In March 2020, just a few months after the devastating 2019/2020 Black Summer bushfires, state and federal governments rolled over the controversial Regional Forest Agreements (RFAs) which give logging an exemption from federal environment laws.

A new clause has been introduced where a significant event (like the 2019/2020 bushfires) can trigger a Major Event Review (MER).

The review was announced last year, but since then logging in critical habitat for threatened species has continued, and there have been no changes to logging schedules. The review is now open to public consultation and submissions will be accepted until 31 August 2021.

You can find out more about this review here.

As is noted in the MER document and many other reports, the ecological, social and economic impacts of the 2019/20 fires were enormous. The fires had a dramatic impact on many forests which were available for logging as well as protected areas within state forest, national parks and other conservation reserves. Many of the ecological consequences of the fires are not yet understood. Some actions taken after the fires, specifically salvage logging of burnt forests, will compound the damage caused by the fires.

Because of the loss of many production forests, there are clearly implications for the planned phaseout of native forest logging by 2030 and Victoria’s Regional Forest Agreements (RFAs).

Key issues

Fires have increased pressure on threatened species and increased the ecological value of unburnt areas

It is clear that the bushfires have had devastating impacts on Victoria’s forests and wildlife in the east of the state. Many forest dependent species were already negatively impacted by the cumulative impacts of drought, bushfires, and logging.

Logging operations have greatly modified large areas of forest throughout Victoria in recent decades, and the operation of the Regional Forest Agreements continues to be a disaster for the survival of forests and wildlife.

Many bushfire-affected threatened species have logging listed as a major threat in their Flora and Fauna Guarantee (FFG) Act Action Statements. The state government’s own risk assessment of threatened species and habitats carried out in October 2020 notes the toll logging has on threatened wildlife.

Despite the extensive bushfire impacts on wildlife and forests, and the undeniable increase in the habitat value of remaining unburnt areas, pre-fire logging plans have stayed in place. There have not been any reductions or substantive changes to existing logging plans since the bushfires. Additionally, two extra schedules of new logging areas have been announced post fire, one approved in July, and another approved in December 2020.

In May 2020, the Victorian government’s Environment Department recommended that logging stop in key unburnt habitat for threatened species to halt the threat of irreversible damage to biodiversity after the 2019-20 bushfires.

Future logging plans are a significant threat to forests and wildlife. Across the 10 refuge areas identified in the report After the Fires (available here), 553 logging coupes covering more than 20,000 ha of forests are planned for logging by the Victorian government’s logging agency across the Central Highlands, Gippsland, and Alpine areas.

The existing reserve system must be reconsidered in light of the fires

20210417_152935Scientists from the Threatened Species Recovery Hub made recommendations in January 2020 to locate and protect key refuge areas which “will be of profound importance for species’ recovery, and hence should be the immediate and ongoing focus for
conservation management”. A number of key refuges for wildlife have already been logged, and many more are up for logging.

Almost half of the conservation parks, reserves and Special Protection Zones within the Comprehensive, Adequate and Representative (CAR) reserve system in these three FMAs is within the fire extent. The bushfires also heavily impacted the proposed Immediate Protection Areas (IPAs). Announced in November 2019, the IPAs were intended as new conservation measures for the threatened Greater Glider. Approximately 90% of the IPAs in East Gippsland burnt, with a large proportion subject to high severity fires.

Climate change is driving longer and more intense fire seasons

The bushfires of 2019-20 are the third landscape-scale fires to burn through over a million hectares in Victoria during the last 20 years. in terms of massive fires (greater than 250,000 hectares), Victoria experienced two such events in the 19th century and five in the 20th century. In the first two decades of the 21st century, we have already had three mega fires. This increase in frequency and intensity should be a key consideration of the Major Event Review.

As noted by the Victorian government’s ‘Climate Science Report 2019’,

‘There has been an increase in dangerous fire weather and the length of the fire season across southern Australia since the 1950s.

Many government initiated inquiries have identified the link between climate change and fire risk and intensity:

The Royal Commission into National Natural Disaster Arrangements, also referred to as the Bushfire Royal Commission was explicitly asked to look at mitigation options, but not drivers of global heating. In spite of this, it found that further warming of the Australian climate over the next 20 years “appears to be inevitable,” meaning that catastrophic bushfire conditions will become more common.

The NSW Bushfire Inquiry found that “climate change as a result of increased greenhouse gas emissions clearly played a role in the conditions that led up to the fires and in the unrelenting conditions that supported the fires to spread”.

In Victoria, the report into the 2019/20 fires produced by the Inspector-General for Emergency Management (IGEM) said “the incidence of large, severe and recurrent bushfire events in Victoria has increased exponentially over recent decades and shows no sign of slowing.”

As has been noted by DELWP, with climate change driving an earlier start to the bushfire season, with more bushfires starting in spring – when winds are often strong – this ‘may also change fire weather conditions that are experienced, such as wind speed and direction’ (source).

The current Regional Forest Agreements (RFAs) have 16 clauses that mention climate change. Climate change is mentioned over 40 times in the East Gippsland RFA and similar in other RFAs. Yet the Major Event Review summary document does not mention climate change. This is a significant oversight.

The implications for climate, the links to extreme fire and the combined impact of logging should be assessed in detail and at regional scale in the Major Event Review. Climate change will have profound impact on the capacity of the forest to supply both wood/pulp, habitat and other ecological services like water in the future.

The MER should specifically address climate resilience actions as identified in the RFAs, such as:

  • Ensure all EVCs that are Climate Change Vulnerable are afforded additional protections beyond that provided for under the JANIS Reserve Criteria.
  • The identification and protection of refugia.
  • Protect important occurrences of the species or community in the CAR Reserve System and maintain or restore ecological management regimes to ensure its viability.
  • Improve climate change resilience and future viability of Listed Species and Communities and other MNES informed by best practice approaches, best available science and Traditional Owner knowledge.

Impacts on Alpine Ash forests

As is noted in the MER report, most of the area burnt in the 2019–20 bushfires was fire-tolerant mixed-species eucalypt forest. These species typically survive most fires and regenerate by resprouting after the fire event.

However, Ash species were also affected by the bushfires. Ash species are typically killed by high severity fire and regenerate through seeds that are released from the canopy. If Ash trees are killed before they reach seed-bearing age (around 20 years), Ash forests may not regenerate without intervention. Large areas of Ash forests have been impacted by recurring fires since 2003, meaning there was an extensive area of immature Ash forest in the landscape in the lead-up to the 2019–20 fire event. The total area of Ash forest impacted by the bushfires in 2019–20 is 4,286 hectares of Mountain Ash forest and 52,516 hectares of Alpine Ash forest. It is estimated that 11,500 hectares of immature Ash forest was impacted by high severity fire in 2019–20.

However there have been repeat fires previously in this vegetation community, including to the west of the footprint of the 2019/20 fires and this must be considered in the review.

The Bushfire Recovery Project is tracking forest regrowth in NSW and Victoria after the 2019/20 fires, using data gathered by citizen scientists, and gives some insight into how affected forests are recovering.

Their report has found that while low elevation forests appear to be recovering well, forests in some subalpine areas ‘near Mount Kosciuszko and in Victoria’s East Gippsland region are struggling to recover from the 2019-20 bushfires’.

This is consistent with everything we already know about the impact of climate driven fire seasons on the higher elevation Alpine Ash forests.

According to research published in a report called ‘Biological responses to the press and pulse of climate trends and extreme events’, Alpine Ash forests face the prospect of ecological ‘collapse’.

The mountain forests in the east of the state, which are dominated by Alpine Ash trees are now so threatened by fire and the prospect of collapse that the state government has an aerial seeding program to stop the collapse of these forest systems.

Following the 2013 Harrietville-Alpine Bushfire, the Department of Sustainability and Environment, or DSE – now DELWP) and Parks Victoria initiated a rapid response forest recovery program, which aimed to restore Alpine Ash forests that had been burnt in 2003 and/ or 2006/7 and where only limited numbers of parent trees had survived. Since then, the program has been expanded considerably as more areas have been burnt multiple times.

In October 2020, it was announced that:

‘The Victorian Government is undertaking the largest forest restoration effort in the state’s history with a $7.7 million operation that airlifted tonnes of eucalypt seeds into areas of forest devastated by last summer’s fires. 

Associate Professor in Forest and Landscape Dynamics at Melbourne University Craig Nitschke says that:

‘A projected warming and drying climate, possibly with more lightning, is likely to lead to increasingly frequent, severe fires. The hotter, drier conditions will also constrain the capacity of both alpine ash and mountain ash to recover from disturbance, by reducing tree growth, seed production and seedling establishment. Reduced growth, combined with shorter intervals between high-severity fires, will result in ‘interval squeeze’, which can threaten these species’ persistence as the climate changes’ (source).

Given the heavy current reliance on Alpine Ash forests by the timber industry, and with the vegetation community facing the prospect of ecological collapse, it is essential that the Review look at greatly reducing the reliance on these forests in any further production through to the wind up of the native forest industry.


Logging, including so-called salvage logging operations, must be fully suspended in East Gippsland and the Alpine areas, and should be suspended elsewhere in forests that contain threatened species impacted by the fires.

A moratorium on logging is urgently needed at least until there can be comprehensive, well-resourced surveys undertaken as part of the Major Event Review, and required protections put in place for threatened species.

Government should bring forward the 2030 transition out of native forest logging. In November 2019, the Victorian government committed to a decade-long transition out of native forest logging. This timeframe was too slow even before the bushfires and its devastating impact on forests and wildlife. Now there is an even more urgent need to rapidly transition the logging industry out of native forests

Urgently prepare Recovery Plans for species both impacted by the fires and threatened by ongoing logging, and update Conservation Advice. Recovery Plans are critical to protecting listed species, yet so many species at risk of extinction still have no Recovery Plans. The work to finalise these Plans is now even more urgent due to the fires. Some listed species never had Plans prepared at all – others were written in the 1990s and have not been substantively updated or strengthened since then, despite ongoing species declines and obviously weak, vague, and inadequate protections.

Make a submission

You can make a submission via the government’s Engage website here.

You can easily make a submission here (this information is provided by Goongerah Environment Centre).