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The Victorian Government is doing a Major Event Review on the impact the 2019-20 bushfires had on native forests and the native forest logging industry.

It’s hard to forget the intensity and unprecentted scale of the Black Summer bushfires. The impact on lives, homes, landscapes and wildlife is still difficult to comprehend. Many of the ecological consequences of the fires aren’t yet understood.

A key aim of the review is to figure out how the impact of the bushfires affect Victoria’s Regional Forest Agreements (RFAs). RFAs are the long-term plans for managing native forest logging in our state.

We now have a rare opportunity to pressure the state government to restore native forests, not log them.

SUBMISSIONS CLOSE: TUESDAY 31 AUGUST (11:59pm)


Who is conducting the review?

An independent panel established by state and federal governments:

  • Dr Gillian Sparkes, Victorian Commissioner for Environmental Sustainability.
  • Ms Katherine Mullett, a proud Gunaikurnai, Ngarigo Monero woman with a background in Cultural Heritage Management and Land Management.
  • Dr Tony Bartlett, forester.

Feedback on the summary report will be collated and provided to the panel. The panel will also be informed by Traditional Owner knowledge, science and conversations with the community through meetings and consultation.


The Victorian National Parks Association perspective

Our key concern is the cumulative impacts of drought, bushfires, habitat loss (through native logging) and future extreme climatic events on Eastern Victoria’s ecological communities.

The immediate loss of habitat (such as hollow-bearing trees), native vegetation, predation (from invasives like cats and foxes), and browsing by invasive herbivores (like deer) poses an immediate threat to endemic plants, animals and insects.

The review must not underestimate the importance of unburnt refuge areas within and outside of the fire footprint.


How can my organisation or I participate?

Individuals and organisations are invited to contribute their views ‘on the impacts of the 2019-20 bushfires on Victoria’s Regional Forest Agreements’.

A summary paper has been prepared and published on the Engage Victoria’s ‘Major Event Review For Victoria’s Fire Impacted Forests’ webpage. The process for submitting is outlined on the webpage.

Consultation sessions are being held in Eastern Victoria between 30 August & 14 September 2021.

Making a submission

We’ve prepared an editable Microsoft Word document that outlines the key issues in greater detail. You can download and modify this document as the basis of your own submission.

Draft submission – outline of our key issues (Word)

Download or read our Major Event Review submission (PDF)

Once you’ve completed your submission, visit the Engage Victoria Major Event Review webpage and scroll down to the ‘Upload a Submission’ section.

You’ll be guided through the process. Please let us know when you’ve made a submission or if you need assistance. Email v[email protected]

SUBMISSIONS CLOSE: TUESDAY 31 AUGUST (11:59pm)

 Key issues

We’ve identified ten key issues that must be addressed for the review to be effective. There’s likely many more, so it’s important to add your own experiences and knowledge.

  • Assessing implications of climate change, fires and forests
  • Protecting unburnt forest refuges
  • Old growth impacts
  • Impact on threatened species and communities
  • Impact on logging yield
  • Impact on the reserve system
  • Impact on ash forests
  • Better management post fire
  • Protection of large old trees
  • Impact of salvage and post-disturbance logging

Read the ten key issues in depth below

Assessing implications of climate change, fires and forests

The bushfires of 2019-20 are the third landscape-scale fires to burn through over a million hectares in the last 20 years. This frequency and intensity is consistent with the minimum 1.5°C climate change scenario, and should be a key consideration of the Major Event Review.

The current Regional Forest Agreements (RFAs) have 16 clauses that mention climate change. Climate change is mentioned over 40 times in the East Gippsland RFA and similar in other RFAs. Yet the Major Event Review summary document does not mention climate change.

Key Points:

The implications for climate, the links to extreme fire and the combined impact of logging should be assessed in detail and at regional scale in the Major Event review. Climate change will have profound impact on the capacity of the forest to supply both wood/pulp and habitats in the future.

Specifically address climate resilience action identified in the RFAs ( clauses 15R and 52 E, 52F ), such as:

  • Ensure all EVCs that are Climate Change Vulnerable are afforded additional protections beyond that provided for under the JANIS Reserve Criteria.
  • The identification and protection of refugia.
  • Protect important occurrences of the species or community in the CAR Reserve System and maintain or restore ecological management regimes to ensure its viability.
  • Improve climate change resilience and future viability of Listed Species and Communities and other MNES informed by best practice approaches, best available science and Traditional Owner knowledge.
Protecting unburnt forest refuges

The Victorian National Parks Association, with East Gippsland community conservation groups, commissioned an analysis of the impact of the bushfires on a range of threatened plant and animal species in Eastern Victoria. The analysis also assessed the impact of ongoing logging on remaining forest spared from the flames.

The released joint report After the Fires: Protecting Our Forest Refuges used the Victorian Government’s own spatial data and focused on ten forest areas: Errinundra, Cottonwood, Cabbage Tree, Far East Gippsland, Swifts Creek, Nunniong, Colquhoun, Mt Alfred, Sardine Creek to Bemm, and the North-East Alpine Region.

Many of these unburnt and lightly burnt refuge areas contain extremely valuable and rich habitat features essential for the rehabilitation, recruitment and dispersal of wildlife into recovering forests. The analysis revealed:

  • Of the 585,000 ha of state forests in the East Gippsland forest management areas, only 112,000 ha is outside the fire extent. Of that unburnt forest, 90,000 ha remains unprotected and open to habitat loss caused by native forest logging.
  • Across the 10 refuge areas, 553 logging coupes covering more than 20,000ha of forest are planned for logging by the Victorian government’s logging agency VicForests.
  • Not only have there been no reductions or substantive changes to existing logging plans since the bushfires, two additional logging schedules have been approved by state-owned VicForests in the 12 months since the fires.

Key Points:

The After the Fires report makes the following recommendations, which should be considered by the Major Event Review.

  • Protect each of the key refuges identified in the report and any other remaining unburnt forests from current and future logging, to ensure the survival and persistence of flora and fauna species that rely on these forests to survive.
  • Commit to not logging any identified habitat remaining in Victoria for each threatened species significantly affected by the 2019-20 bushfires, particularly those species listed in the report.
  • Bring forward the 2030 transition out of native forest logging. In November 2019 the Victorian government committed to a decade-long transition out of native forest logging. Doing so sooner would avoid further damage.
  • Prioritise funding and restoration of areas impacted by the bushfires to restore habitat and provide better resources for weed and pest control programs in forest areas to improve recovery from bushfire events.
  • Declare and map the key refuges identified in this report as high priority assets in need of protection from all types of future fires, including planned burns.
Old growth impacts

Protection of old growth forest is a vital issue. It is identified in the East Gippsland RFA (Section 52A, 52B) for its ‘environment and heritage values’. It is clearly in scope of the MER as it is a part of criteria in the Comprehensive and Adequate and Representative Reserve System (CAR) (clause C, in MER Scope). Impacts on old growth forests are not mentioned in the MER summary report.

When old growth forests are burnt, they are no longer considered to be old growth. This leaves the old growth forest estate vulnerable to exploitative logging following fire, even if values on the ground remain and fire severity was less than modelling showed. Despite commitments in East Victoria to protect old growth forest, this loophole is of great concern. It also begs the question of how much old growth is actually left and how a commitment to “90,000 hectares of Victoria’s remaining rare and precious old-growth forest … will be protected immediately” can be delivered.

Key Points:

  • Old growth forest is crucial. The value of the RFAs are impacted by fire and should be assessed in detail by the MER.
  • Assess in detail how remaining old growth values were impacted in the 2019–20 fire season, including mapping, and assess how those values will be protected post fire
  • Update the old growth forest identification assessment tool, including re-evaluating disturbance thresholds, to enable old growth forest to be protected in all its forms across different forest types and species.
  • Identify mechanisms to deliver commitment to protect 90,000 ha of old growth.
Impact on the reserve system

The regional forest agreement require the Victoria to establish a Comprehensive and Adequate and Representative Reserve System (CAR), some of these are formal reserves like national but mostly in Victoria they relate to fixed zoning system, like special protection zones.

The impact on the CAR reserve system and Immediate Protection Areas in East Gippsland was extensive with much of the CAR reserve system areas (Special Protection Zones and Management Areas) set up within the RFAs severely impacted by fire.

The Interim Protection Areas (IPAs) were committed to by the Government in 2019 to protect Greater Glider habitat as a conservation measure in the Greater Glider Action Statement under the FFG Act [1] The IPAs are yet to be formalised by government, 18 months after the announcement.  East Gippsland IPA were also heavily impact by fire, with 71% of it severely burnt.

Key points:

  • CAR reserves under RFAs need to be formalised and expanded to meet needs of threatened species and ecosystems
  • Interim Protection Areas (IPAs) need to be formalised and expanded to meet needs of threatened species and ecosystems
[1] https://www.environment.vic.gov.au/conserving-threatened-species/threatened-species-fact-sheets/greater-glider
Impact on ash forests

The ongoing impact of the fires on Alpine Ash and Mountain Ash forests are also of great concern.

The bushfires in 2019–20 burnt 4,286 hectares of Mountain Ash forest and 52,516 hectares of Alpine Ash forest (DELWP 2020). The 2009 Black Saturday fires burnt 78,200ha of Mountain Ash forest in the Central Highlands. The remaining Ash forests of Victoria now rest on a knife’s edge. The management of these forests now will determine if we have Ash forests at all in the future.

RFAs tend to ignore the successive or cumulative impact of bushfire, despite the occurrence of multiple extensive fires in the last 10 years. The issue of fire is complex, yet the RFAs ignore fire impact on both the extent and structure of the forest. The RFAs also fail to consider the implications of fire on resource availability for industry. Less wood in Gippsland may also mean more logging in the central highlands.

Key Points: 

  • The MER should consider the cumulative impacts of fire and logging on the landscape and capacity of the forest to supply wood products particularly in Ash forests.
  • The MER should also consider the likelihood of increased fire frequency under climate change and the flow on effects to future yield of wood products particularly in Ash forests.
Logging yield & supply

The 2019–2020 fires impacted around 50% of available annual volume in native forest, pushing the already declining industry into further decline. Almost 40% of the General Management Zone (the area open for logging) in East Gippsland was impacted by fire.  

The overall impact of the fire is significant on supply of native forest products. We are concerned that the impact on forest in East Gippsland, Gippsland and North East will drive additional logging in other parts of the state such as central highlands or is more inaccessible or sensitive areas.  

With the dramatic decrease in timber yield resulting from the fires, as well as likely future fires further decreasing potential yield in the future,  the targets in the State Government’s Forest Plan to phase out native forestry by 2030 and timelines need to be reassessed. 

Key Points: 

  • Review yield against future fire predictions, climate change and the exit target in the Forestry Plan.
  • In the context of reduced supply, the transition out of native forest logging should be brought forward, with relevant increase in funding to support worker and industry transition.
  • Introduce peer review and clear transparency around wood modelling, and the assumptions used.
  • Develop a clear break down of segments of yield, sawlog, and pulp log over time and the relationship with sustainable yield. 
Better management post-fire

Forest ecosystems are at their most fragile and vulnerable after large disturbance events such as bushfires. Australian forest types are adapted to fire to an extent, but further disturbance associated with pest plant and animal invasion, salvage logging, removal of hollow bearing trees and use of heavy machinery in areas recovering from fire delays the recovery of forest ecosystems for decades after the fire and in some cases could lead to permanent damage to ecosystems. Reduction of threats to the recovery of forests immediately after fire and for many years after is needed to allow these areas to natural regenerate and recover from mass disturbance events.

The responses by the state government: initiating the ‘Victoria’s bushfire emergency: biodiversity response and recovery’ program; and funding the Bushfire Biodiversity Response and Recovery Program is to be commended, but longer term programs are also needed.

Key Points:

  • Develop weed and pest management plans for the regions impacted by the fires taking into account local conditions, values, species and threats. 
  • Secure long-term funding of weed management programs in fire affected regions on a 3-5-year basis. 
  • Expand large scale management programs to control pest carnivores such as cats and foxes, building on the work of the Southern and Glenelg Ark programs run by DELWP. 
  • Introduce plans for sustained reductions of pest herbivore species such as deer, pigs and horses. 
  • List of deer as a pest species in Victoria to remove confusion for land managers and owners across all land tenures. 
Protection of large old trees

The protection of large old trees in native forests is pivotal to combating the decline of large old trees across the landscape. Protecting these trees also protects threatened species such Greater Gliders and Leadbeater's Possum that require the hollows in these trees as habitat. The loss of hollow bearing trees from Victorian native forests and woodlands is recognised as a threatening process under the Flora and Fauna Guarantee Act 1988. Large old trees are also important for carbon sequestration. 

The current protections for large old trees are inadequate and should adopt the Australian Standard, Protection of Trees on Development Sites used in most other industries, to expand the protection zone around these important trees and protect them from logging.  

The impacts of the 2019–20 fires on the old growth forest and large old trees needs to be understood due to the importance of old growth forests as wildlife habitat, ecosystem recovery and carbon sequestration. 

Key Points:

  • Develop publicly available mapping of all large old tree remaining in areas impacted by the 2019–20 bushfires. 
  • Protect large old trees by implementing Australian Standard, Protection of Trees on Development Sites (AS4970 2009) in areas impacted by logging, roading and other development works. 
  • In areas with high densities of large old trees and hollow bearing trees, logging should be excluded. 
  • Replace the criteria for large old trees to have a dbh of 2.5m or more with a more ecologically appropriate definition to include smaller ecologically significant trees. 
[1] https://www.environment.vic.gov.au/conserving-threatened-species/threatened-species-fact-sheets/greater-glider 
Impact on threatened species and communities

In Victoria during the 2019–20 fire season, 244 species had more than 50% of their modelled habitat within the burnt area, including 215 rare or threatened species (Flora and Fauna Guarantee (FFG) Act). Of those species, 43 had more than 50% of their modelled habitat impacted by high severity fire, and all but one were considered rare or threatened species (FFG Act). This placed extreme and acute stress on those populations. 

When considered with the additional threat from ongoing forestry operations, many of these species are at great risk. There are at least 23 threatened species and communities that are at high or significant risk as a result of forestry operations, mainly from loss of hollow-bearing trees, habitat loss and fragmentation, direct mortality, loss of feed source or sedimentation effects. Examples include Giant Burrowing Frog, East Gippsland Galaxias, Glossy Black-Cockatoo, Leadbeater’s Possum and Diamond Python. The MER must address the protection of these species within their broader risk context. 

Key Points for Major Event Review:

  • Implement critical habitat determinations under the FFG Act for protection of key unburnt areas of high conservation significance.  
  • Undertake a detailed gap analysis of forest dependent species on the new FFG list acknowledging the impacts of the 2019–2020 bushfires, and the longer-term impacts of climate change and logging. 
  • Take appropriate action to protect important occurrences of the identified species or communities in the CAR reserve system and maintain or restore ecological management regimes to ensure its viability. 
  • Recommend that action statements be prepared for all identified forest dependent species list on the new FFG list within the next two years. 
Impact of salvage and post-disturbance logging

Post fire or salvage logging is one of the most destructive forms of logging and has long lasting impacts on the forest ecology and health as well as forest dependent wildlife.

Salvage and post-disturbance logging subject native forests to the mechanical pressures of logging during the post-fire recovery stage of the vegetation, compounding various disturbance pressures of both fire and logging. Added claims that salvage logging assists with fuel reduction are contrary to studies which show that it can actually increase bushfire risk, because the salvage logging slash increases fine surface fuels on the ground.

With a planned 2030 phase out of native forest logging in Victoria, the impacts of salvage/post-disturbance logging will linger for many generations after the logging industry has finished, leaving a legacy of degraded and less resilient forest landscapes in the face of a rapidly changing climate.

Key Points:

  • Unsustainably high yield levels should be avoided in high conservation value fire impacted areas where these levels currently drive salvage and post-disturbance logging which damages recovering ecosystems and threatened species.
  • Establish long term monitoring plots across all FMA areas that have been subjected to salvage and post-disturbance logging to further understand the impact.
  • Undertake ecosystem recovery works if suitable.