Chair 18 Feb 2000
West Victoria RFA Independent Panel
PO Box 502
East Melbourne Victoria 3002

Submission on

West Victoria 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.

Public participation

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 native forests.

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.

Thus, apparently:

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 be minimised.
• Large areas are preferable to small areas.
• 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

Employment

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

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 influence.

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 Gum regeneration.

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 MAP).

1. 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.
2. The area has a significant amount of Old Growth forest and E.obliqua not found in Reserves here.

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

1. Yellow-bellied Gliders and Powerful Owls are located in the forest east of North-South Rd
2. This is one area that NRE has yet to vandalise.
3. 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)
4. The unit is then large enough to be viable according to JANIS criteria, and to offer continuity for other species.

• Jens Rd Block. This block must be included for the following reasons:

1. It has the under-represented Herb-rich Foothill Forest (EVC 23), for which only 8% are currently suggested to be in recognised Reserves.
2. It is the known residence of Powerful Owls

• Dunmore Rd Block – this entire block should be reserved for following reasons:

1. It contains the under-represented Herb-rich Foothill Forest (EVC 23),
2. 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 submission..

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 against activities.
• 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.

5. 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 40 years.

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.

APPENDIX 1. HFNC submission to Parks Victoria on Black Range State Park Draft Management Plan (April 1998)

[Following are excerpts from this document that relate to RFA outcomes]

Hamilton 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 environment.

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.

We believe 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 below.

Plains grassy woodlands.

The Black 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.

Over 99% 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.

The existing 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 area.

The State 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".

The area 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 important.

The Black 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 of view.

References

APPENDIX 2. HFNC submission to Parks Victoria on Dergholm State Park Draft Management Plan (April 1998)

[Following are excerpts from this document that relate to RFA outcomes]

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.

• 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 Glider area

• 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 1998.

• 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.

• 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 "oversights".

• 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 by NRE.