Loss of hollow-bearing trees in native forests and woodlands due to ecologically unsustainable forestry practices
Advice to the Minister for the Environment and Heritage from the Threatened Species Scientific Committee on a public nomination of a Key Threatening Process Environment Protection and Biodiversity Conservation Act 1999
1. Name and description of the key threatening process
The nomination for listing 'Loss of hollow-bearing trees in native forests and woodlands due to ecologically unsustainable forestry practices' as a Key Threatening Process was originally submitted under the Endangered Species Protection Act 1992 (ESP Act).
The previous committee (the Endangered Species Scientific Sub-committee, ESSS) decided that an agreed definition of 'ecologically sustainable' was not required to reach a conclusion on the nominations. ESSS therefore amended the name of the threatening process to: 'Continuing net loss of hollow-bearing trees in native forests and woodlands due to forestry practices'
The nomination describes the loss of hollow-bearing trees as having two components: activities which remove or destroy hollow-bearing trees, and processes which affect younger trees and seedling recruitment, preventing or reducing the replacement of hollows lost through natural attrition.
Practices which lead to the loss of hollow-bearing trees are:
- Logging and associated operations which can remove and damage trees with hollows and leave insufficient younger trees to replace losses due to natural mortality and thus ensure a continuing supply of hollows;
- Firewood harvesting which can remove and damage trees with hollows and leave insufficient younger trees to replace losses due to natural mortality and thus ensure a continuing supply of hollows;
- Native vegetation clearance and cropping operations which remove trees with hollows; and
- Prevention of recruitment of hollow-bearing trees. Mature and over-mature trees in remnant fringes, patches and paddocks will generally not be replaced when they fall, where saplings and understorey vegetation are cut, burnt for fire protection or grazed.
Only the practices set out in point 1 fall within the scope of this nomination.
Net loss of hollow-bearing trees was defined (by ESSS) as 'a process where numbers of hollow-bearing trees decline faster than new hollow-bearing trees are formed and where this net loss is likely to continue to such an extent that few hollow-bearing trees remain in the landscape under consideration, threatening local survival of hollow-dependant species'.
3. How judged by TSSC in relation to the Environment Protection and Biodiversity Conservation Act 1999 criteria
- Could the threatening process cause a native species or an ecological community to become eligible for listing as Extinct, Extinct in the Wild, Critically Endangered, Endangered or Vulnerable?
- Could the threatening process cause a native species or an ecological community to become eligible to be listed in another category representing a higher degree of endangerment?
- Does the threatening process adversely affect 2 or more listed threatened species (other than conservation dependent species) or 2 or more listed threatened ecological communities?
In its original assessment, the nominated process was found (by ESSS):
- not to meet the ESP Act criterion for 'adversely affecting two or more listed species'. ESSS believed the process 'is affecting Leadbeater's Possum (although efforts are being made to mitigate this loss via an approved Recovery Plan) but is not affecting the Swift Parrot (Lathamus discolor)'; and
- to meet ESP Act the criterion 'that it could cause native species that are not endangered to become endangered'. ESSS believed the process 'is affecting species not listed…Whether it is adversely affecting such species is less clear. Lack of detailed information on the long-term effects of forestry practises makes it difficult to make conclusions about whether particular species are threatened by the nominated process or not…there is always a risk that some species may become endangered because forest managers do not have the necessary data to modify management practises.'
ESSS also found that 'a nationally co-ordinated threat abatement plan is not a feasible, effective and efficient way to abate this process in places where a RFA is being developed, so long as RFAs take sufficient account of the possible deleterious effects of loss of tree hollows on fauna. However, in areas where no RFA is being prepared the process is not being sufficiently abated at present and the preparation and implementation of a nationally coordinated threat abatement plan is a feasible, effective and efficient way to abate the process'. ESSS therefore recommended that a threat abatement plan should be developed only for those parts of Australia not covered by a RFA by 2000.
Subsequent to this advice the process could not legally be added to the list of key threatening processes under the ESP Act, since it occurs both in and outside Commonwealth areas. This restriction is no longer applicable under the EPBC Act.
Updated information, and changes in forest management policies and regulations over the last three years (since ESSS advice was prepared) include:
- Of the nine species included in the nomination which 'could become endangered or vulnerable because of the threatening process', only one has since been listed as 'Vulnerable', Baudin's Black-Cockatoo Calyptorhynchus baudinii. For this species the national Action Plan for Australian Birds reports 'nest sites could have become limiting had past management continued', and the recommended actions relate only to monitoring populations and non-lethal mitigation of cockatoo damage to orchards (Garnett and Crowley 2000).
- Lack of nesting hollows due to forestry practises is not listed in the Bird Action Plan as a threat to Red-tailed Black-Cockatoo, Powerful Owl, Sooty Owl or Rufous Owl (Garnett and Crowley 2000).
- Although ESSS concluded the process was affecting the listed species Leadbeaters possum Gymnobelideus leadbeateri, they noted efforts to mitigate this threat via an approved recovery plan. This recovery plan has now been in place for over three years. In addition, the complete range of the Leadbeater's possum is now covered by the Central Highlands RFA.
- RFAs now exist for a large proportion of Australia's forests: 90% of Victoria, all of Tasmania, south west Western Australia, and most of the eastern seaboard production forests of New South Wales. Both the process and the species mentioned in the nomination (apart from the Rufous Owl) occur both within and outside areas covered by RFAs. ESSS concluded a threat abatement plan was not required for RFA areas, provided RFAs take into account the effects of the loss of tree hollows.
- RFAs provide for Comprehensive, Adequate and Representative reserve systems, designed to protect at least 15% of the pre-1750 extent of each forest ecosystem, and at least 60% of each forest ecosystem’s old growth element, effectively protecting a representative area of habitat for the full range of forest biodiversity in RFA regions. In addition, for areas still available for forestry operations, RFAs accredit State forestry management prescriptions, which include specific provisions for recovery plans and threatened species management, and more general provisions for habitat management, such as buffers and habitat trees.
- For non-RFA regions, a range of State forestry management prescriptions, nature conservation and threatened species legislation, vegetation clearance controls and voluntary measures apply. State Forestry management prescriptions apply to all land managed by State agencies. Nature conservation legislation eg. Victorian Flora and Fauna Guarantee Act 1988, NSW Threatened Species Conservation Act 1995, apply to state managed and private land, and contain provisions for State listed species, such as yellow-bellied glider and squirrel glider.
Conclusion - The TSSC believe that any threat posed by this process, both within and outside RFA areas, is currently being mitigated to the extent that the process:
- is not likely to cause a native species or an ecological community to become eligible for listing in any category, other than conservation dependant;
- is not likely to cause a listed threatened species or a listed threatened ecological community to become eligible to be listed in another category representing a higher degree of endangerment; and
- does not adversely affect 2 or more listed threatened species (other than conservation dependant) or 2 or more listed threatened ecological communities.
The threatening process does not meets s188(4)(a), s188(4)(b) or s188(4)(c) of the EPBC Act.
TSSC recommend that Continuing net loss of hollow-bearing trees in native forests and woodlands due to forestry practices is not eligible for listing as a Key Threatening Process under the EPBC Act.