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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. REFERENCE LIST Banks, S.C., Knight, E.J., McBurney, L., Blair, D. and Lindenmayer, D.B. 2011. ‘The effects of wildfire on mortality and resources for an arboreal marsupial: resilience to fire events but susceptibility to fire regime change’, PLOS One, 6: 22952 Butt, N. 2013. ‘Give me a home among the gum trees But what if those gum trees lose their home to climate change? - Decision Point #72’, University of Queensland. Viewed 16th January, 2014, <http://decisionpoint.com.au/images/DPoint_files/DPoint_72/dp72%20p8%20butt%20gum%20trees.pdf> Caripis, L. 2013. ‘Victorian law change abandons native forests to loggers’, The Conversation, 27th May. Viewed 16th January, 2014, <https://theconversation.com/victorian-law-changeabandons-native-forests-to-loggers-14113> Clarke, H., Lucas, C., Smith, P., 2012. ‘Changes in Australian fire weather between 1973 and 2010’, International Journal of Climatology, 33(4): 931-944 Climate Commission. 2011. ‘The Critical Decade: Climate Science, Risks and Response’, Climate Commission Secretariat, Department of Climate Change and Energy Efficiency, Canberra Collinge, S.K. 2009. Ecology of Fragmented Landscapes, ‘The John Hopkins University Press’, Baltimore, USA Department of Sustainability and Environment [DSE]. 2013.‘Advisory List of Threatened Vertebrate Fauna in Victoria’, DSE Victorian Government, Melbourne. Viewed 16th January, 2014, <http://www.depi.vic.gov.au/__data/assets/pdf_file/0019/210439/Advisory-List-ofThreatened-Vertebrate-Fauna_FINAL-2013.pdf> Department of Sustainability and Environment (2013) Advisory List of Threatened Vertebrate Fauna in Victoria, March 2013. Hansen, B.D., and Taylor, A.C. 2008. ‘Isolated remnant or recent introduction? Estimating the provenance of Yellingbo Leadbeater's possums by genetic analysis and bottleneck simulation’, Molecular Ecology 17: 4039–4052. Hansen, B.D., Harley, D.K.P., Lindenmayer, D.B. and Taylor, A.C. 2009. ‘Population genetic analysis reveals a long-term decline of a threatened endemic Australian marsupial’, Molecular Ecology 18: 3346–3362. Lumsden, L.F., Nelson, J.L., Todd, C.R., Scroggie, M.P., McNabb, E.G., Raadik, T.A., Smith, S.J., Acevedo, S., Cheers, G., Jemison M.L. and Nicol M.D. 2013. ‘A New Strategic Approach to Biodiversity Management – Research Component’, Arthur Rylah Institute for Environmental Research, Department of Environment and Primary Industries, Victoria. Lindenmayer, D.B., Cunningham, R.B., Tanton, M.T., Nix, H.A. and Smith, A.P. 1991. ‘The conservation of arboreal marsupials in the montane ash forests of the Central Highlands of Victoria, south-east Australia: III. The habitat requirements of Leadbeater’s Possum Gymnobelideus leadbeateri and models of the diversity and abundance of arboreal marsupials’, Biological Conservation, 56: 295-315 Lindenmayer, D.B, Cunningham, R.B, and Donnelly, C.F. 1993. ‘The conservation of arboreal marsupials in the montane ash forests of the Central Highlands of Victoria, south-east Australia: IV. The presence and abundance of arboreal marsupials in retained linear habitats (wildlife corridors) within logged forest’, Biological Conservation, 66: 207–221 Lindenmayer, D.B. 2009. ‘Forest Pattern and Ecological Process: A Synthesis of 25 Years of Research’, CSIRO Publishing, Melbourne Lindenmayer, D.B., Hobbs, R.J., Likens, G.E., Krebs, C.J. and Banks, S. 2011. ‘Newly discovered landscape traps produce regime shifts in wet forests’, PNAS, 108(38):15887–15891 Lindenmayer, D.B. 2012. ‘Sending Leadbeater’s Possum down the road to extinction’, The Conversation, 14th December. Viewed 18th January, 2014, <http://theconversation.com/sending-leadbeaters-possum-down-the-road-to-extinction11249> Lindenmayer, D.B., Laurance, W.F. and Franklin, J.F. 2012. ‘Global Decline in Large Old Trees’, Science, 6112(338): 1305-1306. Lindenmayer, D.B., Blanchard, W., McBurney, L., Blair, D., Banks, S., Likens, G.E., Franklin, J.F., Laurance, W.F., Stein, J.A. and Gibbons, P. 2012. ‘ Interacting factors driving a major loss of large trees with cavities in a forest ecosystem’, PLoS ONE 7(10) Lindenmayer, D.B. and Possingham, H.P. 2013. ‘No Excuse for Habitat Destruction’, Science 10, 6133(340): 680 Lindenmayer, D. B., Blanchard, W., Mcburney, L., Blair, D., Banks, S. C., Driscoll, D., Smith, A. L. and Gill, A. M. 2013a. ‘Fire Severity and landscape context effects on arboreal marsupials’, Biological Conservation, 167(12): 137 Lindenmayer, D.B., Blair,D., McBurney, L., and Banks, S. 2013b. ‘New Restoration Forest Management Prescriptions to Conserve Leadbeater’s Possum and Rebuild the Cover of Ecologically Mature Forest in the Central Highlands of Victoria; Version , The Australian National University, Canberra. Viewed 17th January, 2014, <http://fennerschoolassociated.anu.edu.au/documents/New_Manag_Pres_%20VS2_%202_July_2013.pdf> Lindenmayer, D. B., Hunter, M.L., Burton, P.J. and Gibbons, P. 2009. ‘Effects of logging on fire regimes in moist forests’, Conservation Letters, 2(6): 271-277 Lindenmayer, D. B, Malcolm L. Hunter, Philip J. Burton, & Philip Gibbons. 2009. ‘Effects of logging on fire regimes in moist forests’, 10.1111/j.1755-263X.2009.00080.x Mackey, B.G., Lindenmayer, D.B., Gill, A. M., McCarthy, M. A. and Lindesay, J. A. 2002. ‘Wildlife, Fire and Future Climate: A forest ecosystem analysis;. CSIRO Publishing. Melbourne. 188 pp. In. Owen, W.H. 1963. ‘Further sight records of Leadbeater’s Possum’, Victorian Naturalist 79: 292293 Brendan Mackey, Heather Keith, Sandra L. Berry and David B. Lindenmayer 2008 ‘Green Carbon - The role of natural forests in carbon storage’ Tollefson, J. 2014. ‘Tree growth never slows’, Nature, DOI:10.1038 Victorian Government. 2009. ‘2009 Victoria's Timber Industry Strategy’, Department of Primary Industries, Melbourne. Viewed 17th January, 2014,< http://www.dpi.vic.gov.au/forestry/aboutforestry/projects-and-initiatives/timber-industry-action-plan/timber-industry-strategy/timberindustry-strategy-development-process>