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The Wilderness Society Victoria Inc submission
on the assessment of the Gymnobelideus
leadbeateri (Leadbeater’s Possum) to list as
critically endangered under the Environment
Protection and Biodiversity Conservation Act
1999 (EPBC Act)
23rd January, 2014
For further information relating to this submission please contact:
Ben Campbell
Victorian Community Campaigner
The Wilderness Society Victoria
[email protected]
Introduction
The Wilderness Society Victoria is a nature conservation organisation working to protect
Victoria’s native forests from logging and woodchipping and to ensure the ongoing survival of
native flora and fauna in these regions.
As such, this submission speaks to the importance of taking significant steps to ensure the
protection of the Leadbeater’s Possum - the State’s faunal emblem.
Twelve species of native mammal have become extinct within Victoria in the last two centuries,
and sixteen mammal species are now considered at or near risk of extinction - as EPBC listed
and assessed in DSE 2013). A number of additional mammals are currently recognised as
threatened under the Victorian FFG Act (DSE 2013).
Populations of other threatened species have plummeted in recent years; the Baw Baw frog,
the Powerful Owl, the Sooty Owl, and the Barred Galaxias are all forest dependant and are all
negatively impacted by logging operations. This gives an indication of the poor health of these
forest ecosystems due to inadequate protection measures.
This submission calls for the uplisting of the Leadbeater’s Possum to critically endangered. It
gives an indication of the state of the Leadbeater’s Possum by looking at existing data and
highlighting the threats to this species. It also looks at how current management practices are
falling short of protecting this species and suggests action plans to ensure its ongoing survival.
Population numbers
We support the numbers presented in the nomination regarding population size and current
number of breeding individuals.
A recent study (Lumsden et al., 2013) by the Arthur Rylah Institute has indicates vastly higher
number of Leadbeater’s Possum compared to other studies. The figures were not published in
this paper but have since been cited in VicForests’ Sustainability Report1 (3,750 - 11,250
animals). We strongly question these figures, given the lack of transparency on how they were
arrived at, when not reported in the original study but somehow arrived determined in the
business report of a State agency charged with managing logging operations. The original study
data appears problematic, and not definitive. It seems a number was sought prematurely with
this limited data and there was not sufficient scientific rigor behind this result.
A lot seems to have been assumed to arrive at these figures. They surveyed 180 sites and
sighted the species at 29. It is evident the figure was derived from extrapolations based on a
number of assumptions, including that the species occurs across the landscape in suitable
1
http://www.vicforests.com.au/files/aamitulnsj/VicForests-Sustainability-Report-2013.pdf
habitat. Deriving a population of 3,750 - 11,250 from 29 sightings needs to be strongly
questioned.
Extent of occurrence and area of occupancy
We support the numbers presented in the nomination regarding the extent of occurrence,
extent of decline and area of occupancy.
6. Are you able to provide data about available habitat area and declines in Tables 1 and 2 at
pages 6–7? Can you provide supporting data/justification or other information?
We support the data that is published in Professor David Lindenmayer’s studies relating to this
table. We do not have any other data to add.
General
7. Do you agree that the species is eligible for inclusion in the critically endangered category
of the threatened species list?
We agree that the species is eligible for inclusion in the critically endangered category and
suggest this uplisting would be a necessary and crucial step to take to accurately reflect the
status of the species and ensure the ongoing survival of the species. All of the large-scale and
long-term datasets on the Leadbeater’s Possum undertaken by Professor David Lindenmayer
throughout his 30 years of studying the species, regarding its habitat requirements and the
effects of fire and logging on this critically endangered species clearly indicate that it is headed
for rapid extinction unless significant steps are taken urgently.
Image: Ian Moodie
The criteria for placement on the critically endangered list is addressed throughout this
submission and pertinent studies and data are referenced accordingly. It is evident that:
The species has undergone a very severe reduction in numbers and there is a risk of this decline
continuing with regards to some of the threats mentioned in this document
It has a very restricted habitat area and its geographic distribution is precarious
We strongly support the evidence in the nomination of rapid population declines under current
management regimes - both in terms of the population modelling, and the population crash
following the 2009 bushfires. It is clear that previous and current threats have caused the
population numbers of the Leadbeater's Possum to plummet. With potential threats considered
it is likely that the population will continue to rapidly decline, which in turn would likely lead to
the extinction of the species.
The probability of extinction in the wild over 3 generations is at the critical level when
considering the factors highlighted in the threats and legal sections of this submission
8. Is the information used to identify the nationally threatened status of the species
accurate?
We believe the information used to identify the nationally threatened status of the species is
accurate.
9. Can you provide additional data or information relevant to an assessment against the
listing criteria?
We support the data that has been given in the nomination and we have given additional
information relevant to an assessment against the listing criteria through this submission.
10. Have you been involved in developing this nomination?
We have not been involved in developing this nomination.
Questions about threats
11. Do you agree that the threats identified in the nomination are correct and that their
impact on the species is as described?
We support the threats identified in the nomination. We believe they are correct and their
impact on the species is as described.
12. To what degree are the identified threats likely to impact on the species in the future?
Logging and loss of hollow-bearing trees
Logging is a major form of disturbance to Leadbeater’s Possum habitat and is a major
contributing factor in the rapid demise of the species. The Mountain Ash areas of Victoria (a
large proportion of habitat for the species) is logged by clearfelling. Clearfelling is an incredibly
destructive process and clearfelled areas do not support viable populations of large old trees as
they are typically destroyed in logging operations or, if retained, they die or collapse soon after
logging. Large areas of forest can be rendered unsuitable for Leadbeater’s Possums when a
dramatic change in landscape occurs through a series of closely juxtaposed logged areas.
Studies have repeatedly shown that the probability of occurrence of the species at a site is
significantly correlated with the abundance of hollow-bearing trees on a site (Lindenmayer
et al,. 2013a). The more hollow-bearing trees that occur on a site, the higher the probability
that Leadbeater’s Possum will occur on that site. Figure 1 (Lindenmayer et al., 2013b)
demonstrates this.
Figure 1: Relationships between the abundance of (living and dead) hollow-bearing trees
per 3 ha and the probability of occurrence of Leadbeater’s Possum
Source: http://fennerschoolassociated.anu.edu.au/documents/New_Manag_Pres_%20VS2_%202_July_2013.pdf
A key part of the habitat of Leadbeater’s Possum is access to large old trees. They are typically
190 years old (and often much older). Recent articles in Science and PLOS One have shown
there is a rapid and catastrophic decline in populations of large old trees throughout Mountain
Ash forests (Lindenmayer, Laurance & Franklin, 2012 and Lindenmayer et al., 2012). This is
occurring because of past repeated logging, fire and post-fire salvage logging. This also occurs
as logged and regenerated forests are more fire prone for about seventy or more years after
harvesting. These drivers are creating a severe shortage of suitable nesting and denning sites
for use by arboreal marsupials - including the Leadbeater’s Possum (Lindenmayer, 2012).
At unburnt sites, high-rates (approximately four times higher than in previous decades) of live
tree death and collapse of dead hollow bearing trees was also reported between 1997 and
2011. In this time period a large amount of large, living and hollow bearing trees died
(Lumsden, et al. 2013). This decline was unexpected, and the length of this rate of decline is
unknown (Lumsden, et al. 2013). This loss, compounded by the lack of replacement hollow
bearing trees currently in the Leadbeater’s Possum’s habitat, will likely lead to a critical
shortage of vital hollow bearing trees for several decades to come (Lumsden, et al. 2013).
Modelling projections based around the current, and other, rates of tree loss line up with
predictions that by 2039 on long-term monitored Leadbeater’s Possum survey sites most of the
hollow-bearing trees will have collapsed (Lumsden, et al. 2013). This rate of loss will continue
for several decades and the carrying capacity of these forests as habitat will correspondingly
decline due to their lack of nesting sites (Lumsden, et al. 2013).
Image: Karena Goldfinch
From the time of european settlement, old growth stands (which support the highest
abundance of hollow-bearing trees) are a tiny fraction of what they were (1/30th to 1/60th).
This is the result of a century of logging (including the deliberate past conversion of old growth
forest into regrowth stands), 40 years of intensive and extensive clearfelling, and repeated
wildfires (Lindenmayer et al., 1991, 2013a).
Fire
After the 2009 ‘Black Saturday’ bushfires, approximately 42% of Leadbeater’s Possum habitat
was lost. Surveys conducted at long-term sites have indicated that the species cannot live on or
amongst burned sites. Large areas of this unburned intact forest are critically important for the
survival and protection of the Leadbeater’s possum (Lyndenmayer, 2012). Recent data has
shown that the population of the species has been reduced heavily on unburned sites where
the surrounding forests and landscape have been burned (Lindenmayer et al. 2013).
The recent logging in the forests of the Central Highlands has changed the ecological landscape
of the species habitat, making the forests more prone to fire and therefore more likely to
further diminish the dwindling population of the Leadbeater’s Possum (Lyndenmayer et al.,
2009). Areas which are logged lose significant moisture and when ‘regenerated’ can turn from
wet sclerophyll forest to dry sclerophyll forest. When this transformation has occurred, the
forests are more likely to burn at high severity and the fires will therefore be more likely to
damage the species habitat. These severe changes to the landscape can have devastating
effects on both the Leadbeater’s Possum and on the large, ancient trees in which they live
(Lyndenmayer, 2012).
Professor David Lindenmayer found that the fire-mediated landscape context effects identified
for Leadbeater’s Possum were very similar to those resulting after logging. When areas of the
forest have been logged, the abundance of the species was significantly depressed in “narrow
strips of retained forest surrounded by recently clearfelled areas”(Lindenmayer et al., 1993).
It has been found that some arboreal marsupials, including the Leadbeater’s Possum, are highly
sensitive to changes in the landscape-level forest cover resulting from the clear felling of trees
(Lindenmayer et al., 1993, 1999). Given these past findings, Professor Lindenmayer has
predicted that “unburned sites surrounded by extensive areas of burned forest would be less
likely to support animals than sites where the surrounding forest remained
unburned.”(Lindenmayer et al., 1993, 1999). Therefore, even if species can survive in unburned
refuges, they may still be sensitive to wildfire in the surrounding landscape (Lindenmayer et al.,
1993, 1999).
Consistent statistical modelling has shown that all species are significantly more likely to occur
in landscapes where there is abundant vegetation and trees. Species such as the Leadbeater’s
Possum do not live where there is an absence of the hollow-bearing trees (see fig 1), whether
they be destroyed by logging or wildfire (Lindenmayer et al., 1991b, 1994). Where there is a
vast number of hollow bearing trees, the Leadbeater’s Possum was more likely to occur,
particularly at high elevation and on sites which have been regenerated after the devastating
fires in 1939 (Lindenmayer et al., 1991b, 1994) .
Lindermayer also predicted that high severity fire will have a direct impact on animal mortality,
and an indirect impact on habitat suitability, in particular the increased levels of destruction of
severe fire of large old trees (Banks et al., 2011b; Lindenmayer et al., 2012) which arboreal
marsupials use as nest and den sites (Lindenmayer et al., 1991a).
This is a globally endangered species and Victorian Government agencies have estimated 42%
of its habitat was burned in 2009. Other data has shown that the abundance of the species was
also reduced on unburned sites where the surrounding landscape had been burned
(Lindenmayer et al., 1993, 1999). Additionally, the building of roads for practices such as
logging can also increase the risk of bushfires (Lindenmayer, Blanchard, et al. 2012) and climate
change is increasing the chance of a major bushfire (see ‘potential threats’ section for climate
change threat). These findings, combined with previous research (Lindenmayer et al., 1993)
showing similarly negative effects of logging on Leadbeater’s Possum in these forests, highlight
the critical value of large, intact, long-unburned old-growth areas (supporting trees 150 to 400
years of age) for the conservation of the species.
Decline in habitat condition
The threats mentioned in this document; logging, loss of hollow bearing trees, fire, climate
change, and landscape traps all collectively contribute significantly to a current decline in the
species’ habitat condition. This needs to be treated as real and urgent.
Population fragmentation
A major study suggests that the fragmentation of the Leadbeater’s Possum habitat could have
an adverse effect on its survival rate (D. Lindenmayer, et al. 2013). The study references the
susceptibility of some species of arboreal marsupials to the change in forest cover, stemming
from the clearcutting of adjacent sites. The fragmented landscape that results from logging in
close proximity to other coupes cannot sustain the Leadbeater’s Possum (Lindenmayer, 2012).
It is suggested that the Leadbeater’s Possum is susceptible to damage, particularly fire damage,
in its surrounding habitat (D. Lindenmayer, et al. 2013). Unburned habitat areas bordering
burnt sites displayed depressed population figures (Lindenmayer, Blair, et al. 2013). Some small
refuges of Leadbeater’s Possum populations have been found after the 2009 fires in gullies,
though the future of these populations in absence of adequate habitat trees is questionable
(Lumsden, et al. 2013).
Due to recent habitat fragmentation it is suggested (Hansen 2008, Hansen et al. 2009) that this
has resulted in genetic differences in the species. There is no subspecies but rather two
separate ‘Evolutionary Significant Units’ (ESUs). For a population to be fragmented to the point
that genetic variations form shows the extent of the disturbance to this species and its habitat.
Population fragmentation results from habitat fragmentation and the two main drivers of
habitat fragmentation are logging and fire. Due to the ongoing logging practices and increasing
risk of fire due to climate change there is a significant risk of further population fragmentation.
13. What threats are impacting on different populations, how variable are the threats and
what is the relative importance of the different populations?
We are supportive of evidence provided in the nomination relevant to different populations.
We would also suggest that, given the scale of logging operations occurring in montane ash
forest, the direct impact of logging could be expected to be dramatically higher in this forest
type than in sub-alpine woodland or lowland swamp populations. However, the increased fire
risk resulting from logging operations in montane ash forests could be expected to present a
more generalised threat across both Mountain Ash and sub-alpine woodland particularly, and
possibly lowland swamp populations given the threat of bushfire impact may be at a landscape
scale.
14. Can you identify other threats, past, current or potential that may adversely affect this
species at any stage of its life cycle?
Climate change
The Mountain Ash forests of Victoria play an important role in keeping the climate in balance.
About 15-20% of net Carbon Dioxide (C02) emissions globally have originated from land
ecosystems, primarily from deforestation and degradation (Climate Commission, 2011) during
logging and post-logging burning. Victoria’s native forests are some of the most carbon dense in
the world (Mackey et al., 2008). If clearfell logging were to cease in south-eastern Australian
forests, the carbon sequestration potential of the logged forest area would be 2 Gt C
(equivalent to 7.5 Gt CO2) (Mackey et al., 2008).
Image: Peter Halasz
Recent research published in the journal ‘Nature’ shows that in 97% of tropical and temperate
tree species, growth rate increases with size. This suggests that older trees play a vital role in
absorbing carbon dioxide from the atmosphere. Prior to the study, the common assumption
was that as trees aged, their growth rate and carbon absorption decreased. This belief came
from two different lines of evidence; first, it has been shown that at the whole forest level,
young forest acquires mass faster than old-growth forest. Second, studies have shown that the
leaves of older trees are less efficient at photosynthesising than the leaves of younger trees
(Tellefson, 2014).
Major climate-change related effects in Mountain Ash forest include likely increases in fire
frequency and extreme fire weather (Clarke et al., 2012), which will have major impacts on the
structure and composition of Mountain Ash forests (Mackey et al., 2002). In addition, changes
in climatic conditions are likely to reduce the environmental niche and in turn reduce the area
of suitable habitat for Leadbeater’s Possum (Lindenmayer et al., 1991) . There is an increasing
fire frequency expected consistent with climate modeling and landscape traps (see landscape
trap section below) being established on the forests landscapes (Lindenmayer et al., 2011).
There is strong scientific evidence showing the dramatic impact which climate change is already
having on the regenerative capacities of native flora, particularly eucalypt forests, and the
implications for biodiversity and ecological processes.
A study by the National Environmental Research Program's Environmental Decisions Hub has
found that climate stress on eucalypts will mean many of Australia's Eucalypts species (of which
there are over 700) will struggle to cope with climate change (Butt, 2013).
Trees are among the first groups to be affected globally by climate change, as they are
particularly vulnerable due to long generation times and short dispersal distances (Butt, 2013).
This suggests a dangerous cycle of stressing the forest ecosystem; climate change gets made
worse by the logging and burning regime and in turn the Eucalypt species fall under more stress
due to climate change. The study found that under the mid-range climate scenario, these
species will lose 20% of their climate space, and twice that under the extreme scenario.
Dr Butt suggests there is additional concern for the impact these conditions will have on wildlife
in such areas. 'Trees are habitats and food sources. So this will have a cascade effect on birds,
bats and invertebrates that are reliant on eucalypt, and it will affect pollinators as well. As the
Leadbeater’s Possum is so dependent on these trees this could have a significant knock on
effect to their populations.
Landscape Trap
The landscape trap has significant implications for the Leadbeater’s possum and should be seen
as a significant threat. Figure 2 shows how a landscape trap forms and what factors influence it
(Lindenmayer et al., 2011).
The ‘landscape trap’ happens when entire landscapes are shifted into, and then remain
trapped in a highly compromised structural and functional state as the result of multiple
temporal and spatial feedbacks between human and natural disturbance regimes (Lindenmayer
et al. 2011, p.1).
Fig 2 - Conceptual model of a landscape trap. The trap results from the reinforcing feedback
loop shown in red.
Source: http://www.pnas.org/content/108/38/15887.full
The mountain ash (Eucalyptus regnans) forests in the central highlands of Victoria; the only
location that Leadbeater’s Possums live in the wild, are likely to have a shift from that of a
landscape dominated by mature hollow bearing trees to a landscape dominated by young fireprone forests that do not survive to become old enough to develop hollows, in turn
dramatically reducing potential for Leadbeater’s Possum habitat. Evidence comes from new
spatial information following massive wildfires in 2009, perhaps the most economically
destructive in Australian history (2009 Victorian Bushfires Royal Commission (2010) Final Report
(Parliament of Victoria,Melbourne), coupled with understanding that has emerged from 28
years of extensive field information and associated data analyses in mountain ash forests
(Lindenmayer, 2009). Below is a diagram showing the system and factors involved with the
landscape trap in the Mountain Ash forests of the Central Highlands of Victoria (Lindenmayer
et al., 2011).
Fig 3. Development of a landscape trap in the Mountain Ash forests of the Central Highlands of
Victoria.
Source: http://www.pnas.org/content/108/38/15887.full
It is clear this threat of a landscape trap forming in Leadbeater’s Possum habitat is real and
should be taken into account when trying to gauge the risk to the species in the future.
Suggestions for managing this are given in the section about management.
15. Can you provide supporting data/justification or other information for your responses to
the questions about threats?
We have provided this throughout the previous section about threats.
Questions about management
16. What planning, management and recovery actions are currently in place supporting
protection and recovery of the species? To what extent have they been affective?
Current strategies to conserve the Leadbeater’s Possum are more than 15 years old and the
studies and data highlighted in this document indicate that these strategies are inadequate, as
the species is at a very high risk of extinction in the next 20-30 years or much sooner if the
habitat area is hit by another major bushfire.
Some of the existing conservation strategies for the species have been significantly watered
down, such as the process of habitat recognition2 by the Victorian Government. This has lead to
areas of suitable habitat being logged and further increasing the species’ risk of extinction
(Lindenmayer et al., 2013b).
Revising the current zoning system
We are deeply concerned about the re-zoning exercise either slated or already underway for
the Central Highlands region. The recent re-zoning exercise in East Gippsland has resulted in
very poor outcomes for the maintenance of natural values, including the protection of habitat
for endangered species in that region from logging. We are gravely concerned that the review
of Special Protection Zones (SPZs) in the Central Highlands will further undermine the prospect
for recovery of Leadbeater's Possum.
Based on the results of ongoing and recently updated work (Lindenmayer et al., 2013b) on the
habitat requirements of Leadbeater’s Possum, we support the suggestion that with regards to
the current zoning system for Leadbeater’s Possum there is a need to:
Redefine Zone 1 habitat for the species to include both living and dead trees
Reduce the detection rate from the original 50% probability of detection on a site (as per the
original 1A prescriptions) to a more conservative figure of 40%, in accordance with the
increasing rarity of the possum
100 m wide buffer should be established adjacent to the boundary of a given area of Zone 1
habitat to: (1) protect hollow-bearing trees from fires lit to regenerate nearby logged areas, (2)
protect hollow-bearing trees from wind damage, and (3) protect colonies of Leadbeater’s
Possum because the species is sensitive to disturbance of the surrounding landscape
(Lindenmayer et al., 1993, 2013a)
Areas of Zone 1 habitat should be recognised as Special Protection Zones
Careful aerial and on-ground assessments of all areas proposed for logging in the montane ash
forests must be completed prior to harvesting taking place to avoid areas of Zone 1 forest being
mistakenly logged
The location of areas of Zone 1 forest and the adjacent buffers must be mapped and the
subsequent spatial data lodged on the Government Geographic Information System to ensure
they are clearly delineated as logging exclusions
2
http://www.dse.vic.gov.au/__data/assets/%20pdf_file/0018/156231/APPROVED-DSE-LeadbeatersPossum-Survey-Standard_21012013.%20pdf
We support these points as actions that need to be taken at a minimum and we acknowledge
there are other forest values additional to the Leadbeater’s Possum that need to be taken into
consideration as well.
The Law is failing to protect the Leadbeater’s Possum
MyEnvironment Inc v VicForests [2013] VSCA 356
The result of the MyEnvironment v VicForests appeal highlights the weak environmental laws
and regulations which intend to protect flora and fauna such as the Leadbeater’s Possum.
Warren CJ found that the Leadbeater’s Possum Action Statement and the Central Highlands
Forest Management Plan provide protection of the species “by categorising areas of habitat
into three zones, each of which provides for a different level of protection” 3. However, the
stringent zoning classification of the species habitat in the regulatory instruments do not
protect “all suitable habitat of the Leadbeater’s Possum but only… capture optimal habitat, or
habitat with presently existing potential.”4 This is a significant problem as there is very little
‘optimal habitat’ left.
In addition, the trial judge found that the Leadbeater’s Possum action statement does not
impose enforceable obligations on VicForests, weakening the implementation of the species
action statement even further.5 This construction not only allowed VicForests to log the coupes
involved in this case, but establishes a precedent allowing them to do so in the future which
puts the species habitat and population at great risk.
Tate JA held that the density of hollow-bearing trees “required to attract the greatest degree of
protection depended upon the hollow-bearing trees being old hollow-bearing trees and not any
hollow-bearing trees regardless of age.”6 This interpretation of the legislation could allow for
VicForests to continue to legally log hollow-bearing trees, which could we have colonies of
Leadbeater’s Possum in them, so long as they are not over 120 years old.
The court in fact acknowledged that the species is “deemed to be in a demonstrable state of
decline which is likely to result in extinction or is significantly prone to future threats which are
likely to result in extinction.”7
Sustainable Forests (Timber) Act 2004 (Vic)
The plans to manage and protect the Central Highlands and the Leadbeater’s possum are
currently in force under various Victorian and Commonwealth legislation, however these laws
3
MyEnvironment v VicForests [2013] VSCA 356, [17].
ibid, [171] (4).
5
Appellants outline of submissions B3, 14.
6
MyEnvironment v VicForests [2013] 356, [22] per Tate JA.
7
Ibid. [48].
4
are inadequate. The Central Highlands Forest Management Plan (CHFMP) was due for review
over five years ago, and is yet to be reassessed or audited in its sixteen years of operations. Not
only are the predictions in this plan based on pre-1998 data, it has failed to integrate three
major wildfire events and the extensive Victorian drought. The fires in 2009 should have
triggered a review of the CHFMP, as significant proportions of Leadbeater’s Possum habitat was
destroyed by the wildfire (Lindenmayer, 2012).
The recent commencement of amendments made to the Sustainable Forests (Timber) Act 2004
(Vic) (SFTA) (The Sustainable Forests (Timber) Amendment Bill 2013) have weakened the
sustainability legislation for the Central Highlands and in turn the Leadbeater’s Possum habitat.
The changes have diluted, if not removed, government and environmental oversight of logging
in Victoria’s publicly-owned native forests. The legislation’s purpose is no longer only to provide
for environmentally sustainable logging practices, but rather to grant ‘long-term access to
timber resources in State forests’.( Sustainable Forests (Timber) Act 2004 (Vic) s1.) The
mandatory five-yearly government review of orders has been removed, and the limit on
allocation orders has been changed to grant VicForests indefinite ownership of native forests
(Flora and Fauna Guarantee Act 1988 (Vic) s1. ). These long-term contracts for logging in
publicly-owned forests are very risky and highly unsustainable as they would lock in supply of
wood that may not be available or even exist in several years. Despite Senator Colbeck’s claim
that by 2020 there will not be enough timber to sustain the industry, VicForests can now
implement twenty year logging contracts (Lindenmayer, 2012). There is now huge potential for
the irreversible damage of our native forests and the Leadbeater Possum’s habitat, pushing the
species further towards, if not to, extinction. The reduction of government oversight gives
extortionate power to VicForests. The VicForests board of directors can now decide to
commence logging without prior government approval of their timber release plan. VicForests
is a business enterprise with a singularly commercial objective, therefore the likelihood that
they will ensure the prosperity of the Leadbeater's possum is dismal. These amendments to the
legislation will substantially weaken the safeguarding of native forests, and will likely secure the
extinction of the Leadbeater’s Possum (Caripis, 2013).
Flora and Fauna Guarantee Act 1988 (Vic)
There are inadequate requirements in the Flora and Fauna Guarantee Act 1988 (Vic) (FFGA) for
measures to conserve threatened species to be implemented in the Forest Management Plans
(FMP) or the Action Statements. As a result, the Department of Sustainability & Environment
has not revised these plans on a regular basis, nor is there a system in place for such revision.
The failure of FMPs to be implemented reflects an inherent failure of the FFGA to achieve its
purpose, to ‘promote the conservation of Victoria's native flora and fauna’. (Flora and Fauna
Guarantee Act 1988 (Vic) s1.) A VAGO audit which was tabled in 2009 found that the “full range
of ‘management processes’ and ‘conservation and control measures’ available in the [FFGA] has
not been used”.8 This is largely due to the “perceived complexity and difficulty” of the relevant
8
VAGO: Administration of the Flora and Fauna Act 1988 (Vic) p 2.
provisions.9 In addition, there is a lack of time limits in the legislation which would ensure that
action statements are developed, finalised and implemented. In 2012, the Environmental
Defenders Office completed a report that found that the FFGA “remains very poorly
implemented, with many of the legal measures to protect flora and fauna never used.”10 This
further confirms that the current FFGA remains practically unenforceable, and cannot
adequately protect the endangered Leadbeater’s Possum.
In 2002 a review was conducted by the department which concluded that current policy
framework for the “protection of threatened species in Victoria is in need of a major
overhaul.”11 Whilst there was a multitude of recommendations made to improve the
legislation, no amendments have to this day been made.
The Central Highland Regional Forest Agreement (1998)
The Central Highland Regional Forest Agreement (1998) (RFA) bound the government to
‘provide for the protection of rare or threatened flora and fauna species and ecological
communities.’ (The Central Highlands Regional Forest Agreement (1998) s 54) This out-dated
and ineffective RFA was negotiated without minimum standards for environmental impact
assessment or habitat, and reviews have not been conducted into its effectiveness. In the
recent case of MyEnvironment v VicForests [2012] VSC 111, Justice Obsorn declared that the
aforementioned clause of the RFA has not been achieved. He held that an Action Statement
does not actively protect the habitat of the Leadbeater’s Possum independently; rather it
defaults to the FMP. Without being reviewed, the FMP does not fulfil the obligation to integrate
‘community expectations’, new information and other developments to provide for protection
of native flora and fauna.
Victorian Auditor_General’s Office Audit: Managing Victoria's Native Forest Timber Resources
(December 2013)
A recent audit of the Victorian native forest timber resources has found that both VicForests
and the Department of Environment and Primary Industries (DEPI) have “not established all
plans necessary to manage the recovery of threatened species, or reviewed existing plans
following successive, substantial fires.”12 Both entities have failed to meet their obligations,
highlighting how current legislation does not adequately ensure the protection of endangered
species such as the Leadbeater’s Possum.
9
Ibid.
Where’s the guarantee? Implementation and enforcement of the Flora and Fauna Guarantee Act 1998
& Wildlife Act 1975, 3.
11
VAGO: Administration of the Flora and Fauna Act 1988 (Vic) Audit Summary, p 2.
12
VAGO: Managing Victoria’s Native Forest Timber Resources, 4.3.2, p 35-36.
10
In 2012 a full review of the SFTA was completed, however the government's terms of reference
“limited the review primarily to improving certainty around timber supply”.13 This review
focused on the logging and timber production outcomes, rather than assessing timber
production giving consideration to environmental or sustainability practices.14 The review of
this legislation therefore gave almost no consideration to the protection of the endangered
species occupying Victoria’s forests and resulted in the removal of a large amount of
government oversight in regard to VicForest’s operations.
In sum, the whole management and legislative protection system is failing to protect the
Leadbeater’s Possum. The statutory requirements within Forest Management Plans and Action
Statements highlight that the current management of the Leadbeater’s Possum habitat are
completely inadequate. There have been a number of audits and investigations into the
legislative protection of Victoria’s native forests, however those which increase protection for
endangered species are yet to be adequately enacted. In addition, the recent Sustainable Forest
(Timber) Amendment Bill have reduced the protection of Victoria’s native forests substantially.
Fire management practices
Lindenmayer’s findings (Lindenmayer et al., 2013a) underscore the importance of management
practices to better protect species that decline after fire. These include conserving areas of
unburned forest, particularly those with hollow-bearing trees which are critical nest sites for
arboreal marsupials. These recommendations are currently the opposite of existing
management practices.
Mitigating fire risk by tackling climate change more rigorously is critical in ensuring a healthy
forest ecosystem. With the evidence presented in this submission, and with particular regard to
new scientific findings, it is clear that the old Eucalyptus Regnans play a significant role in
mitigating climate change and in turn fire risk. Thus, it is imperative that we keep these old
trees intact to avoid this dangerous cycle and to ensure the Leadbeater’s Possum does not fall
under more pressure than it already is under.
Management practices to avoid the landscape trap in Mountain Ash Forests of Victoria
Proactive and long sighted management is crucial to prevent the development of landscape
traps given that landscape traps might be at increased risk for development in response to
significant major natural disturbances, which are likely to become more frequent, more severe,
or both in the Central Highlands of Victoria under rapid climate change.
13
14
Ibid 4.3.1 p 34.
Ibid.
The management interventions that we would recommend to reduce the probability of
landscape traps developing are:
To recognise that landscape traps can exist and identify the suite of spatial and temporal
characteristics that can combine to give rise to them, including; exploitation of the natural
resources in a landscape through unsustainable logging practices, alteration in the spatial
characteristics of landscapes, including modifications to the frequency and severity of
ecological disturbances, feedbacks between altered environmental conditions and other major
anthropogenic stressors, and severely impaired landscape processes and functions. After
developing the suite of spatial and temporal characteristics we suggest particular emphasis
needs to be placed on dramatically reducing the anthropogenic stressors that are fueling the
threat of this landscape trap, in particular unsustainable logging activities.
17. Can you recommend other actions that would aid the protection and recovery of the
species? Please provide supporting information.
The ongoing threat of logging and associated increases to fire risk in the Central Highlands need
to be addressed as a central issue when looking at increasing protection and allowing for
recovery of the Leadbeaters Possum. Central to addressing these risks is reform of the logging
industry across the range of the Leadbeater's Possum, primarily through significant reduction in
logging for woodchips.
Image: Karena Goldfinch
Inclusion of alternative feedstocks to Australian Paper's Maryvale mill is crucial to reducing
logging pressure on forest habitat, and must be a critical component of achieving both the
recovery of the Leadbeater’s Possum and ensuring the timber industry in Victoria is more
sustainable. Australian Paper is the major buyer of pulplogs from Victoria’s native forests.
Under the Forest (Wood Pulp Agreement) Act 199615, the legislated wood contract between
government and Australian Paper is currently 350,000m3 per annum.
There is a clear choice for the State to improve and reform the Victorian wood products
industry and reduce logging for woodchips in state forests, or continue to commit our unique
and precious wildlife to extinction by allowing the logging to continue at current rates.
Logging is driving the Leadbeater’s Possum towards extinction. We therefore contend that
recovery of the Leadbeater’s Possum, while maintaining current levels of logging in native
forests, is not possible.
Consideration of alternative plantation feedstocks, primarily for Australian Paper is critical to
the recovery of the species. Victoria's plantations are already producing around three times the
volume of pulplogs compared to that of native forests (ABARES Australian Forest and Wood
Products Statistics) - and there is great potential for Australian Paper to use the established and
available plantation estate, particularly in western Victoria.
Australian Paper already utilises the western Victorian plantation resource as a minor
component of its paper manufacturing, however for a more complete shift of its feedstock the
company will need stronger incentives to change its practices - particularly stronger
conservation prescriptions for the protection of the Leadbeaters Possum and likely Government
assistance for the transition to an alternative plantation resource.
The available scientific information clearly indicates that new strategies based on the best
available and most up-to-date science are urgently required. Professor David Lyndenmayer and
his team have provided guidelines for a new approach to restoration forest management to
better conserve Leadbeater’s Possum and rebuild the (ecologically) mature forest estate in the
Central Highlands of Victoria. It is our view that Professor Lindenmayer’s suite of forest
management prescriptions (Lindenmayer et al., 2013b) must be implemented as a matter of
urgency and at a minimum.
The following is a summary of the suggestions from this report:
1. A new zoning system for Leadbeater’s Possum - redefine zone 1 habitat for the species,
taking into account living and dead trees in definition of zone 1 forest; establish 100m buffer
zone adjacent to boundary of zone 1 to protect hollow-bearing trees from lit fires and wind
damage, etc.
2. Strengthened protection of locations known to support Leadbeater’s Possum - protect sites
where species have been detected/recorded in last 15 years.
3. Enhanced protection of all living and dead hollow-bearing trees - each existing living and
15
http://www.austlii.edu.au/au/legis/vic/consol_act/fpaa1996309/
dead hollow-bearing tree be buffered by a surrounding area of unlogged forest.
4. Protect all areas of existing old growth and expand the cover of old growth to 30% of all
Leadbeater’s Possum Management Units - a new approach to “restoration forestry” is needed
that aims to ensure that at any given time, 30% of the area of each Leadbeater’s Possum
Management Unit will be old growth forest.
5. Expanded riparian buffers - increase width of riparian (streamside) reserves within wood
production forests to better protect existing hollow-bearing trees, increase the chances that
existing regrowth trees can grow through to ecological maturity and become hollow-bearing
trees, and increase the chances that areas of retained forest will provide suitable habitat for
Leadbeater’s Possum
6. Replacement of clearfell logging by modern retention harvesting - Experimental work
undertaken by ANU in collaboration with VicForests and the Department of Sustainability and
Environment has clearly shown that variable retention harvesting is logistically feasible in
Victorian Mountain Ash forests.
7. Revised estimates of the area available for logging, the allocation order and sustained
timber and pulpwood yield - These revisions will be needed once the prescriptions have been
implemented (and not vice versa). Exit packages likely to be needed for timber workers and
contractors, however, additional jobs may be found in implementing the prescriptions.
Creation of a Great Forest National Park
The new Great Forest National Park16 is a proposal to create a two tiered park system for bush
users and bush lovers alike that protects and maintains this important ecosystem function. The
park stretches from the Kinglake National Park right through to the Baw Baw's and to the North
East up to Eildon.
The Great Forests Park will be an investment for the long-term because it will secure the
conservation of the Leadbeater's Possum and bring it back from the brink of extinction. To
ensure the species survival, we would argue we need to create a new national park, not only to
the species and the forests; but carbon stocks, water supplies, and lower the risk of bushfires.
In the context of the conservation Leadbeater’s Possum there is a need to expand our reserves
in the area for the following reasons:
The current reserve system is too small to support a viable population of Leadbeater’s Possums,
particularly if there are more fires in the near future
16
http://www.greatforestnationalpark.com.au/park-plan.html
A large ecological reserve provides a greater chance for natural fire regimes and growth of large
old trees to be restored
As Mountain Ash forests store vast amounts of carbon, a new national park will be critical to
maintaining carbon stocks. The park would therefore be critical to any policy to reduce carbon
emissions
The new park needs to connect key areas of habitat for Leadbeater’s Possum, and also connect
existing reserves. Connectivity like this promotes the dispersal of the possums through the
forests, including those recovering after wildfire. The national park must encompass areas of
existing old growth forest and also areas where environmental modelling indicates old growth
will develop in the future. The park must also be big enough to be larger than major
disturbance events such as wildfires. This will ensure there is sufficient habitat to support viable
populations of Leadbeater’s Possum.
Image: Emma Campbell
At the same time as creating the park, pulp and timber yield from the the Mountain Ash forests
must be reduced. Mountain Ash forests have already been over-cut, and to maintain sustained
yield from the forests and set aside the Giant Forest National Park will even further increase
over-cutting. This is because it will concentrate industrial clearfelling on a reduced area of
available forest. This is why it is imperative for the State to improve and reform the Victorian
wood products industry and reduce logging for woodchips in state forests, otherwise we will
continue to commit our unique and precious wildlife to extinction by allowing the logging to
continue at current rates.
18. What organisations and individuals are currently, or potentially could be, involved in
management and recovery of the species?
There are a number of organisations, NGOs, friends of groups and individuals involved in the
management and recovery of the species; all of which have an important part to play and
should continue to be involved in the process accordingly . The Wilderness Society Victoria
supports the involvement of Traditional Owners in the management and recovery of this
species.
Conclusion
In the 15 years since the last major strategies for the conservation of Leadbeater’s Possum
were developed considerable new research has been conducted. This work has demonstrated:
There have been significant losses of large old (hollow-bearing) trees which are nesting sites for
Leadbeater’s Possum (Lindenmayer et al., 2012).
Old growth stands – which support the highest abundance of hollow-bearing trees
(Lindenmayer et al., 1991) – are a tiny fraction (1/30th-1/60th) of what they were at the time
of white settlement. This is the result of a century of logging (including the deliberate past
conversion of old growth forest into regrowth stands), 40 years of intensive and extensive
clearfelling, and repeated wildfires (Lindenmayer et al., 2012a).
Leadbeater’s Possum is absent from sites burned in the 2009 fire and the abundance of the
species is significantly depressed on unburned sites where the surrounding landscape has been
burned (Lindenmayer et al., 2013a).
Extensive fires in 2009 have damaged almost half of the known habitat of Leadbeater’s Possum
and the species appears to be on an extinction trajectory. Indeed, populations of Leadbeater’s
Possum have been lost from extensive areas such as the Lake Mountain region.” (Lindenmayer
et al., 2013b).
The Wilderness Society is committed to ongoing advocacy in support of measures to protect
the Leadbeater’s Possum, and likewise the condition of the forests of the Central Highlands in
which the Leadbeater’s Possum lives. The Leadbeater’s Possum is one of the most-studied
animals on the planet. After three decades of extensive research, the science is very clear, as is
the extinction trajectory of the animal. We agree with the nomination to uplist the species to
critically endangered and when looking at all of the factors mentioned in this submission ,the
nomination and the related studies, we believe the species meets the criteria to be uplisted
and we urge the committee to recommend an uplisting.
It is our view that effectively resolving the crisis around the Leadbeater’s Possum, in both the
short-term and for the long-term, is the foremost environmental challenge facing the Victorian
Government. Uplisting the species to critically endangered would be a significant step in
ensuring its ongoing survival.
Additional to this, we suggest there is a clear choice for the State to improve and reform the
Victorian wood products industry and reduce logging for woodchips in state forests, or continue
to commit our unique and precious wildlife to extinction by allowing the logging to continue at
current, unsustainable rates.
Extinction is of course not something that happens overnight; it does not simply occur the
moment the last individual of a species dies. Extinction occurs over years and decades. As such,
now is the time for meaningful, courageous intervention.
Given that logging is the single greatest threat to the Leadbeater’s Possum’s survival and that it
is currently occurring and is controllable, it is our view that if the State is serious about rescuing
its animal emblem from extinction, this activity ought to be halted in known habitat while the
processes unfold for the consultation for uplisting the species to critically endangered and the
Leadbeaters Possum Advisory Group discussions.
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