TIMBER HARVESTING WITHIN SITES OF SIGNIFICANCE FOR RAINFOREST
David Cameron memorandum of understanding

A memorandum of Understanding. (File number 86/737) by David Cameron made recommendations for rainforest protection in the Otways. Ten proposed Rainforest Sites of Significance(RSOS) were nominated.

As of September 2002, information contained in this memorandum has never officially been made publicly available.

Extracts from Memorandum of Understanding (File number 86/737)

SUBJECT: TIMBER HARVESTING WITHIN SITES OF SIGNIFICANCE FOR RAINFOREST

TO: Paul Gullan, Manager, Flora and Fauna Survey and Management Group.
FROM: David Cameron Rainforest Project Botanist, Flora and Fauna Survey Management Group.

26th March 1990.

Survey of Rainforest in Victoria (Page 1)

The Flora and Fauna Survey and Management Group is currently conducing a statewide survey of rainforest. This project is partially funded by the Commonwealth Government through the National Rainforest Conservation Program and represents an integral part of the State's contribution and commitment to this Program. Victoria's component of this Program was launched in December 1986 and two of its objectives are:

- to improve knowledge and understanding of the rainforest estate; and

- to ensure careful management and protection of areas of rainforest.

The rainforest project was formulated to achieve the first objective and to contribute to the achievement of the second. To meet these objectives, the Project Description (fi1e 86/737, foios 44-49) requires that:

`The survey will identify sites of botanical significance and will assist in determining the need for further reservation or special management prescriptions.'

and further states that:

'The primary objectives (of the project) are to classify and map rainforest, to evaluate conservation status, determine sites of special significance and build a reliable information base for developing and applying land use prescriptions.'

Accordingly, the Project Description states that the penultimate stage in the project, prior to the preparation of the final report and maps, is to:

`Further analyse data to identify sites of significance and hence identify need for further reservation or management requirements.'

In effect, the project brief requires the development of a concept of the critical habitat requirements of Victoria's rainforest communities. Ultimately, it is envisaged that these rainforest communities will warrant nomination under the Flora and Fauna Guarantee Act.

Management Recommendations for Rainforest Sites(Page 5)

The State Conservation Strategy is explicit regarding the level of protection which, in general, should be accorded sites of biological significance. The Strategy states that:

"The Government will complete surveys of all sites or areas of ecological or scientific significance in the State and will take protective measures where appropriate. As a general rule, those sites significant at the State level or above will be preserved for nature conservation purposes and sites of regional or local significance will be protected wherever possible.'

The current protection by prescription (minimum 20 m or 40 m buffer) of rainforest in state forest, under the Code of Forest Practice, is considered to provide, minimal and doubtfully adequate protection for rainforest and is considered acceptable only for minor occurrences of local significance. Larger rainforest stands, defined as those which can be delineated by structural mapping using API at a scale of 1:100,000, are considered to warrant a minimum prescribed buffer of 100 m width.

In accordance with the State Conservation Strategy and the principle of catchment integrity for rainforest conservation, we recommend, on ecological! grounds, that timber harvesting and prescribed burning be excluded from all designated sites of regional, state or national significance for rainforest.

Together with the three tiered prescriptive protection proposed for rainforest stands
of local significance, (minimum prescribed buffers of 20, 40 or 100 m width according to width and size), and the management priority implied by the rating of sites of regional, state or national significance, our management recommendations provide a comprehensive six tiered approach to rainforest conservation throughout the state.

Accordingly, the Flora and Fauna Survey and Management Group has objected, through its representative on the .Cutting Areas Review Committee, to all harvesting proposed within sites of significance for rainforest. In its deliberations the Committee has focused attention on those coupes proposed for harvesting in the 1990/91 season. Schedules 1 to 6 list all coupes proposed for harvesting in 1990/91 Wood Utilization Plans submitted by each Region concerned, 'to which objection has been raised on the grounds that they fall, wholly or in part, within designated sites of significance for rainforest,

Policy Commitments and Obligations (Page 8,9)

A number of State Government and Departmental policy initiatives and commitments have a direct or indirect bearing on the issue of timber harvesting within sites of significance for rainforest.

The first is the Rainforest Policy which, as a component of the State Conservation Strategy, commits the Department to protect all rainforest from harvesting and other disturbances. The ambiguity regarding the legitimacy of the Department's amended definition of rainforest calls for a conservative approach to harvesting in the vicinity of rainforest and a moratorium on activity within communities which comply with he ecological definition of the Rainforest Technical Committee, as required by the Strategy.

The State Conservation Strategy further commits the Government to protecting all sites of significance and wherever possible, sites of regional significance.

The likelihood that Victorian rainforest communities will be nominated under the Flora and Fauna Guarantee Act implies that continued activity within areas (especially designated sites of significance) likely to be defined as critical habitat for rainforest communities is in conflict with the spirit of the Guarantee and should be avoided.

Through its participation in the National Rainforest Conservation Program, in co-operation with Commonwealth Government, the State Government has an obligation to `ensure careful management and protection of areas of rainforest', particularly of sites of significance identified by the rainforest study partially funded by the Commonwealth.

The Department also has an obligation to the community to maintain flexible options for consideration by the Land Conservation Council in current and forthcoming. investigations. The Council is currently reviewing land use in the Corangamite and Melbourne (District 2) Study Areas. These reviews are likely to determine land use decisions affecting rainforest sites in the Otways and Central Highlands. In its Final Recommendations for the East Gippsland Area Review, the LCC also states that:

`The Council will be conducting an investigation of rainforests in Victoria with a view to making recommendations on the range of uses for them and the way in which they should be protected through reservation. The rainforests in East Gippsland will be included in that in that investigation. Information collected by the Department of Conservation, Forests and Lands will provide a basic and important input.'

It is inevitable that sites of significance identified in this project, and the values associated with them, will form the focus of the Council's special investigation into the conservation status of Victorian rainforests and the adequacy of their representation within the current reserve system. Failure to protect sites of significance for rainforest from harvesting in the interim is likely to be seen as pre-empting the outcome of each of these investigations.

We recognise that the Department also has commitments under the Timber Industry Strategy and that commitments to the timber industry are likely to be difficult to meet, particularly in some Regions where contingency provisions are inadequate to cover harvesting exclusions for a variety of reasons, including protection of sites of significance for rainforest. In the event that in any particular Region the Department is unable to meet its commitments under the TIS and it is obliged to consider harvesting within sites of significance, then we recommend that the following guidelines be observed. In the spirit of the State Conservation Strategy, sites of regional significance should be assessed on a site by site basis and harvesting priority be given only to sites with a history of recent forestry activity. Within such sites harvesting should be approved only up slope of prior harvesting, preferably limited to ridgelines and upper slopes, and sub-catchment units containing rare or threatened species populations or other unique or special features should be avoided altogether. In general, no harvesting should be contemplated within sites of state or national significance, although a rare exception may be made where there is a demonstrable history of extensive recent harvesting. In all cases, harvesting within any designated site of significance must be excluded from a minimum prescribed rainforest buffer width of 100 m. In the event that a decision is made to permit harvesting within sites of significance, we recommend that CARC(cutting areas review committee) be reconvened to thoroughly reassess any proposals to harvest within individual sites of significance.

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