A mature or late mature tree as a recruitment tree to replace each retained hollow bearing trees when they die,

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1 Protecting Habitat Trees NEFA BACKGROUND PAPER Protecting Habitat Trees Prepared by: Dailan Pugh, 2014 Large old trees provide essential resources for numerous animals that are not provided sufficiently by young trees (see The Importance of Old trees). This is reflected in the Threatened Species Licence (TSL 1999) for north-east NSW which includes a variety of prescriptions aimed at retaining minimum numbers of mature and old trees, specifically requiring the retention of: 10 large old hollow-bearing trees (where extant) per 2 hectares for hollow-dependant fauna, A mature or late mature tree as a recruitment tree to replace each retained hollow bearing trees when they die, 6 mature and late mature eucalypt feed trees for nectivorous species in every two hectares of the net logging area where they occur (increased to ten eucalypt feed trees near records of the most vulnerable nectivores); 15 mature and late mature feed trees within 100 metres of a Yellow-bellied Glider sap feed tree, observation or den site record, or within 200m of a call detection record;

2 Yellow-bellied and Squirrel Glider sap feed trees; roosts, dens and nests of various bats, owls and gliders (if found); all hollow-bearing trees and stags within 100m of Pale-headed Snake; and, ten stags (dead trees) per 2 ha where they occur and are not considered dangerous. All retained trees are meant to be marked for retention, be relatively healthy and be protected during logging operations, including, not allowing debris to accumulate around their bases. In the coastal forests only the remaining numbers of hollow-bearing trees need to be retained (where <10 per 2ha), whereas in the escarpment forests the largest available trees need to be retained where there are insufficient hollow-bearing trees left to meet the 10 per 2ha requirement. Trees retained as hollow-bearing trees and recruits can also satisfy the requirements for retention of mature and late mature feed trees if they are the appropriate species. NEFA s experience is that roosts, dens and nests of various bats, owls and gliders are rarely searched for or found, and that eucalypt feed trees, Yellow-bellied Glider feed trees and Yellow-bellied Glider and Squirrel Glider sap-feed trees are rarely identified or protected (i.e. see Doing Surveys). In practice the only habitat tree retention prescriptions that are at least applied in a cursory fashion are those relating to hollow-bearing and recruitment trees. It has long been recognised that to mitigate the impact of logging operations upon some hollow-dependent fauna it is necessary to manage for provision of habitat trees in perpetuity (see The Importance of Old trees). This requirement focuses on the need to retain the big old trees with abundant and large hollows suitable for denning and nesting by a plethora of vulnerable fauna (such as owls, cockatoos, parrots, possums and gliders), along with sufficient mature trees (likely to survive and develop hollows in the future) to replace the old trees when they die. While the aim of this prescription is claimed to be to retain large hollow-bearing trees in perpetuity, in the absence of a requirement to retain sufficient recruitment trees to replace hollow-bearing trees as they die out it is a token attempt and can not achieve this aim. (see The Importance of Old trees). In practice its poor application guarantees that it will be ineffective. There is a war of attrition against hollow-bearing trees being waged. Our recent audits have repeatedly found that usually there is only token identification and marking of hollow-bearing and recruitment trees, often limited to near roads or logging boundaries. In our first audit of Doubleduke State Forest NEFA (Pugh 2010b) identified one area that appeared to have had hollow-bearing trees marked after logging, and found logging underway in another area without hollow-bearing and recruitment trees being marked. We publicly complained at the time, though the best the EPA would do is issue a warning letter. NEFA (Pugh 2010c) subsequently assessed an area of 1.75 hectares in Doubleduke and found that an average of 1.9 hollow-bearing trees, and 1.3 recruitment trees, per hectare had been marked for retention, though the EPA ignored our complaint. In an area at Girard State Forest (Pugh 2010d) only three hollow-bearing trees and two recruitment trees were marked for retention in a 3.7 ha area, giving a marking rate of one

3 hollow-bearing tree per 1.2 ha and one recruitment tree per 1.4ha. Again the EPA excused the lack of marking up. In Royal Camp State Forest NEFA (Pugh 2012e) found in one 5 hectare area only one tree was marked for retention. In another 2.3ha sample to assess tree retention from a randomly chosen multi-aged part of the stand, only 4 out of the 11 required hollow-bearing trees were marked and retained and only 5 out of the 11 required recruitment trees were marked and retained, none of the 11 required trees were marked as eucalypt feed or Koala feed trees. Of the total of 16 trees removed that were over 40 cm dbh (diameter at breast height) and thus likely to have been mature, late-mature or senescent, at least 11 should have been retained as hollow-bearing or recruitment trees and should not have been logged. In response to our complaint the EPA assessed an area of 8.4 hectares in compartment 15 and found 2 hollow bearing trees (H) and 3 recruitment trees (R) that had been marked. The Threatened Species licence required around 42 H trees and 42 R to be marked for such an area, along with 42 Eucalypt Feed Trees and 42 Koala Feed Trees (the later which can count as H and R trees). The TSL thus required that a minimum of 84 H and R trees should have been assessed, identified and marked for retention as fauna habitat before logging commenced. The Forestry Corporation thus marked for retention less than 6% of the required trees. This was the same area where the Forestry Corporation hadn t done the required Koala scat searches and hadn t identified Koala High Use Areas (see Doing Surveys). The EPA just sent the Forestry Corporation a warning letter for the failure to identify and protect habitat trees. (Pugh 2014). At Royal Camp the EPA failed to inspect the locations of 4 hollow-bearing trees that had been felled and reported by NEFA (with GPS localities). In these areas there were very few hollow-bearing trees and all should have been retained.

4 One of 4 felled hollow-bearing trees at Royal Camp SF reported to EPA but subsequently ignored. This hollow would have been readily observable from the ground (Pugh 2012e). None of the tree was utilised and it appeared to have been felled to get rid of it. NEFA (Pugh 2012e) also provided the EPA with photos and GPS localities of 8 hollowbearing trees that were marked as recruitment trees, even taking the EPA to 3 of these on the ground, only for the EPA to later claim that they could not locate the alleged location, no GPS data was provided and that The EPA searched the area described but did not identify any suitable H trees marked as R trees. The EPA later admitted they were wrong, though made no attempt to assess the issue. The gist of the problem being that all hollow-bearing trees should have been retained and an additional mature recruitment tree retained for each one. Not only did this rort by the Forestry Corporation enable them to retain half as many trees, it also meant that the mature trees needed as future recruits were able to be logged. In the same area, the EPA were shown an unmarked hollow-bearing tree and a marked recruitment tree with debris left stacked around them, which were also reported (with photos and GPS localities), only to have the EPA later claim Officers could not locate the alleged location, no GPS data was provided and The EPA searched the area described and did not identify any H or R trees with excessive debris. In one case the EPA even photographed the breach and recorded its GPS locality while with NEFA. Photos of hollow-bearing tree marked as a recruitment tree, and recruitment tree with debris around base in Royal Camp SF shown to the EPA, who later claimed they were unable to find them (Pugh 2012e)

5 Even the few hollow-bearing and recruitment trees identified and marked by the Forestry Corporation often do not comply with selection and management criteria. NEFA s recent audits have identified numerous specific examples of breaches of habitat tree retention prescriptions. At best the EPA only writes another useless warning letter to the Forestry Corporation, though often they excuse them. Under the TSL retained hollow-bearing trees must be selected from the trees with the largest dbhob (diameter at breast height over bark) and must be live trees and should have good crown development and minimal butt damage (TSL 5.6 a, c). In practice we find that where marking-up is done a significant proportion of trees fail to satisfy these criteria. In some cases there may be no better choices, though we often find that good sound trees in the vicinity are logged and only useless trees retained. Severely damaged tree retained as a hollow-bearing tree in Girard SF, aside from being half dead the tree had no hollows and is now incapable of forming them (Pugh 2010d). Note the debris stacked against base ready for burning and the extensive damage to the wildlife corridor behind.

6 One of many trees in Styx River SF with extensive butt damage retained as hollow-bearing trees, often sound trees of similar sizes were found cut down in the vicinity, though the EPA saw no problem with the preferential selection of damaged trees.

7 Small tree marked as hollow-bearing tree in Styx River SF, despite not having any hollows and larger trees being logged. Recruitment trees are required to be mature to late mature growth stages, to have good crown development and minimal butt damage, and also to not be suppressed (TSL 5.6 b, d). Suppression occurs when trees are out competed by adjoining trees and become consequently stunted and deformed, which can persist after the competing trees are removed and means the trees are never likely to develop into hollow-bearing trees. In practice we find that appropriate trees are often not retained as there is a direct conflict between good recruitment trees and good sawlogs. It is the hiatus in the availability of mature recruitment trees that poses the greatest long-term threat to hollow-dependent fauna. At both Yabbra and Doubleduke (Pugh 2009, Pugh 2010b) it was found that marked recruitment trees were often suppressed regrowth trees with poor crown development. At one site at Girard (Pugh 2010d) 2 hollow-bearing trees and 7 recruitment trees were classed as suppressed, and one recruitment tree had 60% of its butt severely damaged. At the other site 1 hollow-bearing tree and 1 recruitment tree had significant butt damage.

8 Hollow-bearing (right) and recruitment (left) trees in Yabbra SF (Pugh 2009). Note the butt damage to the marked hollow-bearing tree and the small size of the suppressed recruitment tree. The large old tree is vulnerable to burning and is unlikely to survive long, while even if the recruit was healthy it has no chance of providing replacement hollows in time though as it is suppressed it will be lucky to outlive the hollow-bearing tree. This is pure and deliberate tokenism given that more appropriate alternatives were logged nearby.

9 A 20 or so year old Blue Gum fallaciously marked as a recruitment tree in Koreelah SF - more suitable mature trees were cut down in its vicinity. One of many retained recruitment trees found in Styx River SF with significant butt damage. Suitable trees had been logged in the vicinity.

10 The TSL (5.6 g) requires damage to retained trees to be minimised and that logging debris must not, to the greatest extent practicable, be allowed to accumulate within five metres of a retained hollow bearing tree or recruitment tree. Many retained habitat trees are killed or damaged in post-logging burns, particularly when fuel is left stacked around the bases of trees. NEFA often finds debris around habitat trees. At both Yabbra and Doubleduke (Pugh 2009, Pugh 2010b) it was found that retained trees often had large amounts of debris felled and pushed around their bases. At one site at Girard (Pugh 2010d) 8 of 13 hollow-bearing trees and 7 of 10 recruitment trees had significant amounts of debris dropped or pushed around their bases. At another Girard site all five marked trees had significant amounts of debris left around their bases. With a 2.48 metre diameter this Tallowwood was the largest tree measured in what had been an oldgrowth stand in Girard SF. It is likely to be over a thousand years old. Unfortunately, contrary to licence requirements, large volumes of debris were pushed against its base, creating a funeral pyre waiting for the post-logging burn.

11 Examples of Habitat and recruit trees with debris stacked against bases in Girard SF (from Pugh 2010). Most tree retention prescriptions are set per 2 hectares which both EPA and Forestry Corporation take to mean that this is the average density needed to be retained across the whole of the logging area. The original intent was that Forestry Corporation should retain the required number of habitat trees within every two hectares, where available. Now the Forestry Corporation use it both ways to minimise retentions. In Girard SF where NEFA (Pugh 2010) found that only three hollow-bearing trees and two recruitment trees had been marked for retention in a 3.7 ha area, the EPA responded that tree retention must be assessed over the whole net harvestable area of the tract, not just a component. Similarly at Royal Camp SF, in response to the EPA s claim that the Forestry Corporation had only marked 2 hollow bearing trees and 3 recruitment trees across an

12 area of 8.4 hectares, the Forestry Corporation maintained there had been no breach because across the 751 hectares of the net harvest area... sufficient trees were marked and retained (which was probably untrue but hard to disprove without counting every tree) (Pugh 2014). Yet in Koreelah SF NEFA (Pugh 2013) found the majority of the stand had previously been logged and culled to remove most old trees, with a remnant 6 ha stand of oldgrowth Brushbox forest retained. NEFA wrote to the Forestry Corporation s CEO Nick Roberts that The TSL requires that most, if not all, of these ancient trees be retained when densities are averaged across the stand to which he responded that: The intent of the TSL is not to retain HBTs in aggregated clusters to offset lower occurrences elsewhere in the harvesting area.... So, on the one hand the Forestry Corporation claim they can offset inadequate habitat tree retention over large parts of a logging area by retaining higher numbers in one part of a stand, though on the other hand they maintain they don t need to increase tree retention in one part of a stand to offset deficiencies elsewhere. The EPA were asked (Pugh 2013) to provide clear guidance on the application of these prescriptions and to make a ruling on the contradictory claims made by Forestry Corporation, though they have yet to do so. The retention requirements for hollow-bearing and recruitment trees are inadequate, with the requirements for recruitment trees grossly inadequate (see The Importance of Old trees). Where the habitat tree prescriptions are implemented, the poor selection of trees significantly reduces the intended protection. Of most concern is the intentional and widespread rorting of recruitment tree prescriptions. As the retained hollow-bearing trees die there will be far too few recruitment trees left to replace existing hollows. The hiatus in the future availability of tree hollows will cause further significant reductions in hollow-dependent fauna. Trees identified as qualifying as habitat trees need to be permanently identified and protected by recording their localities with a GPS and monitoring them over successive logging operations. This will make trends clear and improve auditing. Though to avoid rorting it is clear that all surviving trees over 100 years old should be fully protected. The Importance of Old trees Threatened Species Protecting Exclusion Areas Doing Surveys REFERENCES Pugh, D. (2009) Preliminary Audit of Yabbra State Forest Compartments 162 and 163. North East Forest Alliance, December Pugh, D. (2010b) Preliminary Audit of Doubleduke State Forest Compartments 144, 145 and 146. North East Forest Alliance, June Pugh, D. (2010c) Preliminary Audit of Doubleduke State Forest Compartments 144, 145 and 146, Supplementary Report. North East Forest Alliance, November 2010 Pugh, D. (2010d) Preliminary Audit of Girard State Forest Compartments 44, 45, 46, 54, 55 and 56. North East Forest Alliance, August 2010.

13 Pugh (2012e) NEFA Audit of Royal Camp State Forest. North East Forest Alliance. Pugh, D. (2013) Koreelah State Forest Audit. North East Forest Alliance, June Pugh, D. (2014c) North East Forest Alliance submission to: Performance of the NSW Environment Protection Authority (Inquiry), (vi) the regulation of forestry practices in Royal Camp State Forest. North East Forest Alliance.