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The Rainforest Project

The request or straight to The response

TO : The Honourable Sherryl Garbutt

CC Steve Bracks , Premier of Victoria

11 December , 2001

The undersigned groups wish to bring to the Minister’s attention our concerns regarding the conservation of rainforest in Victoria. Specifically, we are in unanimous agreement that the current definition of rainforest, as applied in the field by the Department of Natural Resources and Environment (DNRE), is scientifically flawed and therefore unacceptable. In addition, we believe that the relevant management prescriptions designed to protect rainforest are totally inadequate.

Victoria’s rainforests are remnants of the Gondwanic landscape and have existed virtually unchanged for in excess of 60 million years. Temperate rainforests of similar composition are found in Tasmania, New Zealand and South America. We are the guardians of a small, in terms of area, but significant, in a global context, biological resource.

According to the departmental definition there is only 15,000 hectares of rainforest in Victoria. Unfortunately this is pragmatic and not a scientific definition and the actual area of rainforest is closer to 40,000 hectares if the definition recognized by the Victorian Rainforest Symposium (1992) is applied. (Appendix I)

It is entirely unacceptable that the survival of these rainforests be jeopardised to accommodate managerial or financial expedience.

Threats posed to rainforest from logging operations include:

  •  Fire:

Rainforest species manifest as understorey when overlap with eucalypt forest occurs. The moisture gradient increases proportionally with the presence of rainforest species, and progressively increases towards the “pure” rainforest stand.

Within natural regimes (subject to lightning strikes and indigenous land management practices), these ecotones or overlaps acted as a fire buffer to protect the core of the rainforest. If the eucalypt and/or ecotonal forest is clear-felled the resulting regrowth tends to be dominated by (fire adapted) eucalypt species.

A combination of factors including height, density, flammability and fuel load of eucalypt dominated regrowth represent and increase the fire hazard to the rainforest, which is known to be fire sensitive. Rainforest species are killed by fire and the subsequent regeneration of those species is slow in comparison with eucalypt species. This results in forest structures and compositions quite different from those being replaced.

This situation is untenable given that NRE’s purpose and mandate is to ensure ecological sustainability.

  •  Myrtle wilt (in cool temperate rainforest): 

Nothofagus cunninghamii (Myrtle Beech) is susceptible to Myrtle Wilt disease which can introduced and/or exacerbated by the mechanical disturbances associated with logging.

  •  Microclimate changes:

Clear-felling alters the microclimate by increasing sun and wind exposure thereby reducing moisture content and regeneration capacity of rainforest.

  • Invasive species:

Weed invasion following logging disturbs natural regeneration processes.

Another emerging threat to rainforest is climate change. The effects of climatic change will be magnified and compounded by logging activities within proximity to rainforest. Rainforests are dynamic systems: they expand and contract according to climatic variables that are beyond human chronological sensitivity and comprehension. The implications of climate change are uncertain. Given this situation the application of the precautionary approach is imperative.

Benefits of applying a scientific definition (Appendix I) :

·        Protection of biologically rich areas; the interface between eucalypt  (sclerophyll) forest and rainforest is a rich tapestry of species diversity and interaction.

·         Linear riparian reserves act to protect water quality.  Clean water is fundamental to human health. Agriculture requires reliable supplies of clean water as do natural systems, e.g. estuarine systems (recreational fishing is worth $1.5 billion dollars to the Victorian economy and relies on healthy, viable natural systems). 

·         Act as genetic corridors - allowing movement of wildlife/insect/plant populations.

Buffer zones: Given the significance of this forest type, buffer strips should be a minimum of 350 metres for rainforest sites identified as being of national, state and regional sites of significance.

APPENDIX I – An ecological definition of Victorian rainforest.

Adopted by The Ecological Society of Australia (1980).

Adopted by the Rainforest Technical Committee (1986) in its report to the Ministers for Conservation, Forests and Lands and Planning and Environment.

Adopted by The Victorian Rainforest Symposium (1992).

“Rainforest is defined ecologically as closed (>70% projective foliage cover) broad‑leaved; forest vegetation with a continuous rainforest tree canopy of variable height, and with a characteristic diversity of species and life forms. Rainforest includes closed transitional and, seral: communities, with emergent eucalypts, that are of similar botanical composition to mature rainforests in which eucalypts are absent.

Rainforest canopy species are‑defined as shade‑tolerant tree species which are able to establish below an undisturbed canopy, or in small canopy gaps resulting from locally recurring minor disturbances, such as isolated windthrow or lightning strike, which are part of the rainforest ecosystem. Such species are not dependent on fire for their regeneration.”

The text in bold type was removed (without the consent or approval of the Rainforest Technical Committee) from the definition submitted to the relevant Ministers.

Yours sincerely

Bill and Ben

On behalf of the following groups:

Friends of the Earth (FoE) Australia

Friends of the Earth Forest Network 

Australian Conservation Foundation

Future Rescue

Native Forest Network Melbourne

Native Forest Network East Gippsland

Native Forest Network Australia Inc

Native Forest Network Yellowstone

Melbourne Clean Water Coalition

Good Wood Advisory Centre.

Friends of the Earth - Czech Republic

FoE – Sweden

FoE - England, Wales, Northern Ireland

Núcleo Amigos da Terra  (FoE Brazil)

FoE Finland

FoE Netherlands

Walhi - FoE Indonesia

CODEFF - FoE Chile


Native Forest Action (New Zealand)

Nature Conservation Council NSW

Lawyers for Forest Inc

Wombat Forest Society

Cobaw and Wombat Forest Action Group 

Concerned Residents of East Gippsland

Goongerah Environment Centre Office

Paperlinx Green Shareholders' Group

Australian Greens (Victoria) Inc

Doctors for Native Forests

Canopy Native Forest Committee

ForestEthics – US

Rainforest Action Network

South West Genaion Greens (Vic)

Lawyers for Forests Inc

Geelong Region Greens

Otways Ranges Environment Network

The Wilderness Society Victoria

Native Forest Network Southern Hemisphere

Gondwana Forest Sanctuary Interim Steering Committee

Monash University Environment Group

Environment Victoria

The response

From : Minister for Environment and Conservation

To : Friends of the Earth Australia

PO Box 222


0 8 FEB 2002


Thank you for your letter of II December 2001 to the Honourable Steve Bracks, Premier of Victoria, and myself regarding the protection of rainforest in Victoria. 

The Victorian Government is committed to the protection and maintenance of rainforest and its associated values. The State's rainforests provide a refuge for fire sensitive and moisturedependent species and contain a large number of species with links to the Gondwanan flora, a time when most of the Australian continent was covered by rainforest.

As a result of previous planning processes, virtually all of the National and State Sites of Significance for Rainforest are protected in the Comprehensive, Adequate and Representative (CAR) Reserve System across the State. Sites of lesser significance, including linear stands along watercourses throughout East Gippsland, the Central Highlands and the Otway Ranges, are protected through the Code of Forest Practices for Timber Production. The Code prohibits timber harvesting within the rainforest stand and a buffer of at least 20 to 40 metres of eucalypt forest adjacent to the rainforest stand must also be excluded from timber harvesting.

Your views regarding the importance of ecotones and gradations toward pure rainforest are acknowledged and this is the reason why the Code requires a buffer of eucalypt forest to be protected adjacent to each rainforest stand. The boundaries of many Sites of Significance also include buffers around the pure stands of rainforest and these areas are also included in the reserve system.

In recent years, a variety of rainforest variants has been identified, ranging from the mixed forests in the Central Highlands and East Gippsland to stands of dry rainforest in the Buchan Valley and other isolated areas in Gippsland. Particular attention has been given to the protection of these variants such that, for example, all stands of dry rainforest on public land are now protected in the CAR Reserve System. Commitments have also been made about the protection of mixed forest on the Errinundra Plateau in East Gippsland and in the Central Highlands. Again, the most significant stands are already protected parks and reserves. 

Myrtle Wilt is a natural disease of Nothofagus cunningharnii and is widespread in Victoria, including stands in parks and reserves that have not been subject to disturbances such as timber harvesting. Movement of people along walking tracks, road maintenance and timber harvesting can contribute to the spread of the disease. Standards to minimise this spread have been in place since 1995, including walking track and timber harvesting controls. The science of the disease was reviewed at the time of the 1996 review of the Code of Forest Practices, based on a detailed rainforest report by independent scientists, Dr Mark Burgman and Professor Ian Ferguson. Research on the disease in Tasmania, which was available when the independent rainforest report was prepared, suggested that buffer widths should reflect the characteristics of the stand.

As outlined above, in recognition of the potential spread of the disease through human disturbance, all timber harvesting activities are excluded from rainforest stands and an adjoining buffer of eucalypt forest. The Department of Natural Resources and Environment is monitoring various sites known to be susceptible to Myrtle Wilt in order  to determine if any changes are required in the current arrangements to avoid the spread of the disease.

I am aware that there has been debate about the definition of rainforest in the past. However, it is very important that Departmental staff have a workable definition to enable them to delineate rainforest stands in the field for various management purposes.

I presume your reference to the need for 350 metre buffers adjacent to Rainforest Sites of Significance is based on the work done on Myrtle Wilt in Tasmania. It is important to understand the context in which that recommendation was made. As you are probably aware, timber harvesting is permitted in rainforest stands in Tasmania. That research proposed buffers of 50 metres to 350 metres for extensive pure Nothofagus forests in Tasmania. The extensive stands of rainforest in Victoria have already been added to the conservation reserve system and are not subject to potential disturbance from timber harvesting. 

In other settings, such as the linear stands of cool temperate rainforest in the Otways, East Gippsland and the Central Highlands, a different response was proposed by the Burgman and Ferguson report. That Report recommended that buffers should be commensurate with the significance of the stands. For stands of lesser significance, such as those that remain in State forest, 20 to 40 metre buffers were recommended.

Measures to protect against disturbance, including possible disturbance from harvesting operations and windthrow, have focused on buffers that protect trees from wounding. The buffers established under the Code reflect this provision.

In respect of any changes to the Code, there is no new evidence that suggests that wider buffers are warranted. The listing of the disease under the Flora and Fauna Guarantee Act 1988 reflects current knowledge that was available at the time of the revision of the Code in 1995/1996.

Thank you for your interest in this important issue. 

Yours sincerely

Sherryl Garbutt                                                                                             I

Minister for Environment and Conservation

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