Logging is Not a Key Threaterning Process

Submission by the
National Association of Forest Industries
to the
Endangered Species Scientific Subcommittee

December 1997

A     Introduction

A range of native birds and animals use nesting hollows in trees for breeding. Where population declines of these species are observed to occur, a reduction in the number of available nesting sites may be one of the causal factors. Effective management of endangered species appears to involve making judgements about which are the most potent causes of population declines, which causal factors are most amenable to beneficial change, and which beneficial change produces the greatest improvement.

The sponsors of the nomination are asking the Subcommittee to agree that "loss of hollow-bearing trees in native forests due to ecologically unsustainable forestry practices" is sufficiently implicated in such population declines to warrant listing as a "key threatening process". It is important to note that it is not simply "loss of hollow-bearing trees" that has been proposed for such listing, but "loss of hollow-bearing trees due to ecologically unsustainable forestry practices".

B     What is "ecologically sustainable"?

The proposal does not contain a definition of ecological sustainability. The negative case ("ecologically unsustainability") is partially defined on p.2 of the nomination where it is stated that:

"Ecologically unsustainable logging operations remove trees well before they reach the age when hollows form."

It seems to be a problem for the nomination that this is the only definition that is put forward, because it gives no indication of the scale on which this practice occurs. It would be fair for the Subcommittee to ask, for example, whether it would be "ecologically unsustainable" for example, to fell one tree before it develops hollows. Would it be ecologically unsustainable to fell ten such trees, or a hundred? If a thousand trees in a coupe were felled, 100 hollow-bearing trees were left standing, and the coupe was surrounded by reserve forest containing a large number of hollow-bearing trees, would that be "ecologically unsustainable"?

The other problem with this definition of "ecologically unsustainable" forestry practices is that it does not seem adequate to explain the loss of hollow-bearing trees that is referred to in the process nominated, only the absence of their development. If a loss of hollow-bearing trees is indeed taking place, the process defined as being "ecologically unsustainable" could not account for it.

More generally, the question of what constitutes sustainable forest management is currently receiving intense, widespread and continuing examination through a series of "Comprehensive Regional Assessments" (CRAs), followed by "Regional Forest Agreements" (RFAs). Both of these processes are paying considerable attention to the problems and the needs of endangered species. These CRA's and RFA's could be regarded as amounting to ostensive definitions of sustainable forest management. Those ostensive definitions might be modified over time by changes to the terms of the agreements, but the agreements are based on best scientific understanding that the expenditure of many millions of dollars by state and federal governments has currently able to achieve. The agreements also take account of the existence of large areas of reserve forest, and the interplay of timber production values and biodiversity, heritage and other values. They are not simple or simplistic.

The nomination placed before the Subcommittee is silent about these far-reaching studies and agreements. It also has nothing to say about the ecological role of reserve forests, or about the extent to which the protection of hollow-bearing trees is already incorporated into forestry codes of practice.

The Subcommittee may decide to treat the lack of a definition of "ecological sustainability" as nothing more than a technical flaw in the nomination. It may decide also that the absence of any factual information about the extent of the allegedly "ecological unsustainable" practices should not be an impediment to the consideration of the nomination. If the Subcommittee were to take that view, it would probably place itself under an obligation to conduct its own enquiry into what is and is not "ecologically sustainable", and also into the extent that allegedly "ecologically unsustainable" practices are actually occurring in forested areas. It might also need to make some judgement about the role of and the adequacy of reserve areas, which the profession of forestry considers to have direct relevance to the sustainability of what happens in production forest areas.

Subcommittee members will be aware that studies and judgements of this kind have been and are being made in the course of negotiating RFA's. Those studies and judgements are accessible to the members of the Subcommittee and could be drawn upon if desired, or replicated.

C     Which Species are Affected?

The nomination mentions a number of species on p.2, and lists others on p.3 and p.4. They are:

• Leadbeater's Possum
• Masked Owl
• Sooty Owl
• Powerful Owl
• Rufous Owl (eastern subspecies)
• Swift Parrot
• Regent Parrot (eastern subspecies?)
• Superb Parrot
• Red-tailed Black Cockatoo (south-western subspecies)
• Yellow-tailed Black Cockatoo
• Baudin's Black Cockatoo
• Brush-tailed Phascogale (southern mainland)
• Yellow-bellied Glider (southern subspecies)
• Squirrel Glider
• Yellow-bellied Sheathtail Bat
• Great Pipistrelle

An examination of the information available about each of these species seems to be required. The last two are not covered in this submission, because no information appears to be readily available.

1. Leadbeater's Possum

   As the recovery plan outlined in Maxwell et. al. (1996) makes clear: "The optimum habitat of Leadbeater's Possum is a regenerating or uneven-aged Ash forest that contains both wattles and an ample supply of old hollow trees. The occurrence and quality of habitat is primarily determined by patterns of successional change and stand development resulting from disturbance such as past wildfires and timber harvesting operations."

   To the lay person, Leadbeater's Possum might seem to be, to a significant degree, dependant upon forest disturbance to maintain the availability of food and nesting sites on a contiguous basis. Uncontrolled wildfire can provide that disturbance, and seems to have done so in fact. Well-managed forestry operations that preserve nesting sites at the same time as providing areas of regrowth with abundant wattle, also provide that disturbance. The disadvantage with a complete reliance on wildfire to provide that disturbance, as the Recovery Outline seems to imply, is that it can lead to spectacular rises and falls in possum populations. It appears to be the long-term consequences of the 1939 fires that constitutes the greatest current threat to the possum:

   "Key threats are that fire killed remnants are rapidly decaying and falling over and recruitment of hollows for the species will not occur in regrowth forest for another 150 years."

   If current timber harvesting operations are sensitive to the need to preserve habitat trees, it becomes hard to see how even a draconian step such as the immediate cessation of forestry operations would do anything at all to prevent the population decline of Leadbeater's Possum that is apparently expected to occur over the next 150 years.

   Given that it was almost certainly not forestry, but the disastrous fires of 1939 that caused what seems to have been a precipitous decline in possum numbers, policy measures that focus on the possible constriction of forestry activities seem to be singularly misplaced.

   Recovery plans and action statements have been prepared under relevant legislation. They contain provision for monitoring and assessment. They include provision for the adoption of appropriate silvicultural practices.

   Any attempt to proscribe forest harvesting would appear not only to be unwarranted by what is known of the reasons for the possums' earlier presumed decline, but also to be antagonistic to the need for forest disturbance on which the continued availability of contiguous food and nesting habitat seems to depend.

2. Masked Owl (northern and southern subspecies)

   Of the southern subspecies of the owl, Garnett (1992b) has this to say: "... Though there is no firm evidence of a contraction of range, it has probably been affected by clearance for agriculture and may currently be under threat from some forest and fire management practices. However, being cryptic, it may be more common than records suggest. ..."

   Of the northern subspecies Garnett (1992b) says: "Very little is known of this sub-species of Masked Owl. Specimens and sight records indicate a distribution from north-eastern Queensland to north-western Western Australia. The bird probably roosts and nests in closed forest and feeds in woodland. Burning may be affecting the survival and regeneration of nest trees, but too little is known to assess status. ..."

   For both sub-species, Garnett (1992b) indicates that what is needed is "more information on basic ecology, particularly home range, diet, nesting requirements" and the effects of current forest management and agricultural practices". This does not appear to constitute a robust scientific basis on which to label something called "ecologically unsustainable" forest management a key threatening process.

3. Sooty Owl

   Garnett (1992b) says that: "Historically the main threat has been clearance of habitat for agriculture with large areas of rainforest being completely eliminated. Clearance for agriculture has now largely ceased, and the sub-species is now most threatened by disturbance of creek-side rainforest, particularly of nest trees, and by clear felling for forestry."

   Of the owls numbers, Garnett says: "Though the Sooty Owl appears to be distributed thinly through suitable habitat, there are as yet no measures of home range size using data from marked individuals. Hence no estimate of population size is valid".

   Nevertheless, Garnett documents extensive conservation measures already being taken. In the central highlands of Victoria, the measures being taken to protect Leadbeater's Possum should also benefit the Sooty Owl.

   Garnett says that aspects of the owl's ecology needing further study include the effect of habitat fragmentation and the loss of old growth elements. As well, "A better understanding of home range size, dispersal capabilities, and nest and roost site requirements is needed to formulate appropriate forest management strategies."

   The effects of feral predation on the owl's prey seems not to have been studied. Given that current felling practices in most of the owl's range leave about 30% of the canopy intact, with emphasis on the preservation of habitat trees, it may be that forestry operations improve the access the owl enjoys to food species on the forest floor.

   Garnett acknowledges the role played by conservation reserves in ensuring the availability of suitable habitat. Against the background of poor information on numbers and ecology, the nomination of any forestry practice as a key threatening process would appear to be unwarranted.

4. Powerful Owl

   Garnett (1992b) notes that the Powerful Owl is rare, but that its exact numbers are uncertain and estimates require substantiation. It is said to have been: "affected by habitat clearance and may continue to be affected by some forest management practices, particularly clear felling. However, the species does persist in forests that have been selectively logged for over a century and can survive close to human habitation. It is apparently able to disperse across open country so populations are unlikely to be fragmented."

   Garnett documents conservation measures currently being taken, and says that future conservation requirements include: "accurate measures of density and lifetime habitat use ... so that forest management can be consistent with owl conservation. The effects of current forest management on nest site availability, prey density, recruitment, home range requirements and other ecological parameters require further study. Monitoring should be a standard part of forest management."

   Many in the forest industries would argue that, to the extent that forestry practices may have caused problems for the owl, those practices have been modified. Chief amongst those modifications are significant reductions in the level of canopy removal involved in clear felling operations, and the preservation of habitat trees.

   Because these modifications have been made, the continued existence of problems may be more a hypothesis than a conclusion. The hypothesis can certainly be tested.

5. Rufous Owl (eastern subspecies)

   Garnett (1992b) says that this subspecies of tropical owl "roosts and nests in fragments of rainforest, particularly gallery rainforest, and forages in surrounding woodland." The available information suggests that in the past much suitable habitat has been cleared for agriculture, but current clearing appears to affect forage areas and not nesting areas (ie not rainforest).

   Proposed conservation measures are: "A survey should be conducted to obtain a more accurate assessment of abundance and the status of nest sites. Particular attention should be paid to the effects of habitat clearance and invasion of habitat by weeds."

   Forestry does not appear to be a suspect, because there are no logging operations in tropical rainforest.

   It is of particular interest in relation to these four owl species, (although not of direct relevance to this submission) that possible problems caused by the impact on owls' food supply of competitive predation by feral cats and the European red fox appear not to have been seriously considered in any of the Commonwealth's Action Plans. Why this is so is not clear. Evidence of the impact of feral predation has been available since the early 80's, and feral predation is already listed as a key threatening process under the Commonwealth Act. Evidence from other countries seems unequivocal:

   "In North America, predation by cats has also been shown to diminish prey for raptors during winter, thus exerting a minor competitive effect on the raptor populations. ... Although no equivalent studies have been carried out in Australia, feral cats could reduce prey populations for nocturnal species such as barn owls ... powerful owls ... masked owls ... sooty owls and letter winged kites." (Dickman 1996)

   Some owl sub-species have apparently shown high levels of adaptability in relation to nesting sites, but finding alternative food sources may be harder. The apparent lack of scientific interest in this aspect of owl ecology is hard to explain. It is true, of course, that the possibility of problems arising from the use of forests for timber production has been of greater public interest.

6. Swift Parrot

   According to Garnett (1992a), populations of the parrot have declined as a result of clearance of feeding and breeding trees. At the same time, Garnett notes that knowledge about the species is not adequate for recovery objectives and actions to be defined accurately, that the parrot's critical habitats in South East Australia are little known, and that the significance of flowering cycles in Blue Gums needs to be established. Forestry Tasmania and land-care groups in north-eastern Victoria have established blue gum plantings to provide food sources, and Forestry Tasmania has implemented forest practices and harvesting codes to assist in conservation of the species on crown land.

   Until knowledge about the species improves it might be difficult to regard any suggestion that forestry is responsible for its decline as anything other than a hypothesis to be tested.

7. Regent Parrot

   The Regent Parrot is a bird of the open woodlands in the Murray basin. Its decline is attributed by Garnett (1992a) to: "clearance for agriculture, particularly mallee (confirmed) competition for nest sites with introduced Honey Bee (confirmed) grazing in mallee (speculative) loss of nest sites through clearance and water-logging (speculative), and cutting of timber for firewood (speculative) trapping for the bird trade (speculative) poisoning and shooting by orchardists (speculative) traffic accidents (speculative). Forest management for timber production does not appear to be in any way implicated in this long litany of adverse circumstances. The statement in the nomination that "the nominated process operates in areas where these species occur" appears incorrect, even allowing for some uncertainty as to what the "nominated process" actually is.

8. Superb Parrot

   The Superb Parrot is another woodland species whose decline is attributed by Garnett (1992a) to "clearance for agriculture, particularly River Red Gum / Yellow Box associations (confirmed), degradation of habitat by stock (confirmed), cutting of timber for firewood (speculative), trapping for the bird trade (speculative)". Curiously, Garnett (1992b) takes a slightly different view of trapping: "... the species is still being trapped for the bird trade. ... probably in large numbers". Inappropriate fire regimes may also be playing a role. More information is said to be needed about nest site selection and competition for hollows, particularly in areas subject to timber extraction (presumably for firewood).

   Forest management for timber production does not seem to be an issue with this species, given its preference for open woodland.

9. Red-tailed Black Cockatoo

   It appears from Garnett (1992a) that too little is known about the cockatoo to actually conclude that its numbers have declined. Also, there is apparently no information on nest site requirements or their availability. The first management action listed in Garnett (1992a) is to: "survey nest sites in conservation reserves and wood production forests." Also required is management action to: "prepare management guidelines for wood production forests to ensure nest sites are maintained and enough trees are retained to allow for replacement of existing nest trees when they die."

   Considering the uncertainty about population levels, and that a shortage of nesting sites is treated by Garnett as a speculative reason for any decline that might have occurred, the management prescriptions seem more than adequate.

   Garnett's (1992a) account of the reasons for the cockatoo's decline takes no account of research (Saunders, 1991) in Western Australia showing that feral cats climbing into tree hollows and preying on nestlings caused the failure of up to 17% of nests. Consequently, Garnett's Action Plan makes no provision for dealing with this problem.

10. Yellow-tailed Black Cockatoo

    While this cockatoo may have a requirement for nesting hollows in trees, it does not appear to be endangered, vulnerable, threatened or rare.

11. Baudin's Black Cockatoo

    The level of information available for this sub-species seems to be comparable to that for the Red-tailed Black Cockatoo. Its decline is not confirmed, and there is not, according to Garnett (1992a), sufficient knowledge to permit the accurate definition of management objectives and actions. Also there is no information on the availability or distribution of nest sites. Better information is said to be needed on recruitment rate and the effects of shooting by orchardists. Against this uncertain background, the statement in Garnett (1992a) that "threats include destruction of nest sites by logging (speculative) prevention of development of new nest sites by short rotation times in wood production forests and shooting by orchardists (speculative) but their biological significance is unknown", might be regarded as a more confident summary than the available information appears to warrant.

    Until the speculative hypotheses are tested and confirmed or rejected, the present and future management actions described in Garnett's Action Plan appear more than adequate, especially when it is considered that the bird's decline is apparently not confirmed.

12. Brush-tailed Phascogale (southern mainland)

    Maxwell et. al. (1996) notes that the range of the Phascogale has been "reduced by about 50%, predominately due to agricultural clearing and deforestation associated with gold-mining activities." Its abundance within its remaining range is "mostly unknown as the species eludes conventional fauna survey techniques. However its distribution appears patchy and it seems to be absent or in very low numbers across much of its remaining habitat."

    The Phascogale is a woodland and open forest dweller that nests in hollow-bearing trees. Woodland is not widely managed for timber production. Maxwell says that "the greatest current threat is the increasing decline in the availability of hollow-bearing trees." This decline is unlikely to have resulted from forest management for timber production. Maxwell also notes "predation by foxes and cats", but makes no attempt to assess the relative magnitude of that impact. Some further light is thrown on this by Dickman (1996) who says "feral cats ... were shown to be a major cause of failure in two of three releases of brush-tailed phascogale in Gippsland (Soderquist 1995)". This may be a fruitful line of enquiry for those researchers looking for reasons why the phascogale's numbers are apparently low in areas of suitable habitat.

    Maxwell's recommended actions say that a management plan should examine what amendments are needed to current forest management practices to enhance phascogale habitat.

    It may be that such an examination would conclude that no "enhancements" are necessary, or that enhancements to habitat will achieve no improvements in the face of continuing efficient cat predation, to which there currently seem to be no effective counter measures.

13. Yellow-bellied Glider (southern subspecies)

    The Glider's preferred habitat according to Maxwell et. al. (1996) is "Coastal and foothill open forest and woodland, also found in lower numbers in wet sclerophyll forest".

    Its range is extensive, and essentially coastal. Maxwell says that it is "considered to be uncommon throughout range, but may have been locally more abundant. Despite large size and highly vocal nature, may be inconspicuous and difficult to census." Maxwell also says that the Glider is "generally found at low densities which coupled with large home range and long-term family groupings indicates that status of Rare is warranted."

    In the light of these general observations, it is perhaps a little surprising that Maxwell offers the forecast that the Glider "will suffer declines in density with the removal of old growth elements from unlogged forests, or from previously lightly-logged forests." No evidence is put forward by Maxwell to support this prediction. It might also be regarded as surprising that Maxwell prescribes, under the heading "recommended actions", the "reservation of large areas of forest containing old hollow trees, coupled with links to other protected areas by corridors no less than 200m wide". This is a somewhat sweeping recommendation for a species that is rare, but not threatened, and appears to take no account of the extent to which "large areas of forest" have already been reserved.

    Maxwell makes no mention of the possible impact of fox and cat predation, despite the evidence that "small possums and gliders are taken preferentially, and that young animals are at particularly high risk of injury." (Dickman 1996)

    In the opinion of this Organisation, Maxwell's treatment of forest management in the case of the Yellow-bellied Glider comes very close to being tendentious. Even so, it makes no reference to the nominated process that is the focus of the public nomination at present before the Subcommittee.

14. Squirrel Glider

    The range of the Squirrel Glider is similar to, but more extensive than, that of the Yellow-bellied Glider. Its preferred habitat is also similar, but more eclectic. Maxwell et al (1996) observes that its "overall distribution [is] not significantly changed but population fragmented and probably in steady decline in areas with predominantly pastoral or agricultural land use. Also has suffered loss of habitat in NSW north of Sydney due to coastal development.

    Maxwell et. al. (1996) offers no comment on population levels, except by conjecture. The Action Plan lists an extensive range of "current threats", and an extensive range of "recommended actions". Amongst the latter are to develop a national recovery plan that examines "what amendments are needed to current forest management practices to enhance Squirrel Glider habitat". Also included is the need to "monitor persistence and abundance throughout range" and "conduct further research into the ecological requirements of the species and the impacts of habitat alterations, including timber removal, silviculture and grazing." It is possible that the examination of forest management practices called for by Maxwell will conclude that no "enhancements" are needed.

    It is puzzling that the Action Plan contains no provision to deal with feral predation in connection with this species.

D     Conclusions

The sponsors of the nomination have provided a definition of the nominated process that is inadequate. Without some evidence of the scale on which the nominated process is occurring, it is hard to see how it could be classed as "ecologically unsustainable". There is also the problem that the harvesting of re-growth forest does not lead to a loss of hollow bearing trees if, as the proponents say, no hollows have formed in the trees being harvested.

If the Subcommittee wishes to disregard the definitional problems and the absence of factual data about the extent of the incidence of the nominated process, it will need to carry out an examination of timber harvesting in general. NAFI considers that this examination would need to have regard to:

• The adequacy of existing species recovery plans insofar as these incorporate elements of forest management.

• The adequacy of silvicultural and harvesting codes of practice currently in use.

• The adequacy of forest management systems in protecting endangered species, as assessed by the Commonwealth through the RFA process.

• The adequacy of reserve areas currently being re-defined and set aside as part of Comprehensive Regional Assessments and Regional Forest Agreements.

• The adequacy of reserve management.

Regarding the evidence concerning rare, vulnerable and endangered species put forward by the proponents, the following summary seems appropriate:

• Some of the species nominated do not occur in areas where the forest resource is managed for timber production.

• In several cases the management of the forest resource for timber production is speculated as having some bearing on population declines. In all of those cases, ameliorative strategies have been put in place and their effects have yet to be determined.

• For species where forest management for timber production is one of several possible threatening circumstances, more seems to have been done to ameliorate the forest management practices than any of the other threats, actual or speculated.

• Some possibly serious threats have been ignored, not only by the proponents of the nomination, but also, to some extent, by the authors of the relevant action plans.

• In several cases, more information about the species ecology is said to be needed before appropriate management actions can be accurately defined.

• For some of the species nominated, population declines are not confirmed, and the species may simply be rare.

In light of this, it appears that the effect of the nomination is to invite the Subcommittee to take what is a speculative hypothesis in relation to a number of rare, threatened or endangered species, and turn it into fact by administrative fiat.

In cases where the reasons for population decline that relate to forest management are stated to be speculative, the proponents are not calling for more or better research to test the speculative hypothesis, they are calling for a finding of fact from the Subcommittee that some ill-defined aspect of forest management for timber production is to blame.

The proponents do not call for the modification of forestry practices that might be beneficial to the species concerned in particular areas. They call for a declaration that would tend to incriminate forest management for timber production generally.

The proponents also do not attempt any ranking of the factors that may have led to population declines in terms of the severity of impact or the urgency of the need for remediation. Instead, they seek the elevation of one of those factors, in many cases only speculatively identified, as a key threatening process.

For the relatively small number of endangered species that are forest dependent, the problems of population decline are evidently more complex than is implied by the simple label of "ecologically unsustainable" that the proponents want the Subcommittee to attach to some forestry practices. Feral predation in particular seems to be emerging as a much more serious and widespread problem than most of the Action Plans prepared under Commonwealth sponsorship appear willing to acknowledge, and there is very little research into and understanding of the impact of altered fire regimes.

In the case of Leadbeaters Possum, it is arguable that sustainable forest management is responsible not for depriving the possum of conditions for its survival, but for providing those conditions. To the extent that a degree of habit disturbance appears to be necessary to ensure a continuing supply of food and nesting sites, the choice facing forest managers seems to be between forestry and wildfire. Because the latter inevitably brings high rates of mortality in possum populations, it seems unlikely to become the management tool of choice.

NAFI regards the nomination as a further attempt to use the opportunity afforded by the Commonwealth legislation to "demonise" forestry in the eyes of the Australian public, and not as a serious attempt to help solve the problem of species endangerment.

References