submissions NEEDED NOW FOR best operating standards for NEW SOUTH WALES  Private Native Forestry


The NSW Department of Land and Water Conservation is currently seeking comments on their draft Guidelines for Logging Private Land.Please get your submissions in  as soon as you can. The deadline has been extended to the 10th of March.

Susie Russell of NEFA ( has studied  the relevant documents and reports that the proposed new guidelines will make it easier to carry out  destructive activities. There has been no consultation for the preparation of these "guidelines" with either conservationists or the agencies that have environmental regulatory functions.

Documents should be available in DLWC offices. Please let us know if you ask for a copy and can't get one. Having searched in vain at the Department of Land and Water Conservation's website under "Private Native Forestry", the Rainforest Information Centre has relied on the always reliable Susie Russell's reading of this elusive document for our submission. We urge you to either get hold of the documents or do the same.

Susie writes: "It seems that the Department of Land and Water Conservation (DLWC) is supporting the logging industries drive for unfettered access to private lands (as the public land wood supply is fast running out).

The Government's intent is that these proposals will become the benchmark for private land logging operations across the whole of NSW. No doubt they are designed to guarantee wood supplies for wood-fired power stations and charcoal burners and ongoing woodchipping"


Submissions should  be sent to

Leanne Wallace, DLWC,
NSW 2001,
fax 02 9228 6427
or email

Letters also need to be sent to Richard Amery, Minister for Land and Water

Bob Debus, Environment Minister,

and  the premier Bob Carr,

Here is a copy of the RIC's submission:



Here is the Rainforest Information Centre's response to your draft.
The proposed guidelines are wishy-washy and  encourage  highly destructive logging to occur in contravention of  the requirements  of ecologically sustainable forest  management  and the urgent need to provide protection for species threatened with extinction.   The guidelines are called best operating  standards and  yet represent the worst operating standards in operation  in NSW.

The  guidelines  have not been properly exhibited.  Requests  for copies  at   regional offices have been met with blank  looks,  as  of March 6, 2001 there is no copy on the DLWC website. The  draft has been poorly circulated.
The document has been prepared on a State Forest computer.  There is a conflict of interest between an agency  responsible  for logging being given responsibility for drafting  "guidelines" to regulate logging.

The "guidelines" are inconsistent with the objects of the  native Vegetation  Conservation  Act,  the  Environmental  Planning  and Assessment Act, and the Threatened Species Conservation Act.
There is a knowing imposition of significant impact.


There is no minimum canopy retention.
There are no minimum tree size retention requirements.
There  is  no restriction on clearfelling.  The  minimalist  tree retention ie up to 5 trees/ ha on average, allows for  configurations  that  enable broadscale clearfelling 
No  requirement to provide information on how much of the proper ty  has already been cleared, the age class and size of  the  remaining  forest  and a management plan that even bothers  to  pay lip-service to sustainability.

There is  no  intended  (or implied) exclusion of logging  from  rainforest  , oldgrowth forest, wilderness, or  rare,  endangered
and inadequately  reserved ecosystems.
Previous  DLWC guidelines had better protection  for  rainforest, oldgrowth  forest,  wetlands,  heath and  rocky  outcrops.  These guidelines  are retrograde and provide less protection at a  time when the community expects there to be stronger protection.
Forest  ecosystems  which  are poorly reserved  on  public  land, (measured  against the minimum criteria set up  the  Commonwealth Government) receive no protection and no process for  determining which areas on private land are of conservation significance.
Areas of extreme erosion hazard are allowed to be logged.
Logging on land over 30 degrees can be logged if a cable  logging technique is used. Expert opinion of soil scientists has been  to limit ALL logging on land over 25 degrees.
There  is no recognition of the need for broad regional  wildlife corridors  to  enable movement of species between  major  habitat areas.
The  requirements for local wildlife corridors have been  reduced to the point of being pure tokenism.
There is a significant reduction in the widths of unlogged buffers along streams.
The filter strips on streams and watercourses are less than those required by the EPA and NPWS on public land.
Filterstrip  widths fail to take into account the extent of  erosion hazard potential.
in western forests and woodlands, already severely degraded, are afforded only a five metre buffer or filter strip. This is tantamount  to  criminal negligence.
Only  2 habitat trees /hectare have to be retained in  River  Red Gum  forests  (except within 50m of a river),  this  compares  to requirements  to retain 5 habitat trees/ha in coastal and  table land areas.
There  is  no requirement at all to leave habitat trees  in  some Cypress  Pine  logging  operations which could see  all  the  old
ironbarks removed.
No   requirement that retained trees (whether as habitat or  feed trees) must be from the largest size classes, and skinny  sapling will do.
No   requirement to retain stags (standing dead trees) which  are important habitat.
No  requirement for retention of nectar feed trees for River  Red Gum and Cypress Pine forests.
No  requirement for pre-logging surveys for threatened species of plants and animals by accredited experts.
No   exclusion buffers around the nests or roosts of any  threatened species.
No   conditions to protect specific threatened species  that  may occur  on the property or in the unlikely event any are  detected and recorded.
No   identification required of high use koala areas, and  there fore no requirements to maintain buffers around such areas or  to retain  minimum  numbers of koala feed trees in  other  areas  of koala habitat.

for the Earth

John Seed, Ruth Rosenhek, Binnie O'Dwyer, Tessalie Parker, Phil Murray, Anja Light,

Rainforest Information Centre
Box 368 Lismore 2480
61 (0)2 66213294