Destructive logging laws slammed by government scientists

Freedom of information documents reveal damning assessment of Berejiklian government’s proposed new logging laws

As the NSW and federal governments are poised to sign off on 20-year extensions to controversial Regional Forest Agreements, documents acquired by the North East Forest Alliance under freedom of information show deep concerns within the Office of Environment and Heritage (OEH) about the impact of new logging laws on protected old-growth, rainforest and koalas.

OEH’s concerns echo those of environment groups and illustrate clearly that the laws will destroy the natural values of our forests. Reminiscent of when Environment Minister Upton signed off on new land clearing laws despite departmental advice that 99% of koala habitat was at risk from clearing, the government is again ignoring OEH advice that koala deaths will increase and habitat quality decrease as a result of the new laws.

Further, the documents reveal that the recommendation by the Natural Resources Commission to allow logging of  forest protected as oldgrowth forest, rainforest and stream buffers for the past 20 years was contrary to the recommendations of the Expert Fauna Panel and that the Panel’s considerations of required protections were based on the erroneous assumption that all these important fauna habitats would be protected.  OEH recommends many of the panel’s recommendations for threatened species need to be revisited in light of the new logging proposals..

On top of recent revelations about the deep unpopularity of native forest logging in the broader community, the National Parks Association (NPA) and North East Forest Alliance (NEFA) are calling for the government to scrap the new laws (called Integrated Forestry Operations Approvals) and chart an exit out of native forest logging.

“The documents show that a keystone of Premier Berejiklian’s draconian changes to the logging rules for public forests is that some 58,600 ha of High Conservation Value Oldgrowth and 50,600 ha of rainforest in north-east NSW may be made available for logging”, said Dailan Pugh of the North East Forest Alliance.

“These forests were protected over 20 years ago as part of NSW’s reserve system because they are the best and most intact forest remnants left on state forests. As logging intensity has increased around them their environmental importance has escalated.

“North East NSW’s forests are one of the world’s centres of biodiversity and now Premier Berejiklian wants to extend her increased logging intensity into the jewels that the community saved.”

Dr Oisín Sweeney, Senior Ecologist with the National Parks Association of NSW (NPA) said: “It’s no wonder the public is sick of native forest logging and that it has lost its social license.

“Here we have clear warnings from OEH that more koalas will die and more koala habitat will be lost. Yet the government’s determined to plough on regardless.

“It’s past time the federal government intervened to stop NSW knowingly driving koalas further towards extinction.” ENDS

Media contact: Dailan Pugh (6680 7063); Oisín Sweeney (9299 0000)


Extracts from NSW Office of Environment and Heritage Conservation and Regional Delivery Division North East Branch (NEB) ‘Submission to the NSW Environmental Protection Agency on the Draft Coastal Integrated Forestry Operations Approval remake’ obtained through freedom of information

The Draft Coastal IFOA appears to enable boundaries separating the CAR reserve system and the harvest area to be amended by inter‐agency agreement with no public consultation. Further, amendments to the boundaries could occur at the scale of the local landscape or even individual compartment. Areas would be assessed in isolation, rather than at a regional scale, and thereby be susceptible to the incremental ecological impact that regional assessments were originally introduced to prevent. This is expected to significantly compromise the CAR reserve system over time.

The NEB therefore reiterates the recommendation from the Expert Fauna Panel for the ‘permanent protection of current exclusion zones’ (State of NSW and the Environmental Protection Agency 2018, p.8) and recommends that the Draft Coastal IFOA include specific provisions that protect all areas that have been protected by the FA, RFA and current IFOA over the last 20 years.

Intensive and selective harvest areas

The CAR reserve system was established in conjunction with selective logging regimes that maintained structurally diverse forest throughout the harvest area. The Draft Coastal IFOA appears to increase the area of public forests on the north coast that would be legally available for intensive harvest, with the risk that large areas of forest will be reduced to a uniform young age class that would take many decades for full ecological function to be restored.

In the intensive harvesting zone (the Coastal Blackbutt forests of the north coast hinterland), the Draft Coastal IFOA proposes to allow coupes of up to 45 ha to be logged with no lower limits on the number of trees retained in the harvest area.

This proposed minimum basal area retention of trees in the harvest areas is below the minimum threshold required to maintain habitat values advised by the majority of the Expert Fauna Panel.

The Draft Coastal IFOA proposes removing the existing requirement to protect habitat ‘recruitment trees’. Over time, this will reduce the number of large habitat trees retained for ecological purposes in harvest areas, as trees die and are not replaced. Recruitment trees identified previously will now be available for harvesting, further reducing the persistent availability of larger trees as a critical habitat element for threatened and protected fauna.

High Conservation Value (HCV) Old Growth

HCV old growth was identified for protection as part of the CAR reserve in 1998. It was comprised of older forest (mapped as ‘candidate’ old growth) that also scored highly for irreplaceability (a measure of significance to biodiversity conservation) and threatened species habitat value. Under the Draft Coastal IFOA, biodiversity values of harvest area will be reduced as the area becomes progressively younger (potentially 21 years old or less). For threatened species, this places greater significance on adequately protecting existing HCV old growth areas.

The NEB recommends that areas of HCV old growth that have been protected for at least 20 years (NRC 2018) are not made available for logging. This will minimise impacts on threatened species.


The concerns raised above in relation to the treatment of old growth under the Draft Coastal IFOA also apply to protected rainforest. Combined, HCV old growth and rainforest form the cornerstone of the CAR reserve system on State forest. Adequate retention of these vegetation types is considered particularly critical in the context of proposed increased logging intensities.

Specific threatened species conditions

Identifying the species that required species‐specific conditions was a major task for the Expert Fauna Panel. However, the Panel’s deliberations occurred prior to the proposals to allow logging access to HCV old growth and rainforest (NRC 2018). Therefore, many of the panel’s recommendations need to be revisited in light of the new logging proposals. For example, some of the old growth dependent species (such as those that require hollows) were considered not to require species‐specific conditions because the existing HCV old growth was protected. Similarly, for many rainforest‐dependent species, and those dependent upon riparian habitats, species‐specific conditions were not proposed on the assumption that the habitat of these species was considered sufficiently protected.

Koala protection

There appears to be a reduction in protections offered to koalas under the Draft Coastal IFOA. Koalas are selective both in their choice of food tree species and in their choice of individual trees. The scientific basis for proposed tree retention rates in the Draft Coastal IFOA is not clear, and the rates are less than half those originally proposed by the Expert Fauna Panel.

While Koalas will use small trees, research has shown that they selectively prefer larger trees. In our experience, the proposed minimum tree retention size of 20cm dbh will be inadequate to support koala populations and should be increased to a minimum of 30cm dbh. Many Koala food trees are also desired timber species, so there is a high likelihood that larger trees will be favoured for harvesting, leaving small retained trees subject to the elevated mortality rates experienced in exposed, intensively‐logged coupes.

Koalas require large areas of connected habitat for long‐term viability. The increased logging intensity proposed under the draft Coastal IFOA is expected to impact Koalas through diminished feed and shelter tree resources. Animals will need to spend more time traversing the ground as they move between suitable trees that remain, which is likely to increase koala mortality.