the proposal to log temperate rainforests in Tasmania for ancient rainforest trees Reject carte-blanche rainforest logging plan: Submission to the Tasmanian Special Species Management Plan

Executive Summary and Recommendations:


  1. Logging existing reserves is controversial in the extreme, unacceptable in conservation terms, and fraught with danger to Tasmania’s reputation, market access, and also risks undermining consumer confidence.
  1. Logging should be explicitly prohibited in the Tasmanian Reserve Estate. Our irreplaceable Reserve Estate must be protected and conserved for the Tasmanian people and for our future generations. 
  1. All state conservation areas and natural reserves should be given the highest level of legal environmental protection, including National Park status for the Tasmanian Reserve Estate.  All National Parks and Reserve Estate must be adequately resourced to provide for world’s best practice management for their natural and Aboriginal cultural values.
  1. A formal government policy of no logging of rainforests should be adopted.
  1. The incompatibility between the just signed Recovery Plan for the Giant Freshwater Lobster (Astacopsis gouldi), and the draft Special Species Timber Logging Plan, must be acknowledged and resolved by the immediate removal of all Giant Freshwater Lobster habitat from planned logging coupes.
  1. Subsidies for the logging industry, including specialty species timber operators, must cease, including in-kind support such as the provision of access roads.
  1. Re-prioritise and re-focus on developing the Hydrowood program, and establish a formal state Wood Bank, where provenance of salvaged wood is certified, and management and sales are undertaken transparently. 


Markets For Change welcomes the opportunity to comment upon the draft Special Species Management Plan 2017 released by the State Resources Minister for public comment.

We note the advice provided on the Department of State Growth requesting contributors use the template provided for ease of collation of responses by departmental officers.  While we have not used that exact form, this submission is structured along similar lines to the departmental template and uses the same headings, supplemented with some additional headings of our own.

In the interests of a genuine and meaningful public consultation process, we request that any subsequent departmental collation process does incorporate this submission in full.  Markets For Change does not object to this submission being made publicly available on the Department’s website.



Overview of the draft Special Species Management Plan

The draft Special Species Management Plan (hereafter referred to as ‘the draft Plan’) represents the latest ideological assault upon Tasmania’s unique native forests, and one which predominantly, and inexcusably, targets our old growth and rainforests currently within conservation reserves.

 he draft Plan targets for logging historically protected forests which have been in reserves for decades, some since the 1980s. Some of these slow-growing rainforest trees are over 300 years old. The plan is silent on the values which these reserves were created to protect and the impacts on such values

The government claims this intrusive logging regime is necessary to support the state’s specialty species timber industry, due to some lobbyists complaining of supply shortage.  However, not all within the specialty species timber industry agree with incursion into reserves or unprotected HCV forests. Those based upon, or moving towards, plantation sourced timber have been explicit regarding their disagreement with the approach.  This again exposes the draft rainforest logging plan as an ideologically driven pandering to certain vested interests.




Forest Areas to be Targeted:

It is with grave concern that we note that under the draft Plan over 350, 000 hectares of high conservation value forests previously designated for future protection under the Tasmanian Forest Agreement will be targeted for logging. This is in addition to the proposed logging of existing formal protected areas.

The iconic takayna/Tarkine in the state’s north-west will bear the brunt of this proposed logging onslaught, with 28 reserves in this region consisting of 295, 700 hectares, threatened by this rainforest logging plan.

Other targeted listed reserves occur in the Blue Tier and Northeast highlands, as well as informal reserves including wildlife habitat strips, streamside reserves and World Heritage Area buffer zones.  All of these areas are highly significant for their conservation values and contribution to the ecological integrity of the immediate and adjacent reserve areas.  Threats to log these areas are also highly controversial given the local community’s attachment to, and desire for the ongoing protection of, these areas.




* Species to which the Plan applies:


The ‘Special Species’ referred to in the Plan, are those defined in the Forestry (RFI) Act 2014:

  • Blackwood - (Acacia melanoxylon)
  • Myrtle – (Nothofacus cunninghamii)
  • Celery Top Pine - (Phyllocladus aspleniifolius)
  • Sassafras - (Atherosperma moschatum)
  • Huon Pine – (Lagarostrobos franklinii)
  • Silver Wattle – (Acacia dealbata)


Most Tasmanians will recognize these as slow-growing rainforest species, with many having links back to our ancient Gondwana forests. (We recognize that silver wattle is not usually defined as a rainforest species). Our temperate rainforests have a much more restricted global distribution than tropical rainforests, and hence their rarity increases our responsibility to ensure they are protected. 

The rainforest species to which the draft Plan applies are renowned for being very slow growing with even small trees being hundreds of years old.  Therefore rehabilitation to the pre-logging condition will be extremely difficult, if not impossible.

A key area of pressure upon global temperate rainforests is logging, and it is extremely disappointing to see Tasmania renege on its national and international responsibilities by proposing this ‘carte-blanche’ rainforest logging plan.

Markets For Change rejects the logging of rainforests.  Old growth and high conservation value forests should not be logged but placed within formal protected and properly resourced reserves such as National Park. 



 * Land to which the Plan applies:


The draft Plan provides the following breakdown of the targeted 420, 000 hectares of forested land (the draft Plan, pg 32):

  • 98, 000 hectares occurring within PTPZ land (within Informal reserves or Outside Provisional Couped-up Areas)
  • 99, 000 hectares within FPPF land
  • 170, 000 hectares within regional Reserves
  • 55 000 hectares within Conservation Areas


Lets be clear, the draft Plan applies to publicly owned rainforests.  It specifically targets Conservation Areas, Regional Reserves, Future Potential Production Forests (FPPF) and Informal Reserves on Permanent Timber Production Zone (PTPZ) land, all of which comprise part of the Tasmanian Reserve Estate, and as such are recognised as part of the Comprehensive, Adequate and Representative (CAR) reserve network.

Some of these Reserves and Conservation Areas have been protected for decades for their conservation values.  These values have only become more pressing and significant over time due to ongoing habitat loss and degradation, climate change, pressure from introduced species, and other factors.

The targeted land is also home to a long list of threatened and iconic wildlife, including the wedge-tailed eagle, masked owl, spotted tail quoll, eastern quoll, swift parrot, grey goshawk, white-bellied sea eagle, and Tasmanian Devil, and notably the vulnerable Giant Freshwater Lobster (Astacopsis gouldi).

 The incompatibility between the draft Plan and the recently joint-government signed Recovery Plan for the Giant Freshwater Lobster cannot be avoided.  The Recovery plan specifically cites habitat loss and disturbance, including forestry operations, as a key contributor to the current vulnerable status, and a potential ongoing threat to the species.  The Recovery Plan identifies catchments which are likely habitat for the vulnerable Giant Freshwater Lobster, including a total of 12 reserves (10 Regional Reserves and two Conservation Areas), which could also be targeted by the draft logging Plan (the Recovery Plan, pgs 15-16).

All potential and rostered logging coupes which fall within the Recovery Plan’s identified Giant Freshwater Lobster catchment areas must be removed immediately from logging plans.

The draft Plan cites DPIPWE (2017) findings that the key risks to threatened fauna from specialty species rainforest logging was likely to be concentrated on those who require nesting habitat, or den habitat.  Despite stating that “disturbances to these fauna may be visual, aural or physical, such as the removal of nesting or denning resources,” (pg 27), the draft Plan then relies on ‘prescriptions’ established under the Forest Practices system, to mitigate any negative impact upon these endangered and vulnerable species.  Reliance on a weak Forest Practices system which has been proven over the years to fail badly at protecting wildlife, water quality and other conservation values, which operates on a coupe by coupe basis without the capacity to impose an wholistic approach, and which is also exempt from the federal Environment Protection and Biodiversity Conservation Act is negligent.

This dismissive and cavalier attitude by the responsible government of the day is unacceptable.  It will badly undermine Tasmania’s reputation and consumer confidence in any timber product derived from these areas.

The outsourcing of responsibility for the survival of threatened, and in some cases endemic species, to private logging operators with a minimalist Forest Practices Plan must be rejected.



* Management of values:

The draft Plan is woefully inadequate in recognizing the significance of conservation values, or in offering any genuine or meaningful protection for those values.

The CAR reserve network is a unique repository of significant conservation values, many of which are incompatible with the proposed logging regime of the draft Plan.

The draft Plan refers to a ‘Conservation Assessment of the FPPF land.  Upon analysis this so-called Conservation Assessment is worryingly, and one surmises deliberately, silent on previous studies which identified the high degree of National Heritage significance and values present across much of the FPPF land.  Additional to the National Heritage values already identified and placed upon the public record is the World Heritage significance of takayna/Tarkine, particularly its contiguous nature of rainforest cover.  This invaluable ‘contiguous nature of rainforest cover’ is targeted for logging under the draft Plan.

The Tasmanian Government’s previous watering down of the management requirements for existing Conservation Areas and Regional Reserves makes a mockery of any attempt outlined by the draft Plan to manage conservation values, water quality values or threatened species impact.

Any so-called Management Plan that is in such blatant denial of the existence of the old-growth, high conservation value forests, their integrity, biodiversity, habitat and other natural values, including water quality, is clearly going to fail in its purported management of these values.  You cannot manage that which you refuse to acknowledge exists.

It must be recognized that many of these current reserves areas are the last resort ‘Ark’ for these threatened, endangered and vulnerable species.  A hole cannot be punched into their Ark, and it be expected that such destruction won’t impact upon their survival.




* Established Supply:

Efforts to publicly justify this out-of-touch logging of rainforests is an apparent supply shortage of the desired special species, or rainforest, trees.  However, the draft Plan does not identify any quantified volume amount deemed necessary by the industry.  The ‘established supply’ across the Reserves, listed Conservation Areas and other land tenures, is just presented in a rather crude mathematical manner, with the inference that it is all ‘needed’ to keep the industry afloat, when in fact no justification for one stick is made by the draft Plan.

Significantly, the draft Plan is silent on the role of previous and current logging practices on the supply levels, and structural changes within the industry, and sensitivity of consumer-driven markets.

It is nonsensical to complain about current supply shortage without discussing the impact of ‘historic’ logging and supply regimes.  Primarily, trees of the identified specialty species were collateral damage of the eucalypt clearfell logging regime.  For decades, and despite public outcry, it was a widely known fact that tons of the now sought after myrtle, sassafras, blackwood, and silver wattle were windrowed up, post-clearfell and eucalypt extraction, and burned.  These ‘special species’ were considered ‘waste’, and they were treated wastefully.

The draft Plan then rubs salt into the wound by seeking to reduce its ‘established supply’ to a ‘maximum annual harvest quantity’, which is a simplistic attempt to translate rainforest species within listed reserves and conservation areas into just a log volume (the draft Plan, pg 35). While busily calculating the amount and location of specialty timber species across the PTPZ land, FPPF land and within Reserves and Conservation Areas, the draft Plan does not identify clearly what is the annual ‘need’. Basically the push appears to be to calculate the amount of trees found where, which log category that can be further divided into, and then further attempt to allocate annual maximum logging volumes.

Further there is a considerable disconnect in identifying that some species require a rotation period from 80 years, Silver wattle, to 300 years, such as Myrtle and Celery top pine, when the draft Plan only ‘provides’ for estimated sawlog volumes on PTPZ land up to 2026-27, and then vaguely from ‘2027-28 onwards’ (draft Plan, pg 31.)

Unless the purported management plan can detail how our current estate of myrtle and celery top pine will still exist across the targeted land tenures in 300 years time, as the draft plan identifies as those species’ rotation rates, then it is nonsensical (the draft Plan, pg 30).  As it is, the draft plan estimates that in 2027-28 there will be 0 cubic metres available of silver wattle from PTPZ land (the draft Plan, pg 31), but we shouldn’t worry as this species is widely distributed elsewhere.   That ‘elsewhere’ includes the Reserves and Conservation Areas.  It is not ‘management’ when a species is exhausted from one category of land, requiring reserves to be plundered.  In fact, that is exploitative and irresponsible ‘business-as-usual’ to trash an irreplaceable natural asset.

Hypothetically, if there was a Dodo Reserve, home of the last members of that species, any moves to justify opening the reserve to hunters on the basis that is where the last ones are, would receive international condemnation.

It needs to be recognized that moves to log our rainforest remnants within the public reserve estate, because that is where those remnants remain, reflects the same absurd attitude as opening up a threatened species reserve to hunters.  




Develop Alternative Supply:

A responsible government would redirect effort into salvaging current timber, such as the Hydrowood project, and establish a formal state Wood bank. Specialty timbers logged at volume as ‘collateral damage’ to industrial logging for eucalypt could be stored until required, overcoming the scandalous waste practiced for may decades.

It is widely recognized that scattered throughout many backsheds and workshops are significant amounts of specialty species timbers in a variety of forms, from burls, to salvaged logs and split beams.  Anecdotal records indicate that much of these resources were collected, or traded, by previous generations, with current generations unknowingly inheriting whatever grandad left in the back shed.  Some current owners do not know what to do with such resource, and so it is left there.  This presents a wealth of untapped salvageable resource.

It requires a systematic promotion and state purchase collection scheme to develop a special species Wood Bank.  Just as Hydrowood reclaims and salvages timbers from our waterways, a dedicated Wood Bank could do the same but salvaging from back sheds and work places.  The Wood Bank, as a minimum, would require provenance of salvaged wood, in that it has not just recently been cut from public lands, with sales and purchases monitored and managed in an equitable and transparent manner.



* Harvest Techniques:

Any attempt to paint the proposed logging methods as ‘sensitive’ logging is a deliberately deceptive sham. 

The draft Plan is to be condemned for its attempt to mislead the public over the degree of intrusion and damage the logging of rainforests will wreck. The proposed so-called ‘partial harvest’ logging methods will effectively result in a clearfelled coupe, following three separate logging incursions of 30 per cent clearance each time. 

The ‘partial harvest’ could see at least 90 per cent of the rainforest coupe logged, with the remaining scattered 10 per cent of rainforest having its ecological integrity irreparably damaged, and adversely affecting the viability of threatened and endangered species.

Contrary to the draft Plan’s assertion that the ‘partial harvest’ technique is ‘commonly used’, that is just not the case (the draft Plan, pg 38). No matter the fancy or misleading terminology of silviculture practices the logging of slow-growing trees over 300 years old, and which have been identified as requiring a rotation period of between 80 years to 300 years can never be ‘sustainable’.

The draft Plan is notably silent on any rehabilitation of the proposed logged areas.  In the terms of any serious draft Management Plan that omission would result in an automatic fail.  As stated earlier in this submission, the great age and extremely slow growth rates of the target rainforest species means rehabilitation to pre-logging conditions will be extremely slow if not impossible.  Inevitably there will be irreversible damage caused to the rainforest, with roading machinery access tracks, loading areas and other logging associated disturbances, beyond the extraction of timber.  This will have immense negative impact to the broader ecological processes of the ecosystem.



* Land owner approvals:

One of the most alarming aspects of the draft Plan is that rainforest logging can commence without any assessment being triggered of the impact of logging upon the specific reserve values or the effect on existing reserve management plans and reserve values.

The absence of any attempt to assess the potential impact of logging upon the targeted rainforest integrity within the context of why these areas were placed in reserve in the first place, is an appalling backwards step.  The draft Plan should be abandoned due to its targeting of rainforest reserves no matter what, however this added failure to follow due and proper management practice, is a further example of how fundamentally flawed, irresponsible and retrogressive it is.




Impact Upon Tasmania’s Brand and Markets:

This draft Plan appears designed to specifically ramp up further controversy within local, national and international markets. 

Similarly, the draft Plan appears designed to deliberately undermine the efforts of many Tasmanians, across a range of sectors, in building a genuine and appealing Brand based on respecting and protecting our natural assets.

The logging of rainforests is abhorred by many across the globe, especially by the communities specifically targeted by the tourism industry, such as the eco-tourism, sector.

As noted above, the so called proposed ‘sensitive logging’ is a delayed installment clearfell sham.  Once this is begun to be known throughout the community, tourism sector, consumers and the markets, any attempt to deny this fact will be recognized as false PR ‘greenwash’.  Not only will this undermine our tourism sector, it will also be a further death-knell for the markets which cannot afford to be associated with fake greenwash.

Locals, individual consumers, national and international buyers will search for, and demand, a genuine and independently certified source of non-rainforest logged specialty species timber for their furniture and furnishings (ie platters, bowls, spice grinders).  If Tasmania refuses to provide that non-rainforest logged certified supply, then Tasmania only has itself to blame when buyers and markets go elsewhere.

Logging existing reserves is controversial in the extreme, unacceptable in conservation terms, and fraught with danger to Tasmania’s reputation and markets. Just as the end result of the draft Plan will be trashed three-step clearfelled rainforests, it will also result in a trashed Tasmanian reputation and Brand.



Who Pays?:

It is worth noting that apparently it will be the private sector logging our rainforests, not Sustainable Timbers Tasmania (formerly Forestry Tasmania).  This is in itself a telling admission that any hope of STT obtaining Forest Stewardship Council certification (FSC) would be dashed if they were to log rainforests from listed Conservation Areas and Regional Reserves (many of which ere created to protect the forest values).

The draft Plan is silent regarding how these forest areas will be accessed by loggers and logging machinery.  The remoteness of many of these forests, the difficult terrain and the inclement weather, particularly in the north-west, will make road building and maintenance a slow and costly business.  Similarly extracting, loading and trucking the timber out will be subject to weather and road conditions.  And technically, any rehabilitation costs would also be incurred.  These factors, plus any potential predicted drop of demand in the markets due to informed consumer preference, make it extremely unlikely that any venture will be cost affordable.

Some in the private-sourced specialty timber sector have voiced their disquiet over the entrenching of a warped and uneven playing field between those who have invested in developing plantations, and those who are provided incentives to keep relying upon cheap access to public resources.  It is worth noting the private sector’s serious concerns that a damaged ‘rainforest loggers’ reputation will tar them with the same brush with some consumers, threatening their business viability.

There must be an end to all public subsidies to the logging industry, including ‘in kind’ support such as the building of logging roads, or subsidized state purchase of logged rainforest timbers.




Tasmania cannot be both the ‘clean, green’ state and the ‘rainforest and old-growth logging’ state.

Logging should be explicitly prohibited in the Tasmanian Reserve Estate.  All state conservation areas should be given the highest level of legal environmental protection, including National Park status, and be appropriately resourced to provide for world best practice management.  Our irreplaceable natural estate must be protected and conserved for the Tasmanian people and for our future generations. 

Given the recognized slow-growth rate of the identified desirable tree species, it is beyond comprehension that some within the specialty species timber industry have been so negligent that it has not developed or implemented a long-term long-rotation private plantation base, and that current advocates of this proposed logging were not vocal and agitating when forest management deemed retrieval of these species cut during broadscale logging to be unimportant. Some, such as blackwood timberworkers, have planned and invested in their plantation resource, yet this draft Plan also risks undermining such private enterprise by further warping any level playing field between the private and public sectors.

Decades of mismanagement of our unique and vital native forest estate, largely resulting in the current identified ‘lack of resource’ must not be rewarded by carte blanche access to the remaining forest.

In summary, it is irresponsible for the government to attempt to justify the liquidation of our irreplaceable natural assets for the benefit of a few.

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