MobiriseTo whom it may concern,
We are concerned about a potential breach of the EPBC Act on Fellas Coupe, in Turtons Creek, Victoria which is being logged by Hancock Victoria Plantations (HVP). We are concerned EPBC listed species are being directly and indirectly impacted by actions associated with current logging practices. The coupe is in an area with high conservation values, including state and federally listed threatened species, and directly adjacent to conservation covenanted properties. The risks of offsite impacts are thus greater in this context.
The species of most concern
There are multiple EPBC species that occur in the region, but in this context we are particularly concerned about the direct and indirect impacts to the EPBC listed Pilotbird (Pycnoptilus floccosus, Vulnerable) and Gang-gang Cockatoo (Callocephalon fimbriatum, Endangered), which have been recorded on the plantation (onsite) and on adjacent (covenanted) properties (offsite).
The EPBC listed Pilotbird (Pycnoptilus floccosus) is listed as Vulnerable. The species was significantly impacted in the 2019/2020 wildfires, with 47% of the species’ overall distribution burnt (Legge et al. 2021), resulting in a possible 30% decline in numbers. It is highly likely that the current actions by HVP will cause further decline to the current Area of Occupancy (AOO) for a species already in decline. Unburnt habitat critical to their survival is found on the logging coupe, and directly adjacent to the coupe on private covenanted properties. This critical habitat includes ‘wet sclerophyll forests, in moist gullies with dense undergrowth’ (Higgins & Peter 2002; DAWE 2022), with an emphasis of the importance of unburnt vegetation, given the impacts of the 19/20 fires. Pilotbirds are ground-dwelling, ‘weak’ flyers (i.e no more than 1-2 m from the ground; Higgins & Peter 2002; DAWE 2022), and therefore at greater risk of habitat loss and fragmentation, as the birds will be unlikely to move great distances. For the Pilotbird, the risk of habitat loss and degradation due to logging is described as a stable threat, with major consequences, but with unknown confidence. We suggest in the following section that the current practices will lead to major and unacceptable consequences for the species both on and off-site in this area.
The Gang-gang Cockatoo (Callocephalon fimbriatum) is Endangered under the EPBC Act, is known to be located in south-western Gippsland (Higgins 1999; Menkhorst et al. 2017), and has been recorded and monitored (nesting and feeding) on the conservation covenant adjacent to the coupe in damp and wet Eucalypt forest. As with the Pilotbird, the Gang-gang cockatoo was severely impacted by the 19/20 wildfires, with 28–36% of known habitat burnt (Legge et al. 2021). This compounded an already declining trajectory, including due to clearance of habitat, including by forestry (DAWE 2022). Gang‐gang breed in mature forest and are less abundant in regenerating forest 10-15 years after logging (Higgins 1999). As the current operation is clear-fell logging of both native forest and planted bluegum (see below), we characterise this as land clearing, which is listed as a severe, current threat with known consequences in the relevant Conservation Advice for the species (DAWE 2022). Logging has a lower consequence noted in the Conservation Advice, though this appears to be associated with forestry practices not reflected in current HVP practice.
Current logging activities by HVP
We understand logging is an existing action that may have previous approval under the EPBC Act, but we believe the current actions are likely to have, or are having, a significant impact on Matters of National Environmental Significance. We believe the remaining unburnt habitat for the species is particularly critical, and that the shifting baseline in (declining) population size should be accounted for. Specifically:
HVP are converting the hardwood plantation (bluegum) to a pine plantation, which have a number of indirect impacts on at least two EPBC listed species. We believe the conversion to pine plantation may constitute an alteration of the approved action, or a new action. In either case, the action is likely to have significant impact on EPBC listed species, particularly the Pilotbird (Pycnoptilus floccosus, Vulnerable) and Gang-gang Cockatoo (Callocephalon fimbriatum, Endangered). In addition, we are waiting for confirmation from the Victorian Environment and Agriculture Ministers (Minister Dimopoulos and Minister Spence), but it is our understanding that 10,000 ha of existing hardwood plantations in the Eastern Strzelecki Ranges (outside of the Cores and Links area) are progressively being converted from hardwood to softwood plantation as part of HVPs operations, without consideration of the local site context. This is likely to have very significant detrimental impacts on multiple listed threatened species, beyond those which are the focus here.
HVP have decided they will not comply with the Flora and Fauna Guarantee Act, so are logging within 20m of rainforest and wet eucalypt forest gullies on Fellas coupe and on the adjoining property. These gullies and buffers are habitat for EPBC listed species, including the Pilot Bird and the Gang-gang cockatoo, which have been recorded on Fellas coupe and on the adjoining property.
HVP have been logging native vegetation within the coupe, including Mountain Ash. Note this vegetation has been mapped by the logging company as plantation since it was last logged (in the 1970s). Council hired an independent consultant (Pathways Bushland & Environment consulting), who has recently provided a report to council that notes there is vegetation on the lease area that is classified as plantation but unable to be distinguished from native forest (specifically Wet Forest and Damp Forest). The report from the consultant is attached. This breach has also been reported to the Office of the Conservation Regulator in Victoria.
HVP have logged native forest vegetation on a Council road reserve, in habitat suitable for the EPBC listed Gang-gang Cockatoo, Pilotbird and Blue-winged Parrot (all recorded in the area). This breach has been reported to the Office of the Conservation Regulator in Victoria.
Associated threats
Given the actions described above, there is a high degree of confidence that the current logging activities will fragment, alter and degrade the remaining habitat for both species (both on the coupe in remaining habitat, and offsite, particularly in gullies on the properties adjacent to the site), as follows:
There is published research documenting the associated higher invasion risk of pine (compared to blue gum) into surrounding vegetation (Calviño-Cancela and van Etten 2018), and the associated degradation of habitat (Brockenhoff et al 2008), so the confidence in our understanding of this negative impact is high. Introducing this particular invasive species to the site will increase the associated risk of weed invasion in the remaining critical habitat both on and offsite, and in the surrounding landscape. We suggest the plan to replant the site with pine compared to the (risk-weighted consequences associated with an) option of replanting a eucalypt plantation contravenes the precautionary principle because there is a higher likelihood of degradation of habitat for the species in a pine plantation.
Removal of vegetation surrounding the gullies will lead to drying of the remaining habitat, and logging of native forests also makes them much more flammable (Lindenmayer et al. 2021).
It is extremely likely there will be increased runoff of soils and associated chemicals (from spraying of the coupe) due to the topography and soil type in the area. The area is currently subject to the Environmental significance overlay ‘ESO5 – Areas susceptible to erosion’ under the planning scheme. Of direct relevance, the Code of Practice for Timber Production 2014 (as amended 2022) (Department of Environment, Land, Water and Planning, 2022) specifies: "On slopes with a high soil erosion hazard or where there is an assessed risk of mass soil movement, additional measures must be taken to avoid movement of soil into streams, such as modification to harvesting methods or increasing of the widths of buffers and filter strips". No such erosion mitigation appears to be in place.
Last, removal of the surrounding dense forest vegetation will leave the individuals in the remaining fragmented gullies at increased risk of predation (Hohnen et al 2016; Stobo-Wilson et al 2020), by both cats and foxes in this location.
Despite multiple reports, the South Gippsland Shire Council and the Office of the Conservation Regulator (DEECA) are not enforcing compliance with legislation, including the Flora and Fauna Guarantee Act.
We are unaware of the conditions of the licence under the EPBC Act, but would like to understand:
If the current logging practices by HVP, including the conversion to pine plantation, removal of native vegetation, and not leaving adequate buffers around critical habitat, constitute a significant indirect impact under the EPBC Act, to the listed Pilotbird (Pycnoptilus floccosus, Vulnerable) and Gang-gang Cockatoo (Callocephalon fimbriatum, Endangered), through degradation of habitat on either (or both) the unlogged gullies on Fellas Coupe or those on the adjoining property.
If the conversion from hardwood plantation to a pine plantation constitutes a change (or alteration) in action, which does not have approval under the EPBC Act. Note, as mentioned above this conversion to pine plantation by HVP is not restricted to this coupe, and is likely to have broader and cumulative significant impacts to EPBC listed species in Gippsland.
Brockerhoff, E.G., Jactel, H., Parrotta, J.A., Quine, C.P. and Sayer, J., 2008. Plantation forests and biodiversity: oxymoron or opportunity?. Biodiversity and Conservation, 17, pp.925-951.
Calviño-Cancela, M. and van Etten, E.J., 2018. Invasive potential of Eucalyptus globulus and Pinus radiata into native eucalypt forests in Western Australia. Forest ecology and management, 424, pp.246-258.
Department of Agriculture, Water and the Environment 2022, Conservation advice for Callocephalon fimbriatum (Gang-gang Cockatoo), Canberra.
Department of Agriculture, Water and the Environment 2022, Conservation advice for Pycnoptilus floccosus (Pilotbird), Canberra.
Department of Environment, Land, Water and Planning, 2022. Code of Practice for Timber Production 2014 (as amended 2022).
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Hampton, J.O. and Davis, N.E., 2020. Impacts of introduced deer in Victoria. Victorian Naturalist, The, 137(6), pp.276-281.
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Higgins PJ & Peter JM (Eds) (2002) Handbook of Australian, New Zealand and Antarctic Birds. Volume 6: Pardalotes to Shrike‐thrushes. Oxford University Press, Melbourne.
Hohnen R, Tuft K, McGregor HW, Legge S, Radford IJ, Johnson CN. Occupancy of the Invasive Feral Cat Varies with Habitat Complexity. PLoS One. 2016 Sep 21;11(9):e0152520. doi: 10.1371/journal.pone.0152520.
Legge, S., Woinarski, J.C.Z., Garnett, S.T., Geyle, H., Lintermans, M., Nimmo, D.G., Rumpff, L., Scheele, B.C., Southwell, D.G., Ward, M. and Whiterod, N.S., 2021. Estimates of the impacts of the 2019-20 fires on populations of native animal species: NESP Threatened Species Recovery Hub. Project 8.3. 2 report.
Lindenmayer D, Mackey B, Gould S, Norman P & Taylor C (2021) How does climate affect bushfire risks in the native forests of south-eastern Australia? Bushfire Recovery Project Report No.1. Griffith University and The Australian National University
Menkhorst P, Rogers D, Clarke R, Davies J, Marsack P & Franklin K (2017) The Australian Bird Guide. CSIRO Publishing, Clayton, South Victoria.
Stobo‐Wilson, A.M., Stokeld, D., Einoder, L.D., Davies, H.F., Fisher, A., Hill, B.M., Mahney, T., Murphy, B.P., Stevens, A., Woinarski, J.C. and Rangers, B., 2020. Habitat structural complexity explains patterns of feral cat and dingo occurrence in monsoonal Australia. Diversity and Distributions, 26(7), pp.832-842.
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