears to have been without permit. However,
there is little to prevent such clearing - and nothing
to prevent clearing of dead trees. A shortage of nest
sites will be critical for future survival of the
cutting activities - this may also disrupt the
birds’ feeding/breeding activity.
boundaries of this block should be reviewed to include
areas which would improve the long-term survival prospects
of the birds. The Park should, in any case, include
the river red gum woodland near the Chetwynd-Casterton
road and to the SE of the Farley's Rd. We fear
that on-going timber harvesting, including mature
river red gums, will compromise the future of the
red-tailed black cockatoo.
Plan should indicate a review of the present Park
boundaries, to see if they are satisfactory for
long-term conservation needs. The case of the red-tailed
black cockatoo was given above. Present boundaries
of Youpayang block are very arbitrary and should be
widened to include part or all of the State Forest which
is contiguous. The Youpayang Block needs a public
on the State Forest should, in any case, be examined
to see whether actions there (fire plan and harvesting)
are detrimental to conservation of rare species. The
management of State Forest areas should ensure the retention
of large old trees for the red-tailed black cockatoos.
APPENDIX 3. Some recent
actions by NRE Forest Service with respect to management
of threatened fauna habitat in Cobbobboonee
- 1997/98 – The
block near the corner of T&W Rd and
Mt Deception Rd was burned in 1991and one block bulldozed
and re-seeded with Messmate. Around 1997 the adjacent
block was treated to leave trees left in a buffer strip
but only about one per hectare in the forest block. At
Holmes Rd forest, hollow-bearing trees were ring-culled
and a few trees were left that were supposedly going to
form hollows at some distant date. Around this period
(6 January 1998), the Portland Manager NRE received information
regarding nest hollows "all feed trees should be
retained in a coupe, additional to habitat trees containing
nesting hollows". The information also stated that
roads that should have a 20 m wide SPZ included Jacky
Swamp Rd, Boiler Swamp Rd, Cobbobboonee Rd, Fish Holes
Rd, Coffee’s Lane, Mt Deception Rd, Sunday Creek Rd.
- 1997- NRE furtively introduced
clearfelling, with large coupes in critical habitat areas.
This area had never before been subjected to that process.
It was a new management practice, coupled with
intensified ring-culling. Claims were made later (Portland
Observer 31 May 1999) that it was only to improve the
sawlog capacity of the forest, or that it was actually
improving biodiversity by creating better trees! (NRE
Officer at RFA Public Meeting at Heywood in 1999). However,
this was clearly intended to pre-empt consideration of
these critical areas for inclusion in a conservation Reserve
when the RFA process visited Victoria.
- Winter 1998 – Woodchipping
began, despite protests from the public, and despite
the absence of a management plan. Trees that were removed
"were primarily less than 30 cm in diameter".
A contractor from Colac did the work for Midway Wood Products
for export out of Geelong and obtained the timber for
an undisclosed (presumably paltry) sum. This area had
never before been subjected to that process.
This process was also
seen as an effort to pre-empt consideration of
these critical areas for inclusion in a conservation Reserve
when the RFA examined the area in March 1999. Morrow claimed
(Portland Observer, 21 August 1998) that they "retained
habitat trees". According to Morrow, they aimed to
thin 250 ha of Annya, Gorae and Cobbobboonee by a woodchip
operation, to maximise future sawlog objectives. Manager
of SW Forestry Peter Keppel stated (Portland Observer
24 February 1999) that the average coupe size was 70
ha and that 500 ha was logged each year. He further
stated that woodchipping had "moved away from the
Portland area and would not return for two or three years".
We believe that such a large coupe size is completely
unacceptable for wildlife conservation. Indeed, that any
clear-felling practice is detrimental to wildlife because
it diminishes the diversity of other species in the forest
and removes hollows for predators and prey.
and conservation groups took their protest over logging
to the Portland streets (Portland Observer 22 February
1999), asking for a cessation of logging until the RFA
process was completed.
- 18 March 1999
– 20 m buffer zone burned along Coffee’s lane. This was
a very hot burn, Habitat trees were burnt to charcoal
shells. This was a Powerful Owl area. In January 1999
an adult was sighted and the next night 2 juveniles were
photographed (ATLAS report)..This is also a Yellow-belly
- April/May 1999
– Cut Out Dam Rd, within 2 km of Surrey Ridge Picnic Ground.
Area logged in 1998. Woodchipped in 1999. Habitat trees
cut off at ground level. Little more than Messmate saplings
left standing. Yellow-bellied Gliders, Powerful owls and
Barking Owls heard calling at Surrey Ridge in February
- Early September 1999 – Surrey
Ridge Picnic Ground – fires set under dead stags in the
area. yellow-bellied Gliders excluded from 6 trees in
the grounds. Powerful Owls and Barking Owls heard calling.
- December 1999 - T&W Rd logging
coupes stopped about 100 m from the Surrey River, where
a Masked Owl had been sighted (ATLAS report). Habitat
trees were cut off at ground level. Similar treatment
was given on the unlogged side of the road. A deliberate
attempt to destroy the habitat. A very large coupe of
clear-fell harvesting in this area, near Cut Out Dam Rd
to Boiler Swamp Rd.
This destruction occurred
despite a Public meeting at Heywood (16 Aug 99) to discuss
RFA Vol 1 Report, where a call as made by those present
in the audience to halt removal of any more mature, hollow-bearing
habitat trees. It was understood by
all that NRE would not do so. Indeed, following
the RFA Public Meeting at Heywood on 10 March 99, Field
Naturalists had called for a stop to ring-culling of all
hollow-bearing habitat trees in Cobbobboonee area, as
less than one third of mature trees remain since logging
began. The Portland Field Naturalists met Minister Tehan
and she agreed to act on the situation in the Portland
area. "..no ring-culling operations will be scheduled
in the Portland forests until the West RFA is signed."
(Media Release, 9 April 1999)
despite further calls from Portland groups, including
the Public Meeting at Portland on 9 Nov 99 to discuss
the West Victoria RFA Report Vol 2, urging NRE to stop
ring-culling and cull-felling of all habitat in the area.
This culling, NRE claimed,
was acceptable because they had only agreed not to
"ring-cull" the trees. A representative
of NRE at Portland had responded on 23 April 99 to the
Minister’s statement by saying that NRE would not schedule
any cull treatment operations until after the West RFA
was finalised. Duplicity personified. Is there any
wonder that NRE has lost the trust of the public?
Portland FNC had made
a detailed submission to Portland NRE concerning the Portland
FMA 1999-2001 Wood Utilisation Plan but had basically
been ignored (Portland Observer, 26 May 1999) and fobbed
off with bland assurances that NRE flora and fauna staff
would be involved in the forestry operations (Portland
Observer, 31 May 1999).
- Mid December 1999 -
NRE Forest Service began bulldozing and widening tracks
in the Beaugleholes Rd area of the Cobbobboonee. This
had been clearly marked as an area not to be logged, and
agreed by NRE. After a public outcry and appeal to the
Minister, Ian Miles (Acting Manager, Forest Management
Branch) NRE responded by saying " the harvesting
of the Beauglehole’s coupe has been postponed, pending
finalisation of the RFA for the west region. Due to an
unfortunate oversight, the annual track clearing program
in the general area has not been amended to reflect the
coupe’s postponement and some brushing up of old existing
tracks has resulted…" (Portland Observer, 17 January
00). Taking the charitable view that the "brushing
up" (bulldozing) was a mistake, that shows
incompetence on the part of NRE. Clearly there was no
satisfactory checking process in place to prevent such
contains many hollow-bearing trees, with Yellow-bellied
Gliders present. A bat roost tree is on the edge of the
road. A Powerful Owl was sighted there on 27 Dec 99 (ATLAS
- January 2000 – New
logging coupe on corner Fish Holes Rd and Boiler Swamp
Rd. This is a known Yellow-bellied Glider area. This coupe
is opposite 2 glider feed trees on the other side of the
road. Glider feed trees and habitat trees were removed
along Boiler Swamp Rd. GPS readings of the position of
these trees had been given to NRE a year earlier. Instead
of being protected these trees appear to have been targeted