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E N V I R O N M E N T A L A U D I T

2005 SPECIAL FOREST AUDIT

ENVIRONMENTAL AUDIT

2005 SPECIAL FOREST AUDIT

EPA Victoria

40 City Road, Southbank

Victoria 3006 AUSTRALIA

February 2006

Publication 1030

ISBN 0 7306 7653 6

Geoff Byrne of URS was commissioned by EPA, in his capacity as an environmental auditor appointed pursuant to

Part IXD of Environment Protection Act 1970, to conduct an environmental audit of timber production on public

land in accordance with the scope of work described in this report. This report contains the findings and

recommendations of this audit.

DATED: 16 January 2006

SIGNED:

GEOFFREY MICHAEL BYRNE

ENVIRONMENTAL AUDITOR

URS AUSTRALIA PTY LTD

© EPA Victoria, 2006

EXECUTIVE SUMMARY

Background

This audit reports on four recent logging incidents

that have occurred during harvesting operations

within state forests in Victoria at the following

coupes:

• Coupe 885-510-0024, Bambam, Cann

River District

• Coupe 874-506-0012, Bicentenial, Cann

River District

• Coupe 864-508-0004, Falls Track, Cann

River District

• Coupe 105-509-0006, Flanagans, Nathalia

District.

The Cann River District coupes, all located in East

Gippsland, were supervised by VicForests, whilst the

Nathalia District coupe, located in the Barmah State

Forest, was supervised by the Department of

Sustainability & Environment (DSE). The incidents

occurred in either 2004 or 2005.

The audit has been undertaken in accordance with

section 53V of the Environment Protection Act, but

does not assess compliance of other aspects of the

harvesting operations with the Code of Forest

Practices, require the issue of Certificate or

Statement of Environmental Audit nor assess the

impact of the logging activities associated with the

incidents.

The specific scope as defined by EPA was to assess:

• procedures that were required to be

followed in the planning and delineation

of the harvesting operations at the coupes

• nature, cause, extent of, and reasons for,

any incursions into the protected areas

associated with these harvesting

operations

• steps undertaken in the planning and

marking of these coupes and whether

these complied with the required

procedures

• changes required to ensure that

harvesting boundaries are properly

defined and implemented and that

protected areas are excluded from forestry

operations

• appropriateness of any changes that were

adopted by the relevant agencies in

response to the incidents.

In examining the changes required, the auditor has

been requested to examine the chain of

accountabilities that apply to coupe planning and

subsequent operations, and whether these are

sufficient to ensure good practice.

The auditor has also been requested to report on

accountabilities, procedures and methods used for

identification, delineation, marking and

management of harvesting areas in other Australian

States and consider these in any recommendations

made.

The period of the audit was July 2004 to November

2005.

The methodology that was adopted comprised a

review of available documentation, standard

operating procedures and relevant legislation;

interviews with DSE and VicForests staff; and site

visits. The site visits included an inspection of each

coupe except for the Barmah forest coupe, which

was inaccessible at the time.

Findings

The field inspections and data review of the four

coupes have confirmed that incursions have

occurred into protected areas at two coupes and

harvesting has extended beyond the nominated

boundaries at the other two, as follows:

• a small section of the Errinundra National

Park has been harvested at coupe 885-

510-0024 (Bambam)

• harvesting has extended beyond the

nominated coupe boundaries at coupes

874-506-0012 (Bicentennial), 864-508-

0004 (Falls Track) and 105-509-0006

(Flanagans) without appropriate authority

• a substantial portion of a superb parrot

Special Protection Zone has been

selectively logged at coupe 105-509-0006

(Flanagans).

In summary the causes of the incidents can be

grouped as follows:

• assumption by VicForests and DSE staff

that features depicted and information

contained in the Coupe Information

System (CIS) are accurate and complete

(all coupes)

• inadequacies in the Forest Coupe Plan

documentation regarding:

• definition of boundaries for protected

areas (Bambam & Flanagans)

• physical features defining coupe

boundaries (all coupes)

• gross and net coupe area (Falls Track)

• insufficient ground confirmation of

boundaries (Bambam, Bicentennial &

Flanagans)

• failure to document and obtain approval

for coupe boundary modifications (Falls

Track & Flanagans)

• assumption by VicForests and DSE staff

that nominated coupe boundaries can be

changed without further cross-functional

review (Falls Track & Flanagans)

• breakdown in the system for agency cross-

functional harvesting review, resulting in

relevant information not being considered

in coupe marking (Bambam & Flanagans).

An examination of planning and regulatory systems

in place nationally and internationally found the

following themes:

• independent bodies are used to regulate

and audit harvesting operations

• provisions exist for penalties once a legal

or regulatory breach is proven

• licensing systems are used to regulate

competencies

• environmental management systems are

in place

• physical features such as roads and water

features are used to define harvest areas

but that these do not translate directly

from a map into the field

• GPS survey techniques are used to

identify harvest boundaries and

protection areas.

The Cann River District office of VicForests, and to a

lesser extent the Nathalia District office of DSE, have

implemented a number of procedural changes to the

oversight of coupe management and documentation

control, many of which should be considered for

adoption in other forestry offices. The most

significant of these include the implementation of a

coupe planning checklist and sign-off pro-forma,

coupe filing system, centralised overview of coupe

activities by District management, greater use of

GPS in coupe marking and better coordination of

staff training.

Appropriate processes for field marking have also

been incorporated in Statewide management

procedures dated October 2005.

Building on these changes, a number of additional

recommendations are made in this audit report to

reduce the risk of similar incidents occurring in the

future and ensure good practice. These include

implementation of proposed environmental

management systems; clarification of limitations

and exclusions of CIS; accurate definition and

documentation of coupe boundaries in the Forest

Coupe Plan; sign-off by senior staff that appropriate

coupe marking has been carried out; formalising GIS

mapping hierarchy; better document control;

clarification of organisational roles in the cross-

functional checking processes; and increased

application of the coupe diary system.

T A B L E O F C O N T E N T S

1. BACKGROUND.................................................................................................................................. 8 2. SCOPE OF WORK......................................................................................................................... 9

2.1. Scope and period of audit ...................................................................................................... 9 2.2. Methodology ......................................................................................................................... 9 2.3. Audit criteria .......................................................................................................................... 9

2.3.1. Code of Forest Practices for Timber Production..................................................................10 2.3.2. Management procedures and prescriptions ......................................................................10

2.4. Support team........................................................................................................................10 3. LEGISLATIVE BACKGROUND ............................................................................................................. 11

3.1. General framework................................................................................................................ 11 3.1.1. Wood Utilisation Plan ....................................................................................................... 11 3.1.2. Timber Release Plan ......................................................................................................... 11 3.1.3. Conservation, Forests and Lands Act 1987 ......................................................................... 12 3.1.4. Sustainable Forests (Timber) Act 2004 .............................................................................. 12

3.2. Yorta Yorta Agreement .......................................................................................................... 13 3.3. Specific issues...................................................................................................................... 13

3.3.1. Harvesting greater than the allocated TRP or WUP coupe area ........................................... 13 3.3.2. Harvesting outside a coupe boundary............................................................................... 14 3.3.3. Harvesting a Special Protection Zone................................................................................ 14 3.3.4. Harvesting in a threatened species habitat ....................................................................... 15 3.3.5. Harvesting in a National Park............................................................................................ 15

3.4. Penalty provisions ................................................................................................................ 15 4. FINDINGS – EAST GIPPSLAND COUPES ....................................................................................... 17

4.1. Coupe 885-510-0024, Bambam, Cobon block, Cann River District .......................................... 17 4.1.1. Coupe history ................................................................................................................... 17 4.1.2. Nature and extent of incident............................................................................................ 17 4.1.3. Cause(s) of Incident......................................................................................................... 20

4.2. Coupe 874-506-0012, Bicentennial, Cann River District .........................................................23 4.2.1. Coupe history ...................................................................................................................23 4.2.2. Nature and extent of incident............................................................................................23 4.2.3. Cause(s) of incident......................................................................................................... 24

4.3. Coupe 864-508-0004, Falls Track, Cann River District ............................................................25 4.3.1. Coupe history ...................................................................................................................25 4.3.2. Nature and extent of incident........................................................................................... 26 4.3.3. Cause(s) of incident..........................................................................................................27

4.4. Processes and procedures at time of, and implemented since, incidents.............................. 28 4.4.1. Management procedures................................................................................................. 28 4.4.2. Other processes and procedures ..................................................................................... 28

5. FINDINGS – NORTH-EAST COUPE......................................................................................................32 5.1. Coupe 105-509-0006, Flanagans, Barmah block, Nathalia District .........................................32

5.1.1. Coupe history ...................................................................................................................32 5.1.2. Nature and extent of incident............................................................................................35 5.1.3. Cause(s) of incident..........................................................................................................35

5.2. Processes and procedures at time of, and implemented since, incident................................ 36 5.2.1. Management procedures................................................................................................. 36 5.2.2. Other processes and procedures ..................................................................................... 36

6. PROCESSES IN OTHER JURISDICTIONS....................................................................................... 38 6.1. Tasmania............................................................................................................................. 38 6.2. Western Australia ................................................................................................................ 39 6.3. New South Wales................................................................................................................. 39 6.4. California............................................................................................................................. 40 6.5. British Columbia ...................................................................................................................41 6.6. Indonesia ............................................................................................................................. 41 6.7. Forest practice certification and endorsement schemes........................................................ 42

6.7.1. ISO 14001........................................................................................................................ 42 6.7.2. Forest Stewardship Council certification .......................................................................... 42 6.7.3. Australian Forestry Standard............................................................................................ 42 6.7.4. Food and Agriculture Organisation Model Code of Harvesting Practice...............................43

6.8. Summary of common themes................................................................................................43 7. CONCLUSIONS ................................................................................................................................44 8. RECOMMENDATIONS .................................................................................................................45 9. BIBLIOGRAPHY ......................................................................................................................... 48

L I S T O F T A B L E S

Table 4.1: VicForests pre and post incident procedures – VicForests coupes .......................................... 29 Table 4.2: DSE pre and post incident procedures – VicForests coupes..................................................... 31 Table 4.3: Parks Victoria pre and post incident procedures – VicForests coupes...................................... 31 Table 5.1: DSE pre and post incident procedures – DSE coupe ................................................................37

F I G U R E S

Figure 4.1: Bambam coupe map as used in the field................................................................................18 Figure 4.2: Part of Certified plan Errinundra National Park .......................................................................19 Figure 4.3: Boundaries Determined in Field............................................................................................ 20 Figure 4.4: Coupe map and national park layer in CIS............................................................................. 22 Figure 4.5: Bicentenial coupe map indicating planned boundary and actual harvest extent .................... 24 Figure 4.6: Falls Track coupe map indicating planned boundary and actual harvest extent ..................... 26 Figure 5.1: Flanagans coupe map (105-509-0009) as seen in CIS .............................................................33 Figure 5.2: Approximate extent of harvesting in area of SPZ (as advised by DSE) .....................................34

2 0 0 5 S P E C I A L F O R E S T A U D I T

EPA Victoria 8

1 . B A C K G R O U N D

This audit reports on four recent logging incidents

that have occurred during harvesting operations

within state forest in Victoria. The objectives of the

audit are to examine incidents at the following

coupes:

• Coupe 885-510-0024, Bambam, Cann

River District

• Coupe 874-506-0012, Bicentenial, Cann

River District

• Coupe 864-508-0004, Falls Track, Cann

River District

• Coupe 105-509-0006, Flanagans, Nathalia

District.

The Cann River District coupes, all located in East

Gippsland, were supervised by VicForests, whilst the

Nathalia District coupe, located in the Barmah Sate

Forest, was supervised by the Department of

Sustainability & Environment (DSE). All the incidents

occurred in 2004 and 2005.

The audit has been undertaken in accordance with

section 53V of the Environment Protection Act, but

does not:

• assess compliance of other aspects of the

harvesting operation with the Code of

Forest Practices

• require the auditor to issue a Certificate of

Environmental Audit or Statement of

Environmental Audit

• assess the impact of the logging activities

associated with the incidents.


Environmental Audit 9

2 . S C O P E O F W O R K

2.1. Scope and period of audit

The specific scope as defined by EPA was to assess:

• procedures that were required to be

followed in the planning and delineation

of the harvesting operations at the coupes

• nature, cause, extent of, and reasons for,

any incursions into the protected areas

associated with these harvesting

operations

• steps undertaken in the planning and

marking of these coupes and whether

these complied with the required

procedures

• changes required to ensure that

harvesting boundaries are properly

defined and implemented and that

protected areas are excluded from forestry

operations

• appropriateness of any changes that were

adopted by the relevant agencies in

response to the incidents.

In examining the changes required, the auditor has

been requested to examine the chain of

accountabilities that apply to coupe planning and

subsequent operations, and whether these are

sufficient to ensure good practice.

The auditor has also been requested to report on

accountabilities, procedures and methods used for

identification, delineation, marking and

management of harvesting areas in other Australian

States and consider these in any recommendations

made.

The period covered by the audit was July 2004 to

December 2005.

2.2. Methodology

The methodology that was adopted comprised:

• document review of available background

information relating to the incidents

• review of available DSE and VicForests

standard operating procedures that

applied at the time of harvesting

• review of relevant legislation

• interviews, where appropriate, with DSE

and VicForests managerial and technical

staff

• site visits to each of the four harvesting

operations

• interviews with relevant DSE and

VicForests field staff.

The site visits comprised brief inspections at each of

the coupes with the exception of the Barmah forest

coupe (105-509-0006), which was flooded at the

time. During the site inspections observations of the

nature and extent of the incidents were made. Field

measurements, as appropriate, were made using a

range finder and a Trimble GPS XRS with satellite

differential correction, which provided sub-metre

accuracy.

2.3. Audit criteria

Any audit must utilise a benchmark, or framework,

against which the risks, systems and performance of

the audited operations are referenced. For this

audit, the criteria contained in the following

documents have been utilised.


EPA Victoria 10

2.3.1. Code of Forest Practices for Timber

Production

The Code of Forest Practices for Timber Production

Revision No. 2, 1996 (the Code) was developed

through a process of scientific review and

community consultation and was ratified in

accordance with section 55 of the Conservation,

Forests and Lands Act 1987.

The stated purpose of the Code is to ensure that

commercial timber growing and timber harvesting

operations are carried out on both public land and

private land in a way that:

• promotes an internationally competitive

forest industry

• is compatible with the conservation of the

wide range of environmental values

associated with the forests

• promotes the ecologically sustainable

management of native forests proposed

for continuous timber production.

The Code recognises that conservation of forests

depends upon careful stewardship and responsible

management so that they can continue to provide

benefits to society. To this end the Code provides

guidelines and prescriptions for environmental

protection during commercial harvesting operations.

The Code is available from the DSE website

(www.dse.vic.gov.au) and is due for revision in

2006.

2.3.2. Management procedures and prescriptions

The Code is augmented by additional prescriptions

(management and utilisation) that are tailored to the

specific characteristics of forests within each region.

The regional prescriptions have recently been

consolidated into a set of Statewide procedures.

There are also native forest silvicultural guidelines,

management plans, utilisation procedures and local

management guidelines that are all relevant to

operations in particular areas.

These include:

• Management Prescriptions for Timber

Production and Other Forest Uses,

Gippsland Region

• Management Procedures for Timber

Harvesting and Associated Activities in

State Forests in Victoria

• Utilisation Procedures for all commercial

harvesting in State forests in Victoria

• Native Forest Silviculture Guideline No. 6,

Site Preparation

• East Gippsland Forest Management Plan

• Forest Management Plan for the Mid-

Murray Forest Management Area

• Wood Utilisation Planning Guidelines.

2.4. Support team

In completing this audit, support to the auditor was

provided by the following personnel:

• Daan Oranje, Senior Resource Analyst

(URS)

• Peter Boyle, Associate (URS)

• Andrew Morton, Vice President, URS

Forestry (URS).

Peter Tange represented EPA during the visit to Cann

River and Nathalia.



3 . L E G I S L A T I V E B A C K G R O U N D

There is a variety of legislation and subordinate

legislation that may be relevant to the alleged

breaches. The general application of the legislation

and associated policies are summarised in the

following section.

The comments made here or elsewhere in this report

do not purport to give legal advice. Only qualified

legal practitioners can give legal advice.

3.1. General framework

3.1.1. Wood Utilisation Plan

The Code requires the preparation of a Wood

Utilisation Plan (WUP) every year. The WUP provides

a three-year schedule of harvesting activities

managed by DSE.

The WUP is used primarily by DSE staff for wood

production and road construction and improvement

planning purposes, specifying the kind and quantity

of wood to be produced over a three-year period.

The WUP also provides information to the public

regarding the location and approximate timing of

harvesting and construction.

Since the promulgation of the Sustainable Forests

(Timber) Act 2004, WUPs are not required to be

prepared for harvesting activities managed by

VicForests. Instead the Timber Release Plan (TRP) is

prepared by VicForests, taking into account various

guidelines and policies.

The Wood Utilisation Planning Guidelines for State

Forests in Victoria outline a number of objectives

and requirements. These are discussed in terms of

the main areas relevant to the alleged breaches

below.

3.1.2. Timber Release Plan

A Timber Release Plan (TRP) 2004–2009 has been

prepared by VicForests under S37 of the Sustainable

Forests (Timber) Act 2004 for the period 1 August

2004 to 30 June 2009. The TRP is prepared taking

into account the Memorandum of Understanding,

dated 16 July 2004, between the Secretary DSE and

VicForests, and the Wood Utilisation Planning

Guidelines for State Forests in Victoria (Forestry

Victoria, DSE 2003).

Similar to the WUPs, the objective of the TRP is to

provide a schedule of coupes selected for timber

harvesting and associated access road requirements

and to identify the location and timing of harvesting

and construction works.

Under the TRP Part 6 Specified Conditions:

‘In undertaking authorised activities, VicForests

will comply with the conditions in the following

documents as amended from time to time…

• The Code of Forest Practices for Timber

Production 1996

• The Code of Practice for Fire Management

on Public Land 1995

• Management guidelines as specified in

Forest Management Plans published by

the DSE relevant to the Forest

Management Areas to which this order

applies

• The Management Procedures for Timber

Harvesting and Associated activities in

State forests in Victoria 2004, DSE


EPA Victoria 12

• The Utilisation Procedures for all

Commercial Harvesting in State Forests in

Victoria, 2001

• Wood Utilisation Planning Guidelines for

State Forests in Victoria 2003’.

However, the consequence of not complying with

these documents is not outlined within the TRP. It is

worth noting that the conditions and requirements

outlined in the Wood Utilisation Planning Guidelines

for State Forests in Victoria are a part of a TRP.

3.1.3. Conservation, Forests and Lands Act 1987

The purpose of the Conservation, Forests and Lands

Act 1987 is to provide an administrative framework

for land management, including establishment of

codes of practice. The Act outlines principles of

integrated land and catchment management. The

Act also outlines the requirement for compliance

with a number of codes of practice and procedures.

In section 39, Compliance with Codes of Practices

states:

‘Compliance with a Code of Practice is not

required unless the Code of Practice is

incorporated in or adopted by—

a) a relevant law; or

b) a condition specified in an authority given

under a relevant law.’

This section is likely to be satisfied through section

46 of the Sustainable Forests (Timber) Act 2004, as

discussed below. There is a legal question as to

whether government officers are similarly bound by

these codes.

3.1.4. Sustainable Forests (Timber) Act 2004

The purpose of the Sustainable Forests (Timber) Act

2004 is to provide a framework for sustainable

forest management and sustainable timber

harvesting in State forests. The Act outlines

principles of sustainable forest management, timber

harvesting and license requirements.

The Sustainable Forests (Timber) Act 2004 outlines

what activities are authorised.

‘S45 (1) A person must not undertake timber

harvesting operations in any part of a State

Forest unless those operations are authorised

operations.

(2) For the purposes of this section, ‘authorised

operations’ means—

(a) in the case of vested timber resources—

(i) timber harvesting operations

undertaken by, or on behalf of,

VicForests in accordance with an

approved timber release plan; or

(ii) timber harvesting operations

undertaken by, or on behalf of, a

person who has entered into an

agreement with VicForests for the

harvesting and sale of timber

resources, or the harvesting or sale of

timber resources; or

(iii) timber harvesting operations

undertaken by, or on behalf of, a

person in accordance with a managed

licence;



(b) in any other case, timber harvesting

operations undertaken by, or on behalf of, a

person in accordance with—

(i) this Act; or

(ii) a licence or permit granted by the

Secretary under section 52 of the

Forests Act 1958.’

The Act also outlines compliance with Codes of

Practice.

‘S46. Compliance with Codes of Practice

The following persons must comply with any

relevant Codes of Practice relating to timber

harvesting—

(a) VicForests

(b) a person who has entered into an

agreement with VicForests for the

harvesting and sale of timber resources or

the harvesting or sale of timber resources

(c) the holder of a timber harvesting

operator's licence

(d) any other person undertaking timber

harvesting operations in a State forest.’

The general framework is summarised in the

following diagram.

3.2. Yorta Yorta Agreement

The Yorta Yorta Co-operative Management

Agreement is an agreement between Victoria and

the Yorta Yorta National Aboriginal Corporation in

relation to land and water management of Crown

land in north central Victoria. It includes the Barmah

State Park and the Barmah State Forest.

The Agreement establishes a Joint Body consisting

of five representatives from the Yorta Yorta National

Aboriginal Corporation and three members

representing the State. The Joint Body provides

advice to the Minister for the Environment on the

management of the designated Crown lands. The

Minister, in making a decision, will consider the

recommendations from the Joint Body in addition to

other authorities and parties. The ultimate decision-

making power remains with the Minister.

3.3. Specific issues

There are a number of issues relevant to the

legislative framework:

• harvesting greater than the allocated

coupe area

• harvesting outside a coupe boundary

• harvesting a Special Protection Zone

• harvesting in a threatened species habitat

• harvesting in a National Park.

3.3.1. Harvesting greater than the allocated TRP or

WUP coupe area

There are instructions in the WUP guidelines in

relation to coupe boundary changes.

The 2003/04 Guidelines state that:

Sustainable Forests (Timber)

Timber Release Plan WUP guidelines Codes of Practice

Authorises

Must comply with

Legal Compliance with Codes


EPA Victoria 14

‘Modifications to coupe boundaries which

increase the planned coupe area by less than

25% or less than 5 ha of the original planned

coupe area do not require a WUP amendment

and may be approved by a Senior Forester or his

or her delegate. In this case, the area included

should be contiguous with the planned coupe

area. For example, a Senior Forester can

approve an increase of up to 5 ha to any coupe

less than 20 ha in area, and in coupes greater

than 20 ha, the Senior Forester can approve up

to a 25% increase in area.

Modifications to coupe boundaries which

increase the planned coupe area by greater than

25% (with a minimum increase of 5 ha) of the

original planned coupe area require a WUP

amendment. If the relevant DSE/DPI businesses

give the amendment an endorsement Category

1, 2a or 2b, the Senior Forester can approve the

amendment. If the amendment receives an

endorsement Category 3 or 4, the DSE Regional

Manager must provide endorsement before the

Regional Manager, Forestry Victoria can approve

the increase in coupe area. If the amendment

receives an endorsement Category 5 from the

DSE Regional Manager, no approval can be

given.’

These have been amended in the 2005 WUP

Guidelines where modifications to coupe

boundaries defined in either a WUP or a TRP are

categorised as either minor or major. With respect to

coupe boundaries, minor changes are those which

increase the planned coupe area by less than 25 per

cent of the original planned coupe area or less than

5 ha. Minor changes require DSE Manager Level 1

approval and documentation in CIS. Major changes,

with respect to coupe boundaries, are defined as

coupe amendments or changes that result in a

greater than 25 per cent increase (with a minimum

increase of 5 ha) in the original planned coupe area.

Such changes require approval by the DSE Regional

Director and documentation in CIS.

Section 43 of the Sustainable Forests (Timber) Act

2004 allows for a change to a TRP if both VicForests

and the Secretary (DSE) agree and the changes are

consistent with the allocation order and the Code.

Part 2.3.2.14 of the Code states that coupe sizes are

to be generally less than 40 hectares.

3.3.2. Harvesting outside a coupe boundary

The Approval Notice for the 2004–09 TRP states the

following:

‘If a boundary of a coupe is identified on maps

by reference to a road, stream, ridge or other

physical feature and the location of the physical

feature on the ground differs from that shown

on the map, the location of the physical feature

on the ground is taken to be the location for the

purpose of this TRP.’

In the WUP guidelines, it is noted that Parks Victoria

staff should be involved in the development of a

WUP where coupes are located adjacent to park

boundaries. However, the planning guidelines

continue to state that a formal endorsement by

Parks Victoria staff is not required.

3.3.3. Harvesting a Special Protection Zone

Special Protection Zones (SPZs) are reserves within

State forest where logging is not permitted.

However, SPZs are not legally gazetted reserves

covered by the Crown Lands Reserves Act.



Consequently an SPZ can be revoked at any time by

the relevant Minister.

3.3.4. Harvesting in a threatened species habitat

Harvesting in a threatened species habitat may be

covered by the Flora and Fauna Guarantee Act 1988

through action statements and by the Environment

Protection and Biodiversity Conservation Act 1999

(Cwlth).

The Flora & Fauna Guarantee Act established action

statements for threatened species, including

management strategies that will be applied. In the

case of the superb parrot, there is a requirement for

100 m buffers from habitat areas.

The superb parrot at Barmah Forest is a listed

species under the Commonwealth Environment

Protection and Biodiversity Conservation Act 1999

(EPBC Act), which outlines assessment processes

that should be undertaken. However, the EPBC Act

exempts actions carried out in accordance with a

Regional Forest Agreement (RFA) or in an RFA

Region.

3.3.5. Harvesting in a National Park

Section 43 of the National Parks Act states that

trades and businesses are not to be carried out in a

park unless authorised.

S43. Trades and businesses not to be carried on

in parks unless authorised

A person shall not, in a park, carry on a trade or

business including a trade or business

authorised, permitted, or licensed under any

other Act or law unless he is carrying on the

trade or business under and in accordance with

a licence, permit, tenancy, agreement or any

other authority granted made or given under this

Act.

Section 13 of the National Parks Regulations 2003

relates to the protection of vegetation.

S13. Protection of vegetation

A person must not, in a park, cut, fell, pick,

remove, take, destroy or damage any flora or

other vegetation, whether alive or dead.

3.4. Penalty provisions

Under the Conservation, Forests and Land Act,

section 91 states that an authorised officer may

serve an infringement notice on any person, if the

authorised officer has reason to believe that the

person has committed a prescribed offence against

a relevant law. This infringement notice is for up to

10 penalty units. The Act gives DSE officers the

power to issue infringement notices; however,

infringement notices must be developed for specific

offences under other legislation (such as the Forests

Act or Sustainable Forests (Timber) Act). Penalties

are applied to Forest Operator Licence holders under

the Timber Harvesting Regulations 2000. VicForests

and DSE staff are not required to hold Forest

Operator Licences.

Any breach of the Code of Forest Practices is a

breach of the approved TRP ‘authorised operation’,

hence S 45 of the Sustainable Forests (Timber) Act

may apply. The Sustainable Forests (Timber) Act

section 45 has penalty provisions:

S45 (1). A person must not undertake timber

harvesting operations in any part of a State

Forest unless those operations are authorised

operations.


EPA Victoria 16

Penalty – 60 penalty units in the case of a

natural person

240 penalty units in the case of a body

corporate.

There are no penalty provisions associated with a

breach of section 46 of the Sustainable Forests

(Timber) Act. However, the Minister may commission

an audit (S47) with a requirement for VicForests to

respond (S48). The minister must allow for the audit

findings and response by VicForests to be publicly

available (S49 (1)) and may cause the information to

be published on the internet (S49 (2)).

Section 43 of the National Parks Act has penalty

provisions in relation to the unauthorised trade and

business in a park.

S43. Trades and businesses not to be carried on

in parks unless authorised

A person shall not, in a park, carry on a trade or

business including a trade or business

authorised, permitted, or licensed under any

other Act or law unless he is carrying on the

trade or business under and in accordance with

a licence, permit, tenancy, agreement or any

other authority granted made or given under

this Act.

Penalty: 20 penalty units.

Section 13 of the National Parks (Park) Regulations

2003 states the following:

S13. Protection of vegetation

(1) A person must not, in a park, cut, fell, pick,

remove, take, destroy or damage any flora or

other vegetation, whether alive or dead.

Penalty: 20 penalty units.



4 . F I N D I N G S – E A S T G I P P S L A N D

C O U P E S

4.1. Coupe 885-510-0024, Bambam, Cobon

block, Cann River District

4.1.1. Coupe history

Coupe 885-510-0024 is located adjacent to the

eastern boundary of the Errinundra National Park. It

is approximately rectangular in shape and had a

planned net area of 11 hectares (ha). The planned

net area of 11 ha is consistent with the coupe plan

area defined in the 2004–09 TRP.

The coupe is bisected by a northwest/southeast

trending ridge protected by a landscape buffer that

effectively separated harvested activities. To the

west of the main ridge another small ridge and

saddle form the watershed boundary between

waters flowing to the east into the Bemm River

catchment and those flowing to the west into the

Cann River catchment. In this vicinity the national

park boundary is this same catchment boundary. A

forest track, Misery Spur Track, runs along and at

times slightly to the side of the main ridge and often

coincides with the national park boundary.

DSE identified the coupe for inclusion in a WUP

endorsed in January 2003. It was carried over to the

2004–09 TRP prepared by VicForests, after the

formation of that organisation in August 2004.

The coupe reconnaissance was conducted in

September 2003 and it was harvested between 15

September 2004 and 25 November 2004. There was

no notation in the coupe reconnaissance checklist

portion of the Forest Coupe Plan of the proximity of

the national park. Forestry operations were

supervised by VicForests staff based in Cann River.

VicForests conducted post-harvesting mapping

using Global Positioning System (GPS) equipment in

February 2005. When this information was entered

into the Statewide Coupe Information System (CIS)

mapping and information database in mid-July

2005, an apparent error in the western coupe

boundary was detected. This error indicated that

logging had extended into the adjacent Errinundra

National Park. VicForests staff immediately notified

relevant VicForests management and Parks Victoria

of the incursion in mid-July 2005. DSE was notified

late July 2005.

4.1.2. Nature and extent of incident

Figure 4.1 shows the coupe map as used in the field

to mark the coupe boundary. The map indicates that

the coupe extends to Misery Spur Track along the

western boundary. The pink shading on the coupe

map shows the national park as it has been mapped

in CIS.


EPA Victoria 18

Figure 4.1: Bambam coupe map as used in the field

For this section of the Errinundra National Park the

definition of the park boundary is not clear. Figure

4.2 shows a photocopy of the certified plan that

defines the park boundary. This figure shows

Misery Spur Track to be located outside (in other

words, to the east of) the park boundary; however,

the auditor has been advised by Parks Victoria and

VicForests that the park boundary is defined by the

watershed boundary as determined in the field.

That is, the park boundary is defined by the

location on the ground of the watershed,

regardless of the location of Misery Spur Track on

a map or in the field, or by the park boundary

mapped in CIS.



Figure 4.2: Part of certified plan Errinundra National Park

Having clarified that the park boundary adjacent to

Bambam coupe is defined by the watershed

boundary, the audit team then attempted to identify

the location of this boundary in the field. The audit

team found that at times it was difficult to undertake

this task to within +/– 10 metres due to the flat

cross-slope nature of the ground and acknowledge

that this would have been even more difficult prior

to harvesting, when vegetation would have limited

visibility. Figure 4.3 shows the following boundaries:

• western coupe boundary taken from GPS

measurements by the audit team in the


EPA Victoria 20

Figure 4.3: Boundaries determined in field

• field, and which coincides with the

location of Misery Spur Track (red line)

• the boundary of the national park, as

judged by the audit team to be the

watershed boundary, which was then

measured by GPS in the field (blue line)

• boundary of the national park as shown in

CIS (pink shading).

It is clear that in this case the GIS layer contained in

CIS does not accurately locate the national park

boundary, because the boundary is defined by the

physical location of the watershed in the field.

The field measurements indicate that harvesting in

the national park has occurred over an area of

approximately 1.1 ha, represented by a strip of land

approximately 400 metres in length and having a

typical width of about 15 to 30 metres.

4.1.3. Cause(s) of Incident

The proximity of the coupe to the national park

boundary was identified in a January 2003 WUP

endorsement as well as during the required agency



cross-functional checks in December 2002. At this

time a Parks Victoria notation of ‘Park boundary

Cobon Road, no need to check’ was made. In a

subsequent cross-functional check in December

2003, for the 2003/04 – 2006/07 WUP, Parks

Victoria again noted the proximity of the park

boundary, but changed the coupe endorsement to a

Category 2b, with a requirement to ‘Notify RIC [sic:

Ranger in Charge] of harvesting and burn schedule’.

It is understood that the cross-functional check was

conducted by the Parks Victoria Cann River office.

The Ranger in Charge for the relevant section of the

Errinundra National Park is located at Orbost and

the relevant Ranger is based at Bendoc. Neither was

involved in the cross-functional check process.

Endorsement categories, related to the level of

approval for timber harvesting on nominated

coupes, comprised the following:

• Category 1 – Endorsed

• Category 2a – Provisional endorsement,

additional comments needed

• Category 2b – Endorsed subject to

comments being addressed

• Category 3 – Prescription/policy

development required

• Category 4 – Field inspection required

(reverts to Cat. 2 if no advice received

before proposed TRP submitted to

Manager VF)

• Category 5 – Harvesting not

recommended.

At the WUP/TRP stage the coupe outline was identified

on a 1:100,000 scale map, with its western boundary

being shown adjacent to, and bordering with, the

national park boundary. Due to the scale at which the

map was produced, Misery Spur Track was also shown

as coinciding with the national park boundary and

therefore forming the western coupe boundary. This

assumption appears to have been continued during

the September 2003 coupe reconnaissance with the

map prepared at that time showing the western coupe

boundary being formed by Misery Spur Track. This map

was entered into the CIS geographic information

system in December 2003.

In February 2004 the western boundary of the coupe

was amended in CIS so that it aligned with the park

boundary as shown in CIS. However, the original

coupe boundary was not deleted and the two coupe

boundaries for the same coupe continued to coexist

in CIS.

When the Forest Coupe Plan was prepared by

VicForests planning staff prior to harvest in

September 2004, the original coupe boundary in CIS

was used instead of the amended coupe boundary.

This error was compounded when, in developing the

computer-generated coupe map, the data layer

containing the original coupe boundary was placed

on top of the data layer for the national park. This

map showed the national park in a pink shade and

the coupe area as a solid purple shape overlying

and hiding the national park boundary (see Figure

4.1). As a result the coupe map in the Forest Coupe

Plan did not show that the coupe was likely to

extend into the national park. This overlay issue is

demonstrated in Figure 4.4, which shows the coupe

map with the coupe area overlay set to transparent.

This figure shows that the original coupe boundary,

as stored in CIS and defined in the TRP, overlaps

with the park boundary as stored in CIS.


EPA Victoria 22

Figure 4.4: Coupe map and national park layer in CIS

Additionally the Forest Coupe Plan did not identify

that the national park boundary is actually formed

by the physical location of the watershed boundary,

rather than by a defined line on a map.

When the coupe was marked in the field prior to

harvesting, the forest officers marked the boundary

along Misery Spur Track in accordance with the

coupe map. Harvesting by the contractor extended

to that marked boundary.

The auditor was advised that, a few days prior to

harvest commencement, the VicForests senior

planner in Cann River advised the Ranger at Bendoc

that harvesting was about to commence and invited

him to inspect the coupe. This contact satisfied the

notification request contained in the coupe’s

Category 2b endorsement as set out by Parks

Victoria. The Ranger confirmed that he was advised

of harvest commencement, but was unable to



inspect the coupe prior to harvesting due to the

short notice, as well as prior work commitments.

In summary it would appear that the primary causes

of the incident are:

• a failure to understand that the national

park boundary in the area of the coupe is

defined by the watershed boundary (refer

to recommendation 4)

• VicForests District planning, supervisory

and field staff assumed that Misery Spur

Track defined the park boundary (refer to

recommendation 10)

• in CIS, the park boundary was masked

when the coupe area was overlaid on top

of it (refer to recommendation 7)

• in-field confirmation of the park boundary

was not undertaken between Parks

Victoria and VicForests District field staff,

a requirement that should have been

included during the agency cross-

functional checks (refer to

recommendation 11).

It is the opinion of the auditor that the primary

causes noted above flag the need for better

identification of key responsibilities and

improvements in supporting systems.

4.2. Coupe 874-506-0012, Bicentennial, Cann

River District


Coupe 874-506-0012 is located on Bicentennial

Road to the east of Cann River. The coupe

reconnaissance was conducted in early April 2005. It

was harvested between 13 April 2005 and 13 May

2005 and had a planned net area of 36 ha. The

planned net area of 36 ha is consistent with the

coupe plan area defined in the 2004–09 TRP.


using GPS equipment. When this information was

entered into CIS in mid-July 2005 it was observed by

VicForests that harvesting had extended beyond the

nominated coupe boundary. VicForests staff

immediately notified relevant VicForests

management and DSE.


Figure 4.5 shows the outline of the nominated coupe

boundary and the area harvested, as measured by

the audit team during the site visit. The audited

coupe boundary coincides with the post-harvesting

measurements carried out by VicForests.

It shows the harvesting has extended outside the

coupe boundary as nominated in CIS in the

following areas:

• to the south by approximately 250 metres

• in an area outside the north-eastern coupe

boundary and up to 300 metres from the

CIS-nominated coupe boundary.

Of the total harvested area of 13.4 ha, approximately

73 per cent (9.8 ha) occurs outside the CIS-

nominated coupe boundary.


EPA Victoria 24

Figure 4.5: Bicentennial coupe map indicating planned boundary and actual harvest extent

4.2.3. Cause(s) of incident

The amended and approved coupe map contained

in the Forest Coupe Plan showed the north-eastern

coupe boundary to be partly defined by a stream

buffer and partly by the location of Bicentennial

Road, although this was not specifically noted in the

Forest Coupe Plan notes. When this portion of the

coupe was marked in the field, the boundary was

taken to the actual location of Bicentennial Road

and subsequently harvesting extended to the road.

When the post-harvesting GPS surveys were

conducted it was apparent that the actual locations

of Bicentennial Road in this area are different to

those shown on the map, as depicted in Figure 4.5.

The location of Bicentennial Road shown on the

coupe map was extracted from CIS, which contains a



GIS layer of the State road network. It would appear

that, for this area, the location of the road in this GIS

layer is not sufficiently accurate for coupe planning.

With regard to the southern portion of the coupe,

interviews with VicForests staff indicate that the

intent of harvesting was for the operation to abut an

area to the south that had previously been

harvested in 1998–99. This intent was not recorded

in the notes on the Forest Coupe Plan. The southern

boundary was represented as a line on the coupe

map, coinciding with the extent of previous

harvesting as it was shown in CIS.

When coupe marking occurred, the supervising

forest officer initially located this southern boundary

using GPS. Initial readings indicated an error with

the location, with the supervising forest officer

considering that it was due either to a malfunction

of the GPS (possibly due to forest canopy cover) or

with the mapping shape file in CIS. The supervising

forest officer was advised that the intent of the

Forest Coupe Plan was for harvesting to extend to

the boundary of the previous harvesting, which was

approximately 1 km from the boundary of

Bicentennial Road and Bismuth Mine Road. The

supervising forest officer located the previous

harvesting boundary and marked the southern

boundary of the new coupe accordingly. No further

reconciliation was conducted regarding the

discrepancy between the on-ground location of the

southern boundary and its location as shown in CIS.

In summary the primary causes of the incident are

considered to be as follows:

• an error in the location of Bicentennial

Road on the mapping layer contained in

CIS (refer to the revised coupe planning

procedure in Table 4.1, implemented since

the incident)

• VicForests District planning staff assumed

that the locations of previous harvest

boundaries in CIS were correct (refer to the

revised coupe planning procedure in Table

4.1, implemented since the incident, and

to recommendation 16)

• a failure by VicForests field and senior

staff to reconcile apparently erroneous

GPS readings or CIS map discrepancies

after initial coupe marking but prior to

harvesting (refer to recommendation 16).


causes noted above flag the need for better

identification of key responsibilities, knowledge of

staff roles and improvements in supporting systems.

4.3. Coupe 864-508-0004, Falls Track, Cann

River District


Coupe 864-508-0004 is located to the south-west of

Cann River. The coupe reconnaissance was

conducted in July 2001 and harvesting was

conducted between 9 September 2004 and 5

November 2004. The Forest Coupe Plan shows the

coupe had a planned net area of 40 ha. The auditor

notes that this is inconsistent with the 2004–09 TRP

which indicates that the coupe plan area is 35 ha.

The gross coupe area was 49.4 ha. VicForests

advised that the intent was to limit the total harvest

area to 40 ha, with harvest areas to be selected by

the supervising forest officer in the field.


EPA Victoria 26

Figure 4.6: Falls Track coupe map indicating planned boundary and actual harvest extent


using GPS equipment. When this information was

entered into CIS in mid-July 2005, it was observed

that harvesting had extended beyond the nominated

coupe boundaries and that the net harvest area was

a total of 51.2 ha. VicForests staff immediately

notified relevant VicForests management and DSE.


Figure 4.6 shows the outline of the actual harvest

area based on GPS measurements taken during the

audit site visit. The audit survey shows that the

coupe has been extended to the east by

approximately 100 metres to coincide with the

location of a pre-existing fire track. The total area

logged as recorded by the audit team is 51.5 ha.



After field marking, the new coupe boundary was not

recorded in the Forest Coupe Plan, updated in CIS or

manually recorded on any coupe maps.

The coupe file did not contain any documentation

confirming appropriate approvals had been

obtained for a coupe modification of greater than

25 per cent of the planned coupe area, or greater

than 5 ha, as required in the WUP guidelines. The

auditor did not observe any documentation

approving the change of the coupe area from the

35 ha approved in the 2004–09 TRP to the 40 ha

noted in the Forest Coupe Plan, nor an approval to

harvest in excess of the 40 ha.


The extension of the coupe boundary to the east

occurred when the coupe was initially marked in the

field. The forest officer marking the coupe judged

that the extension of the harvest area along the

eastern boundary made up for the exclusion of a

low-lying, non-productive area in the north-east

corner of the coupe. The coupe extension area

(11.2 ha) was greater than the area excluded from

harvesting on the original coupe map (9.4 ha). The

forest officer marking the coupe did not note this

discrepancy in the file or the coupe diary.

Since the Forest Coupe Plan did not record the fact

that the coupe had a gross area of 49.4 ha, the

forest officer was not aware that it was greater than

the planned net coupe area of 40 ha. The forest

officer therefore did not exclude areas from

harvesting or consider that there was any need to

seek additional approval to harvest the full coupe

extent.

The lack of documentation in the Forest Coupe Plan

relating to the planned gross area, changed coupe

boundary and WUP guideline approvals appears to

have been due to inadequate implementation of

established processes.

The discrepancy between the coupe area of 35 ha

nominated in the 2004–09 TRP and the planned net

area of 40 ha nominated in the Forest Coupe Plan

appears to have been an administrative error.

In summary it would appear that the primary causes

of the incident are as follows:

• VicForests District planners did not ensure

that the correct coupe area, as nominated

in the 2004–09 TRP, had been entered

into CIS (refer to recommendation 14).

• VicForests District planners did not

document in the Forest Coupe Plan that

the planned gross area of the coupe was

49 ha, compared to the planned net area

of 40 ha (refer to recommendation 6).

• Changes to the coupe boundary made

during field marking were not documented

by VicForests District field staff in the

Forest Coupe Plan (refer to

recommendation 12).

• Appropriate DSE approval was not

obtained for an extension to the coupe

boundary, as required in the WUP

guidelines.

• Accurate measurement of the coupe

extension area was not initiated by

VicForests District field staff (refer to

recommendation 14).

• The production of updated coupe maps

after field marking or during subsequent

harvesting was not initiated by VicForests


EPA Victoria 28

District field staff (refer to revised coupe

marking procedure in Table 4.1,

implemented since the incident).


causes above flag the need for better identification

of key responsibilities, knowledge of staff roles and


4.4. Processes and procedures at time of, and

implemented since, incidents

4.4.1. Management procedures

Revised management procedures for timber

harvesting were published in October 2005 by DSE.

Section 2.4.2 of the October management

procedures lists the processes that must be

followed for the location of coupe boundaries in the

field.

These processes can be summarised as follows:

• The field location of the mapped coupe

boundary must be agreed with relevant

land managers.

• If a coupe boundary, or part of a coupe

boundary, is formed by a physical feature,

prescriptive SPZ or buffer, then the coupe

boundary is the on-ground location of that

feature.

• If all or part of the coupe boundary is not

formed by an identified feature then the

location of the coupe boundary must be

located with a GPS.

• Where GPS readings are not possible then

other forms of measurements, such as

compass and chain, should be employed.

• The method for field location of the coupe

boundaries must be recorded in CIS.

These management procedures apply to operations

monitored or regulated by either VicForests or DSE.

4.4.2. Other processes and procedures

Other formal and informal procedures and

processes have been developed and were either

fully or partly implemented at a similar time or

subsequent to the incidents. Some of these form

part of ongoing review of VicForests standard

operating procedures. Others are specific initiatives

that have been developed in Cann River District

since the appointment of a new District Manager

and in response to the incidents.

It is understood that VicForests is in the process of

developing an environmental management system

(EMS) for implementation throughout the

organisation. In parallel with that process VicForests

is also collating all documentation on standard

operating procedures and guidelines.

Processes and procedures at the time of, and

implemented since, the incidents by VicForests, DSE

and Parks Victoria are summarised by broad coupe

management headings in Tables 4.1, 4.2 and 4.3.



Table4.1: VicForests pre and post-incident procedures – VicForests coupes

Process Processes and procedures at the time of incidents

Procedures implemented since incidents

Coupe identification Planned using 1:100,000 topographic maps. VicForests has advised that plans are in place to undertake a TRP inventory of coupe areas, initially three years in advance of the proposed harvesting date, with the aim of identifying and recording any operational issues (as distinct from cross-functional checks) well before the coupe planning process begins.

Cross-functional checks Cross-functional checks managed by the Senior Forest Officer who typically consulted inter and intra-departmental staff located in Cann River.

Formal lines of reporting have been established in VicForests to reduce confusion and to streamline the process.

Cross-functional changes in Cann River District include:

• VicForests staff to insist on a coupe inspection or review of GPS data by any entity that has made a comment as part of the cross-functional check process

• VicForests staff to consult interdepartmental staff directly responsible for the geographic area in which a coupe is located, as part of the cross-functional check process.

Coupe planning Planners typically produced the Forest Coupe Plans and associated maps using CIS. Typically planners did not undertake their own field reconnaissance.

Coupes mapped as a solid area on the coupe map generated out of CIS, overlaying and hiding other map data.

Net area only recorded in the Forest Coupe Plan.

Coupe planning changes in Cann River District include:

• coupe planning checklist and sign-off pro-forma introduced to confirm that all key coupe planning steps are undertaken

• aerial photo overlays used during coupe map preparation to assist with the identification of key management features such as roads, streams and rainforest

• key coupe planning and management activities identified by coupe and monitored using a prominent whiteboard

• coupe area shown as transparent on the CIS coupe map

• GPS data collected during coupe boundary marking verified against the coupe boundary before commencement of harvest.


EPA Victoria 30



Coupe marking Forest officers marked coupe boundaries with tape or paint using local features to orientate themselves to the coupe map.

Coupe boundaries sometimes modified in the field to fit in with logical boundaries such as existing tracks, or water features that may have not have been apparent during the TRP desktop planning phase.

Coupe boundary changes typically referred to Senior Forest Officers. Changes to coupe boundaries noted on maps or by GPS and given to planners for input into CIS. Planners then referred proposed changes to DSE for approval.

More detailed coupe marking processes are now included in Section 2.4.2 of the October 2005 Management Procedures.

In Cann River District the following processes have also been implemented:

• introduction of range finders to help assess buffer widths

• DSE unlikely to locally approve any coupes in excess of 40 ha gross area for clear fell or seed tree operations.

Coupe supervision Post-harvest boundaries mapped using GPS. The use of GPS to conduct post-harvest boundaries led to the discovery of the three VicForests incidents reviewed.

Coupe boundary changes typically referred to Senior Forest Officers.

Any breaches of Forest Coupe Plans or associated maps reported internally to the District Manager, who notified the region and any other directly related parties.

VicForests has introduced a Coupe Post- Harvest Checklist.

Coupe supervision changes in Cann River District include:

• Forest Officers and Senior Forest Officers to ensure they have access to both the Forest Coupe Plan and the coupe map for all coupes under their supervision

• key coupe management activities identified by coupe and monitored using a prominent whiteboard located in the office

• any breaches of Forest Coupe Plans or associated maps reported internally to the District Manager, who notifies the region, DSE, Parks Victoria and any other directly related parties (irrespective of the nature of the breach).

Record maintenance Forest Coupe Plans, maps and cross-functional checks stored electronically in CIS. Paper copies of plans and maps and any comments or records predating CIS stored in plastic envelopes in ring binders.

In Cann River District the following processes have been implemented:

• introduction of a record maintenance system to store paper copies in coupe-specific folders and to record contents

• GPS data stored in coupe-specific electronic folders linked to the GIS mapping system.

Competency Training typically ‘on-the-job’ with progression monitored by supervisors.

Staff competency processes that have been implemented in Cann River District include:

• introduction of a training management role, responsible for maintaining training records, identifying training needs and training opportunities

• employment of local people to help reduce staff turnover

• Senior Forest Officer responsibilities formalised through the assignment of ‘coupe manager’ roles.



The auditor supports all procedures implemented by VicForests that follow on from their review of the East

Gippsland incidents.

Table 4.2: DSE pre and post-incident procedures – VicForests coupes



Cross-functional checks DSE typically responds to pre-operational enquiries initiated by VicForests. Issues raised by DSE during the TRP approval process and proposed amendments to coupe boundaries typically initiate such enquiries.

Local procedures now require all enquiries/communication to be directed through the VicForests District Manager and the Forest Stewardship and Biodiversity Manager.

Coupe planning Amendments to TRP boundaries typically approved at the District level where changes are less than 25 per cent by area or 5 ha.

Larger amendments referred to Regional DSE staff.

In Cann River, amendments no longer approved at a local level where a request is made to extend a total TRP net area in excess of 40 ha.

Coupe marking DSE typically did not inspect coupes prior to harvest commencement.

In Cann River, DSE district staff to field inspect issues raised by DSE during the TRP approval process prior to harvest commencement.

The auditor supports the procedure implemented by DSE in Cann River to inspect key issues in the field prior to

the commencement of harvesting procedures. The auditor recommends that DSE review its coupe amendment

approvals policy in accordance with the TRP guidelines.

Table 4.3: Parks Victoria pre and post-incident procedures – VicForests coupes



Cross-functional checks Parks Victoria typically responds to pre-operational enquiries initiated by VicForests. Issues raised by Parks Victoria during the TRP approval process typically initiate such enquiries.

Parks Victoria has drafted a Specifications for coupe harvest approval document that outlines its conditions for granting consent for harvest of associated coupes. The agreement or implementation of these specifications by DSE or VicForests is not known.

Coupe marking Coupe marking typically undertaken by VicForests only several days to two weeks in advance of harvesting, giving Parks Victoria only a small window of opportunity for any inspections.

Parks Victoria has made a request that DSE and VicForests consideration implementing a 20 metre buffer zone where logging is proposed immediately adjacent to a national park, to ensure boundary protection.

The auditor recommends that Parks Victoria inspect all coupes adjacent to a national park following coupe

marking and prior to the commencement of harvesting (see recommendation 18).


EPA Victoria 32

5 . F I N D I N G S – N O R T H - E A S T C O U P E

5.1. Coupe 105-509-0006, Flanagans, Barmah

block, Nathalia District


Coupe 105-509-0006 is located in Barmah State

Forest, alongside Grinters Ridge track. The planned

net area of the coupe was 491 ha. The coupe was

harvested as a single-tree silvicultural system with

only marked trees being harvested.

DSE identified the coupe for inclusion in a WUP

endorsed in April 2001. The coupe reconnaissance

was conducted in February 2005. Initial coupe

marking and harvesting also commenced in

February 2005 and was completed in June 2005. As

is the practice with this harvesting system, the

entire coupe was not marked at this stage, just the

southern portion. Progressive coupe marking was

carried out as harvesting proceeded.

The coupe contains or is located near a number of

Special Protection Zones (SPZ). These include box

(ridge) SPZs along the southern and south-eastern

boundaries of the coupe. The coupe also contains

two superb parrot nest tree SPZs. It is understood

that the southern superb parrot SPZ is an area

nominated to provide protection to two trees that

are considered to be nesting trees. The area of the

SPZ is approximately 35 ha.

The Forest Coupe Plan contains a notation that SPZs

exist in the area and that white-bellied sea eagle is

located in the area, but has no reference to the

superb parrot nest tree SPZs. Figure 5.1 shows the

coupe map as seen in CIS and as used to mark the

coupe in the field. It clearly identifies box (ridge)

SPZs along the southern boundary of the coupe and

a Special Management Zone in the northern part of

the coupe. The map does not indicate the superb

parrot SPZ nor does CIS contain such information.

DSE staff based in Nathalia supervised forestry

operations. A Senior Forest Officer was initially the

nominated supervising forest officer for the coupe.

He went on annual and extended leave just after

initial coupe marking but prior to harvesting

commencing. A Forest Officer, newly appointed to

Nathalia, was asked to take over the supervision.

While on leave, and during harvesting, the Senior

Forest Officer remembered that the supervising

forest officer might not be aware of the unmapped

superb parrot SPZ located within the coupe and

contacted the office. At this point DSE staff

recognised that an incursion into the SPZ had

already taken place.

At about the same time a contractor engaged by the

Barmah Millewa Forum raised a concern with the

DSE biodiversity specialist about the apparent large

size of some of the logs coming from the coupe. The

DSE biodiversity specialist investigated the site and

concluded that harvested log sizes were compliant.

At the same time, however, he recalled that there

might be an SPZ within the coupe that did not

appear to be marked and excluded from logging in

the field. Using a GPS he verified that a logging

incursion into the SPZ had occurred and notified

DSE staff at Nathalia.

The auditor has viewed plans held by DSE that show

the location of the superb parrot SPZs within the

coupe and the extent of harvesting. These have not

been reproduced in this report, to ensure the

confidentiality of the SPZ locations.



Figure 5.1: Flanagans coupe map (105-509-0009) as seen in CIS


EPA Victoria 34

Figure 5.1: Approximate extent of harvesting in area of SPZ (as advised by DSE)




Figure 5.2 is an oblique aerial view of the coupe

following the suspension of harvesting activities, as

supplied to the audit team. It shows the

approximate extent of harvesting.

Advice provided by DSE also indicates that a large

portion of one of the superb parrot SPZs located

within the coupe was selectively logged. This

information also indicates that logging extended to

a track along one side of the coupe, beyond the

coupe boundary that was nominated in CIS.

The audit team was not able to confirm on the

ground the extent of harvesting activities due to

flooding of Barmah State Forest during the site visit.


The associated flora, fauna and fisheries check of

December 2000 indicated the presence of superb

parrot in the coupe and comments include ‘…refer to

SPZ…’ The coupe had an endorsement category 1,

requiring no further input.

The flora, fauna and fisheries check of December

2001 again indicated the presence of superb parrot

in the coupe and comments include ‘…refer to SPZ +

white bellied sea eagle + glossy ibis…’. The coupe

endorsement category was revised from 1 to 2,

requiring further input during coupe planning

operations.

The WUP comments as quoted above were

transferred into CIS sometime between 2001 and

2005. No additional comments were made to

indicate the presence of superb parrot.

Correspondence between the District and the Senior

Planner, Flora and Fauna, in June 2003 indicates

that the Senior Planner confirmed the existence of

superb parrot SPZ areas within the coupe and

offered to assist with marking on the ground.

DSE staff were unable to confirm whether or not the

category 2 WUP endorsement or the 2003

correspondence was followed up with a Form 4

seeking cross-functional check approvals prior to

the commencement of harvesting.

The locations of the superb parrot SPZ areas were

held on paper-based maps. They were typically

transferred by hand to coupe maps. Prior to the

introduction of CIS, these maps formed the basis for

the preparation of coupe maps. After the

introduction of CIS the locations of the superb parrot

SPZs were not transferred into CIS to minimise the

potential for the locations of these SPZs to become

widely known and thereby reduce a perceived risk of

poaching. Therefore the superb parrot SPZs did not

appear on the CIS-generated coupe map at the start

of harvesting.

The coupe reconnaissance was conducted in

February 2005. It notes the presence of flora SPZ

areas within the coupe and the potential for white-

bellied sea-eagle sites (but not superb parrot). The

coupe was then partially marked and harvesting

commenced later in February 2005. The relatively

inexperienced supervising forest officer who took

over the coupe was not aware of the existence of the

paper-based maps showing the locations of the

superb parrot SPZs. He was only provided with

information included in the Forest Coupe Plan that

contained the coupe map but did not show the

superb parrot SPZs.

In addition to the issues associated with harvesting

of the superb parrot SPZ, the auditor noted that

harvesting had extended beyond the Forest Coupe


EPA Victoria 36

Plan boundary to an unnamed track along the

western boundary. DSE has advised that the

intention of the WUP was to harvest to the unnamed

track and that the boundary on the coupe map is

considered to be in error.

In summary the primary causes of the incident are

considered to be a combination of a failure to follow

established procedures and inadequate operational

processes, including:

• Comments made with regard to the presence of

superb parrot in the flora, fauna and fisheries

check associated with the WUP review process

were not carried over to the CIS system by DSE

Planning staff (refer to recommendation 3).

• The DSE District field staff does not appear to

have followed up the category 2 WUP

endorsement nor completed a Form 4 or similar

cross-functional check indicating formal

approval to commence harvesting (refer to

recommendation 5).

• A requirement not to include the locations of

superb parrot SPZs in the CIS system and

therefore these were not included on any maps

produced by CIS (refer to recommendation 3).

• Lack of a formal process within DSE to advise

relevant personnel of the existence and location

of paper records of the superb parrot SPZs with

only the reliance on the specific knowledge of a

small number of staff (refer to recommendations

3 and 20)

• Inadequate handover of the management of the

coupe by the DSE Staff (refer to

recommendations 17 and 20).

• Lack of documentation in the WUP or Forest

Coupe Plan regarding the proper description of

the intended western coupe boundary location

(refer to recommendation 4).





5.2. Processes and procedures at time of, and

implemented since, incident

5.2.1. Management procedures

As discussed in Section 4.4.1, revised timber

harvesting management procedures have been

published in October 2005 by DSE, subsequent to

the Barmah forest coupe incident. These

procedures, listing the processes that must be

followed for the location of coupe boundaries in the

field, are applicable to DSE supervised harvesting

operations.

5.2.2. Other processes and procedures

Other formal and informal processes and

procedures have been developed and either fully or

partly implemented since the incident. Processes

and procedures at the time of, and implemented by

DSE since, the incidents are summarised by broad

coupe management headings in Table 5.1.



Table 5.1: DSE pre and post-incident procedures – DSE coupe

Process Processes and procedures at the time of incidents Procedures implemented since incidents

Coupe identification Planned using 1:100,000 topographic maps. No change.

Cross-functional checks First cross-functional check initiated through the WUP planning process, with comments sought from flora and fauna experts.

The responsibility for transferring cross-functional check comments in the WUP to CIS not formally identified or defined.

Form 4 typically used to gain approval to commence harvesting in coupes with a category 2 WUP endorsement.

No change.

Coupe planning The district manager typically produced the Forest Coupe Plans and associated maps using CIS.

The SPZ boundaries for the superb parrot were kept on hand-drawn maps not freely accessible, in order to reduce the potential risk of poaching.

No guidelines were in place to ensure all relevant information is included in the Forest Coupe Plan.

DSE advises that the locations of the superb parrot SPZs will be incorporated into CIS and shown on future coupe maps.

Coupe marking Forest officers marked coupe boundaries with tape or paint using local features and GPS waypoints to orientate themselves to the coupe map.

Knowledge of the superb parrot SPZ areas relied on the presence of senior staff with a long history in the District.

Coupe boundaries sometimes modified in the field to fit in with logical boundaries such as existing tracks, or water features that may not have been apparent during the WUP desktop planning phase.

Changes to coupe boundaries noted on maps or by GPS and given to regional staff for approval and input into CIS.

More detailed coupe marking processes are now included in Section 2.4.2 of the October 2005 Management Procedures.

Coupe supervision Post-harvest boundaries mapped by hand.

Harvest progress not mapped.

Any breaches of Forest Coupe Plans or associated maps reported internally to the District Manager, who notified the region.

No change

Record maintenance Forest Coupe Plans, maps and cross-functional checks stored electronically in CIS. Paper copies of plans and maps and any comments or records predating CIS stored by coupe in a filing cabinet.

No change.

Competency Training typically ‘on-the-job’ with progression monitored by supervisors.

CIS training implemented on an irregular basis.

No change.

The auditor supports the decision by DSE to incorporate superb parrot SPZ locations into CIS and the

development of a more detailed coupe-marking procedure.


EPA Victoria 38

6 . P R O C E S S E S I N O T H E R

J U R I S D I C T I O N S

A desktop review was undertaken of native forest

management planning and regulatory systems and

practices used in Australia, selected overseas

jurisdictions and those promoted by third-party

certification and endorsement bodies with respect

to coupe-planning and marking practices.

6.1. Tasmania

Native forest harvesting operations in Tasmania are

regulated by the Forest Practices Act 1985 (Tas.),

which is implemented in the field using the Forest

Practices Code. To implement the code, the Forest

Practices Board was created, which is responsible

for ensuring that best practice is carried out, and

enforcing the elements of the Forest Practices Code.

The Forest Practices Board maintains the Forest

Practices Unit (FPU), which is responsible for

accrediting forest officers and undertaking

enforcement, regulatory and investigatory activities.

The FPU has no commercial interests and maintains

independence from utilisation operations.

Forest planning is carried out by Forestry Tasmania,

the government body which manages utilisation

operations on public land in Tasmania. The planning

process is governed by legislation, and incorporates

public consultation and expert advice from a range

of sources. A system of management zones is used

by the FPU to define areas of specific value, and

employees of the FPU undertake any assessments

and provide advice with regards to the values.

Operationally, each coupe must have a Forest

Practices Plan (FPP) prepared and certified before

any harvesting operations can be undertaken. The

FPP is prepared by the body undertaking the

harvesting operation, such as Forestry Tasmania or

Gunns Ltd, and must be certified by a Forest

Practices Officer (FPO). FPOs are individuals who

work for the body undertaking operations, but have

been trained and accredited by the FPU. The FPO is

required to ensure that harvesting operations are

carried out as specified in the FPP, and can issue

corrective action notices. The FPU carries out

independent auditing, with around 15 per cent of all

operations assessed and reported publicly. The FPU

is legally required to investigate all complaints of

non-compliance and has the ability to issue fines or

prosecute.

Boundaries of harvest areas are determined as part

of the planning process and are then marked in the

field. There is no defined standard for boundary

accuracy in the Forest Practices Code. The

responsibility for marking area boundaries is

defined in the Forest Practices Plan. Logical

boundaries, such as ridgelines or roads, will be

used where possible and all boundaries will be

surveyed by standard handheld GPS during marking.

Where buffers define boundaries, distances to be

measured from the buffered feature are to clearly

define the boundary. Where boundaries are in

proximity to informal reserves (reserves set aside as

part of the RFA process designed to protect a range

of values, including river reserves and ecotype

reserve), the boundary will be marked in the field,

and any changes to the informal reserve must be

updated to maps. If the change in boundary is likely

to make a significant change to the informal reserve,

the FPU must be consulted and changes must be

approved before operations commence. Formal

boundaries, such as tenure boundaries or gazetted



and dedicated permanent reserves, are assessed

and marked by registered surveyors employed by

Forestry Tasmania.

6.2. Western Australia

The Forest Products Act 2000 (WA) regulates

harvesting operations on public land in Western

Australia and charges the Forest Products

Commission (FPC) as the sole entity for the

commercial production, allocation and sale of forest

products from Western Australia’s native forests and

state-owned plantations. The FPC is a government-

owned entity and is managed as an independent

body.

The Western Australian Conservation Commission,

established in 2000, is responsible for the

preparation of the Forest Management Plan. This is a

strategic document detailing management

directions and priorities on public forested lands

over a period of 10 years. The Conservation

Commission oversees and audits the Department of

Conservation and Land Management (CALM) and the

FPC with respect to the directives set out in the

Forest Management Plan.

CALM develops a three-year timber harvest plan,

and from this FPC develops an indicative annual

harvest plan through processes that involve external

consultation. The annual plans detail coupes for

harvest and flag any significant site-specific flora,

fauna, water quality and cultural values. The annual

plan must be approved by CALM before harvesting

operations can commence. FPC also commissions

CALM to provide advice on site-specific

management prescriptions for any areas of

significant value identified in the annual plan. CALM

typically reviews all issues highlighted by the FPC,

but will not necessarily visit all sites unless

permanent disturbance, such as roading, is planned

to occur.

Representatives of the FPC mark areas for harvest in

the field, and harvesting activities are undertaken in

accordance with a code of practice and CALM

directives. There is no defined system for marking

coupe boundaries in the field but, where possible,

natural feature boundaries are used. Where

boundaries are not aligned with landscape features,

they will generally be determined by handheld GPS

or by field survey from a known point. Priority is

given to ensuring accurate demarcation and

protection of natural features such as streamside

reserves or habitat areas. In areas where harvest

operations are in proximity to formal reserves or

land tenure boundaries, registered surveyors mark

boundaries in the field.

The FPC manages harvesting operations. Operations

are audited by CALM, including feature demarcation

and harvest practices. The Conservation

Commission audits both CALM and FPC operations.

6.3. New South Wales

Native forest harvesting operations in New South

Wales are regulated by the Forestry and National

Parks Estate Act 1998 (NSW) and are managed under

the principles defined in Regional Forest

Agreements. Forest management plans and the

Forest Practices Code for Timber Harvesting (1998)

govern operational activities. Harvesting operations

in state forests are regulated and coordinated by

Forests NSW, a subsection of the Department of

Primary Industries. The Department of Environment

and Conservation is responsible for auditing Forests

NSW operations through its Environment Protection


EPA Victoria 40

Authority (EPA) and National Parks and Wildlife

divisions.

Forests NSW manages utilisation planning and

environmental assessment for all areas of State

forests harvested. The Department of Environment

and Conservation has no direct input into coupe

scheduling and acts purely in a regulatory and

compliance capacity. Conflicting objectives in

Forests NSW forest planning are managed using a

detailed series of prescriptions (defined by an

interdepartmental licensing system) that specify

procedural and operational requirements when

special conditions are recognised.

The coupe planning process involves a series of

indicators that trigger management prescriptions

and includes a detailed desktop investigation into a

range of databases including flora and fauna,

supported by field surveys. Forests NSW employs a

range of specialists, including ecologists and soil

scientists, and has an internal consultation process

to adjust harvesting practices to environmental best

practice. Forest operations are authorised and

supervised by Supervising Forest Officers (Senior

Forest Officers) employed by Forests NSW.

Harvest boundaries are determined as part of the

planning process. There are standard systems for

boundary delineation but there is no standard

system for locating boundaries in the field. Where

possible, existing features, such as streams, roads

and ridges are used. Priority is given to marking

features as determined in the field, except where

boundaries are adjacent to formal reserves or

mapped values requiring protection, such as

rainforest. Specialised teams employed by Forests

NSW, utilising high-accuracy equipment such as

differential GPS, survey formal boundaries. These

teams are not necessarily registered land surveyors.

Forests NSW has an internal auditing system to

ensure it adheres to legislated practices.

6.4. California

Timber harvesting in California is overseen by the

Californian Department of Forestry, which regulates

forest operations on private land on behalf of other

state departments. The Department of Forestry is

responsible for the review of site-specific Timber

Harvesting Plans (THP) and managing stakeholder

consultation with other bodies including the

Department of Conservation, the Department of Fish

and Game and regional water quality control boards.

The THP is an environmental review document that

details the precise area to be harvested, techniques

of harvest and how any special values will be

protected during operations. A THP certified by the

Department of Forestry is required before any

operations can commence, regardless of size, and

can only be prepared by a professional forester

registered with the department. All THPs are

reviewed by the Department of Forestry and a

proportion is audited by number of other

stakeholders. It is the responsibility of the forester

preparing a THP to correctly document all plans and

issues and the landholder is required to fulfil all

requirements.

The Department of Forestry undertakes site visits of

all sites before and after harvesting and also

undertakes more intensive reviews where special

values are recognised. The Department can fine

foresters, operators and landholders where a THP is



incorrectly prepared or where there is a lack of

adherence to the THP.

6.5. British Columbia

The Forest Act (1996) and the Forest and Range

Practices Act (2005) govern native forest harvest

operations in British Columbia. Operations are

regulated by a legislated code of practice, the Forest

Practices Code of BC Act (2005). A new entity, the

Forest Practices Board, was recently created to

independently regulate and audit forest practices on

public lands and ensure compliance with the Forest

and Range Practices Act.

Forest management planning in British Columbia is

undertaken by the Ministry of Forests, which sets

guiding principles and develops forest management

plans in consultation with stakeholders. Experts

providing planning services, including biologists,

foresters and engineers, require licensing in their

field of expertise. Foresters who have completed

specified training modules undertake forest

planning. Management plans must comply with the

silvicultural strategy documents developed for each

management region in British Columbia that contain

regional and provincial prescriptions. Forest

planning practices are guided by the Forest Planning

and Practices regulation, 2004.

Harvesting operations require a forest stewardship

plan or woodlot licence plan prepared by the

responsible harvesting entity and must obtain

approval from the Ministry of Forests before

operations can commence. The responsible

harvesting entity is required to ensure that the

operations defined in the plan are carried out as

specified. The Forest Practices Code specifies that

boundaries be marked in the field before

submission of a plan to the Ministry for approval

and should be mapped to minimum standards

(+/– 1 per cent for scale-based tenures, +/– 0.7 per

cent for cruise-based tenures and +/– 5 m for GPS

mapped areas).

Professionals within the Ministry carry out

enforcement of forestry laws. The Forest and Range

Practices Act and the Forest Practices Code of BC are

both legally enforceable and incorporate a range of

penalties. The Ministry undertakes a risk-based

auditing system, with priority given to areas

recognised to have a high likelihood of non-

compliance, and potentially severe consequences.

In addition to Ministry of Forestry Audits, the Forest

Practices Board undertakes audits and

investigations as an independent body, with all

results publicly available.

6.6. Indonesia

In Indonesia all Forest Management Unit (FMU)

boundaries (also known as concession areas) must

be gazetted and harvesting entities must have a

licence approved by the Ministry of Forestry to

operate within an FMU. Harvesting entities must also

have an approved environmental impact

assessment covering the FMU that addresses

potential social and environmental impacts and

associated management prescriptions. All staff and

contractors must have a licence to operate in the

forest.

Harvesting entities must develop a long-term (20-

year), medium-term (five-year) and an annual

harvest plan that map out the compartments to be

harvested. The harvesting entity must attach a

report that identifies every tree to be felled by a

unique number, its species, diameter and


EPA Victoria 42

merchantable height to the annual harvest plan. To

undertake this task every merchantable and habitat

tree is marked in the field and their location mapped

on 1:10,000 scale maps. All compartment

boundaries must be clearly marked in the field and

the FMU boundary must be surveyed, marked and

cleared to a width of 10 m.

Once harvesting commences, the harvesting entity

must file a monthly log return form indicating which

trees have been harvested. Every log leaving the

forest must be accompanied by a delivery docket,

from the time it reaches the landing to the time it

reaches a processing centre.

Staff from the Ministry of Forestry may audit

operations at any time. Operators who infringe their

licence conditions can have their licence suspended

or revoked.

6.7. Forest practice certification and

endorsement schemes

6.7.1. ISO 14001

ISO 14001 is an international standard governing the

development of Environmental Management

Systems (EMS) for managing the environmental

performance of a business. It is a voluntary standard

established by the International Organisation for

Standardisation that focuses on monitoring of

environmental performance and a process of

continual improvement.

The requirements are systems-based and involve

the development and monitoring of self-defined

objectives and targets. Any industry can achieve

ISO 14001 certification, provided that it has a

management system in compliance with the

standards and submits regular audit results

undertaken by accredited JAS-ANZ auditors.

The FPC in Western Australia and Forestry Tasmania

are currently accredited under ISO 14001 and Forest

NSW has management systems based on

compliance with the standard.

6.7.2. Forest Stewardship Council certification

Forest Stewardship Council (FSC) certification is a

non-governmental certification system aimed ‘to

promote environmentally appropriate, socially

beneficial and economically viable management of

the world's forests’. FSC certification involves

accreditation of forest management and includes

forest product certification. Product certification

requires detailed chain-of-custody monitoring to

ensure products come from accredited forests. FSC

certification requires compliance with a series of

principles and criteria developed to indicate

environmentally, socially and economically

sustainable management.

A key component of FSC certification is the

development of an adaptive management system,

which includes the creation of a formal management

plan, an emphasis on staff training and supervision

and a system for continual improvement of

practices.

FSC certification is carried out by private

accreditation bodies that are required to maintain

full independence from the organisation being

certified. Certificates are monitored through regular

audits.

6.7.3. Australian Forestry Standard

The Australian Forestry Standard (AFS) is a recently

developed Australian standard (AS 4708) that has



been intended to promote sustainable forest

management and is designed to comply with other

international standards. AFS certificates are issued

by AFS Ltd, which maintains the Standard

certification register.

The Standard was developed to fulfil the principles

of sustainable forest management specified in the

internationally agreed Montreal Criteria and requires

the forest manager to monitor and manage to a

number of criteria and associated indicators. The

AFS places the onus on the forest manager to

provide evidence that a forest is being managed to

best practice. The standard covers a broad range of

issues and has emphasis on the development of

management plans and the maintenance of

monitoring and external consultation to ensure that

best practice is being achieved. Emphasis is given

to systems under criterion 1, which states that forest

management shall be undertaken in a systematic

manner that addresses the range of forest values.

Auditors accredited under JAS-ANZ, a not-for-profit

auditor standards body, review compliance against

AFS and register the results with AFS Ltd.

The AFS standard covers both plantation and native

forest operations.

6.7.4. Food and Agriculture Organisation Model

Code of Harvesting Practice

The Food and Agriculture Organisation (FAO) has

developed a Model Code of Harvesting Practice

(1997) based on harvesting codes in place in a range

of countries. It is designed to highlight

environmentally sound harvesting practices. The

code has been developed as a tool for forest

managers to develop locally specific codes. The FAO

code has a high level of detail, placing emphasis on

maintaining planning and management systems and

ensuring that techniques and levels of training are

appropriate for conditions.

6.8. Summary of common themes

There are a number of common native forest

harvesting and management themes across the

jurisdictions. These include:

• the use of independent bodies to regulate and

audit harvesting operations

• the use of licensing systems to regulate

competencies

• the implementation of environmental

management systems that provide operational

frameworks and identify key levels of authority

and associated responsibilities

• provisions for penalties once a legal or regulatory

breach has been proven

• recognition that physical features such as roads

and water features, where possible, ultimately

delineate harvest areas and not a direct

translation of a line on a map to a line in the field

• the use of GPS survey techniques to identify

harvest and protection areas.


EPA Victoria 44

7 . C O N C L U S I O N S

The field inspections and data review of this Audit

have confirmed that incursions have occurred at

each of the four coupes in the following forms:

• A small section of the Errinundra National Park

has been harvested at coupe 885-510-0024

(Bambam).

• Harvesting has extended beyond the nominated

coupe boundaries at coupes 874-506-0012

(Bicentennial), 864-508-0004 (Falls Track) and

105-509-0006 (Flanagans) without appropriate

authority.

• A substantial portion of a superb parrot SPZ has

been selectively logged at coupe 105-509-0006

(Flanagans).

In summary the causes of the incidents can be

grouped as follows:

• assumption by VicForests and DSE staff that

features depicted and information contained in

the Coupe Information System (CIS) are accurate

and complete (all coupes)

• inadequacies in the Forest Coupe Plan

documentation regarding:

• definition of boundaries for protected areas

(Bambam and Flanagans)

• physical features defining coupe boundaries

(all coupes)

• gross and net coupe area (Falls Track)

• insufficient ground confirmation of boundaries

(Bambam, Bicentenial and Flanagans)

• failure to document and obtain approval for

coupe boundary modifications (Falls Track and

Flanagans)

• assumption by VicForests and DSE staff that

nominated coupe boundaries can be changed

without further cross-functional review (Falls

Track and Flanagans)

• breakdown in the system for agency cross-

functional harvesting review, resulting in relevant

information not being considered in coupe

marking (Bambam and Flanagans).





The need for identification of varying levels of

competency and accountability has been

highlighted in this report. This could be addressed

through the development or improvement of

departmental human resource plans (refer to

recommendation 20).

Several causes identified in this report that led to

the incidents reviewed by the auditor relate directly

or partly to a lack of support systems and poor

definition of key accountabilities and

responsibilities. Through the review of other

jurisdictions, it is apparent that environmental

management systems are widely used to support

regulatory and operational functions associated

with native forest harvesting. DSE and VicForests are

likely to benefit from the formal or informal adoption

of an environmental management system (refer to

recommendation 1).



8 . R E C O M M E N D A T I O N S

The previous sections of this report describe a

number of changes to practices and procedures that

have been implemented by both VicForests and DSE

since the incidents. For example, the October 2005

Statewide management procedures contain an

appropriate process for field marking. The Cann

River District office of VicForests has also

implemented a substantial number of procedural

changes to the oversight of coupe management and

documentation control, many of which should be

considered for adoption in other forestry offices.

Whilst these have been beneficial,

recommendations for further changes are listed

below to reduce the risk of similar incidents

occurring in the future and ensure good practice. In

some cases these build on those processes already

in place or directives already proposed.

In making recommendations the following four key

levels of responsibility have been identified:

• management systems

• coupe planning

• field operations

• staff training.

All recommendations are applicable to operations

supervised by either DSE or VicForests. Some

recommendations are applicable to other

departments. Where this is the case this is noted.

The auditor has attempted to ensure that the

recommendations are in addition to new processes

and procedures already implemented since the

incidents.

Management systems

1. Implement as soon as possible the proposed

environmental management systems in DSE

and VicForests that will address critical

functions, aspects/impacts, document control

and review/monitoring procedures.

2. Management systems should include

procedures to ensure that staff are made aware

of data relevant to the coupe that are not

included or accessible in CIS.

Coupe planning

3. Identify responsibility for, and include where

appropriate, all relevant spatial and notational

data into CIS that may influence forest

management activities that are normally

considered during TRP or WUP reconnaissance

activities, such as superb parrot SPZs, carpet

python SPZs and indigenous sites.

4. Accurately define, describe and document the

coupe boundary in the Forest Coupe Plan. This

should include a notation in the Forest Coupe

Plan that formally defines the coupe boundary,

such as a physical feature, a line on a map that

can be confirmed by GPS readings or other

aspects to be defined in the field (such as a

watershed). Develop formal points in both the

WUP and TRP processes where these

boundaries are described.

5. Develop and implement a coupe planning

checklist, similar to a checklist already

implemented by VicForests in Cann River, which

describes critical coupe planning steps and

that also includes formal sign-off by senior staff


EPA Victoria 46

that confirms appropriate coupe marking has

been carried out.

6. Include a notation of both the gross and net

coupe areas (where applicable) in the Forest

Coupe Plan and on coupe maps.

7. Corporate services supporting District Planning

staff should formalise a hierarchy for GIS

mapping layers used to develop the coupe

map, with coupes to be shown as a transparent

area such that no layers accidentally hide other

information.

8. Include on coupe maps the date of production,

or other unique identifier, and maintain a

revision list in the coupe file or other central

register. Mark as ‘Old’ revised coupe maps and

retain on file.

9. Include in the WUP guidelines the roles and

accountabilities of external stakeholders, such

as Aboriginal Affairs Victoria and Parks Victoria,

for coupe endorsement in the TRP process, in a

similar manner to that described for WUP

endorsement.

10. Clarify, either in the WUP guidelines or another

document, the process that VicForests, DSE and

Parks Victoria must follow to formally define a

national park boundary, or other sensitive land

management boundary, in relation to

endorsement of proposed adjacent or nearby

coupe boundaries.

11. Formalise a minimum notification period that

gives responsible staff sufficient time to

undertake pre-operational cross-functional

checks.

Field operations

12. Extend the use of the existing paper-based

coupe diary system to record all coupe-related

activities from the time of coupe marking to

final regeneration survey.

13. Forest officers should note in the coupe diary if

the coupe was marked as planned or if

boundary modifications were made.

14. Section 2.4.2 of the Management Procedures

should be amended so that it is explicit that

they also apply to coupe boundary

modifications.

15. Ensure that coupe boundary modifications are

entered into CIS.

16. Where a the location indicated by a GPS does

not appear to match the expected location, the

operator should take several waypoints and

confirm the location in the office using the GIS

system, aerial photo overlays or other checking

methods before undertaking any coupe

boundary marking.

17. Record and update in the coupe diary who is

responsible for the regulation or monitoring of a

coupe.

18. VicForests or DSE to notify Parks Victoria of

impending harvesting operations next to a

National Park and Parks Victoria to inspect

associated coupe boundaries following coupe

marking and prior to the commencement of

harvesting.

19. Formalise a procedure that describes the level

of notification and required actions in the event

that the managing authority identifies a breach

of the coupe plan boundary.



Staff training

20. Develop a human resources plan, including:

• a process that can adequately identify and

respond to district staff resourcing issues

• identification of staff competency

requirements and responsibility levels

through formalisation of training records

and recognition of training needs,

particularly in the areas of coupe planning,

use of CIS and application of GPS units.


EPA Victoria 48

9 . B I B L I O G R A P H Y

Code of Forest Practices for Timber Production,

Revision No. 2. Department of Natural Resources

and Environment, November 1996.

Forest Management Plan for East Gippsland,

Department of Natural Resources and

Environment, December 1995.

Forest Management Plan – Gippsland, Department

of Sustainability and Environment, June 2004.

Forest Management Plan for the Mid-Murray Forest

Management Area, Department of Natural

Resources and Environment, 2002.

Management Prescriptions for Timber Production

and Other Forest Uses, Gippsland Region,

Department of Natural Resources and

Environment, October 1998.

Management Procedures for Timber Harvesting and

Associated Activities in State Forests in Victoria,

Department of Sustainability and Environment,

July 2004.

Management Procedures for Timber Harvesting and

Associated Activities in State Forests in Victoria,

Department of Sustainability and Environment,

October 2005.

Native Forest Silviculture Guideline No. 6, Site

Preparation, Department of Natural Resources

and Environment, November 1998.

Timber Release Plan 2004–2009, 01 August 2004 –

Approval Notice, Department of Sustainability

and Environment.

Timber Release Plan 2004–2009, 01 August 2004 –

List of Coupes, Department of Sustainability and

Environment.

Utilisation Procedures for all commercial harvesting

in State forests in Victoria, Department of Natural

Resources and Environment, August 2001.

Co-operative Management Agreement between Yorta

Yorta Aboriginal Corporation and the State of

Victoria.

Yorta Yorta Co-operative Management Agreement

Fact Sheet, Department of Sustainability and

Environment and Department of Justice, May

2004.

Wood Utilisation Planning Guidelines incorporating

Timber Release Plan endorsement and approvals

process, Department of Sustainability and

Environment, August 2005.

Wood Utilisation Planning Guidelines for State

Forests in Victoria, Department of Sustainability

and Environment, November 2003

2005 special forest audit - environment protection …/media/publications/1030.pdf · part ixd of...

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