SUBMISSION TO THE GIPPSLAND REGIONAL FOREST PROCESS
By Anthony Amis from Friends of the Earth Forest Network and a Recreational Fisherman.
PO Box 222 Fitzroy, 3065 Ph: (03) 9419 8700 Fax: (03) 9416 2081
I would like to submit my submission to the Regional Forest Agreement Process for the Gippsland region. I would also like the opportunity for myself and a member of my group to address the panel hearings when that opportunity arises.
I would like to express my alarm that the RFA process has paid so little attention to aquatic fauna species and factors concerning their long term survival. As a recreational fisherman it alarms me that land use decisions are being made without wider participation of the conservation and fishing community.
I also am alarmed at the general decline in the health of Gippsland's rivers which can be blamed on very poor catchment management from all land users. My submission however will focus on the role of forestry in degrading the aquatic environment to the dis-benefit of recreational fishermen and conservationists.
I would like to bring to your attention an extremely important report which the Gippsland RFA fails to mention in their September 1999 Assessment Report. The report is entitled Fisheries Economic Impact Studies
Economic Impact of Recreational Fishing in Victoria July 1997 - Fisheries Victoria. The fact that the economic considerations outlined in this report were not acknowledged by the Assessment Report, reveals to me that the worth of recreational fishermen to the Gippsland economy have not been factored into the Regional Forest Agreements. This oversight is appalling and reveals a gaping hole in the Assessment Report. It could be interpreted as being a deliberate oversight.
The following quotes are taken directly from the Fisheries Victoria report (please note that the south east takes in the Gippsland RFA area);
p1 “ Results from the study indicate that in the last year an estimated $1.037 billion was spent on recreational fishing activities in Victoria . . . this represents approximately $200 spent per kilogram of fish caught and kept. The contribution of the recreational fishing sector (including support industries) to the Victorian economy (Gross State Product) is estimated to be $1.265 billion per annum, and the provision of fishing related goods and services generates approximately 27,000 jobs annually . . . Melbourne region made the largest contribution to Gross Regional Product ($765 million per annum), North East ($171 million), South East ($144 million), South West ($106 million), North West ($76 million)”.
p9 “Allocation of recorded expenditure items as fishing expenditure; Fishing Tackle Bait 0.7%, travel, accomodation, fuel, food and drink, hire fees 2.7%, fishing equipment and specialised clothing 12%, Boats, 4WD’s etc 83.4%”
p19 “ Most inland/freshwater species caught (current trip) in South East: trout 52%, murray cod 36%, english perch 27%, blackfish 2%."
p21 “main reason cited for undertaking current trip in South East: fishing 77%, holidays 21%, visting friends/family 2%."
p23 “the north east and south east regions attracted the highest proporation of fishers who made overnight trips: south east motel/hotel 13%, camping 59%, private rental 7%, friends 9%,other 12%."
p26 Estimate of gross expenditure on recreational fishing in Victoria
Compare these figures with those produced in the RFA Comprehensive Regional Assessment Report where on p82
"In 1995-96, tourism and recreation (calculated as the sum of cultural and recreational services, and accomodation, cafes and restaurants) contributed around 3.8% ($4.2 billion) of Victoria's gross state product (ABS 1996). For the same period, employment in the recreational, personal and other services accounted for 7.5%, or 142 900 people in the State. . . In 1995-96, cultural, recreational, personal and other services employed over 10 200 people or 10.4 % (a rise from 1677 in just 5 years - see page 10 of RFA Assessment Report) of the total employment in the Gippsland region. This did not, however, include the contribution of tourism and recreation to the retail and wholesale industries. Combined, these industries were the largest employer in 1995-96 in Gippsland, employing approximately 18 300 people, or 18.5% of the total workforce . . . Tourism is significant to the local economies of many centres in Gippsland. In towns such as Lakes Entrance, Metung and Bairnsdale, significant investment has been made in facilities for accomodation and entertainment including fishing, boating and cultural opportunities (USE 1996). The direct value of the Gippsland Lakes area to the tourism industry is approximately $200 million per year (EGCALP 1997). . ."
According to the Fisheries Economic Impact Studies
Economic Impact of Recreational Fishing in Victoria July 1997 - Fisheries Victoria, a major proportion of this amount must have been generated by recreational fishermen, but the RFA submission document fails to mention recreational fishing in any detailed manner. (ie p84 "More than half the visitors to Gippsland travel for holidays or to visit friends and relatives Table 8.2 Most Popular Visitor Activities in the Gippsland Region, 1995").
In fact when fishing is discussed at all it is the only mentioned in terms of minor detail. (ie p84, p87, p100). Surely a recreation which is so important to the economy of Gippsland requires a more detailed analysis than what was given in the RFA Comprehensive Regional Assessment Report.
Now I will would like to focus on the issue of stream ecology and the fact that if the rivers silt up due to poor management in catchments, through activities such as forestry, fishermen will miss out, with fly fishermen being the first to go.
A forest is more than just trees. It is an incredibly diverse series of ecosystems connected by a countless array of complex interactions. And one fact often overlooked by the timber industry and conservationists alike is that forests are vital for the long term health of our water resources. Poorly planned plantation and native forest harvesting can have serious impacts on our waterways.
"The major single cause throughout the world of the extinctions of populations of fish (and indeed most other species of both plants and animals) is the destruction of habitat". Dr Peter Maitland.
A stream is completely dependent on the surrounding land and vegetation in its catchment and is consequently subjected to the effects of actions carried out there. A stream is a system of habitats linked together in a continuous one-way flow of water, so the actions on a stream at one point can also affect areas downstream. The majority of native freshwater fishes occur in rivers and streams which form most of the freshwater acquatic habitats in Victoria.
There are an enourmous number of invertebrates (animals without backbones) that live in streams. These include Mayflies, stoneflies, caddisflies, alderflies, craneflies, blackflies, dragonflies, aquatic worms, snails, small spiders (called watermites), crustacea such as yabbies, nematodes, flatworms, freshwater sponges and freshwater crabs. Many invertebrates such as mayflies hatch from eggs in the water. The invertebrates are found mainly attached to and amongst snags, leaf packs and rocks. Leaves falling into the stream are eaten directly by invertebrates known as "shredders", such as some stonefly and caddisfly larvae, which shred or bite the softer parts of the plant material. Material not consumed by the shredders is colonised by microorganisms such as aquatic fungi and bacteria and broken down to progressively smaller sizes. Freshwater algae also colonise the leaves and twigs. Invertebrates known as "scrapers", such as some mayflies and snails feed directly on the fungi and algae. As the organic material is broken down, the resultant finer material then serves as a food source for other invertebrates which filter material from the water (filter-feeders), or collect deposited material on stream beds (detritus-feeders).
These animals, in turn are preyed upon by other invertebrates and animals such as fish and platypus. Fish are then a food source for water birds and other fish-eating animals. Insects and other terrestrial invertebrates which live in the riparian vegetation and fall into rivers and streams form a substantial part of the diet of many native and introduced fish species.
Newly emerged mayfly adults need bushes near the stream to rest. Trees protect the swarms of mayflies from wind. Other material from trees such as leaf litter, is utilised by blackfish larvae/juveniles as nursery grounds, providing their food source and shelter. As well as providing instream habitat (such as fallen logs, branches, bark, leaves and submerged tree roots etc), the root systems of riparian (riverside) vegetation bind streamside substrate, preventing erosion and hence high turbidity levels and increased siltation. Without streamside vegetation the entire food chain is at risk.
As freshwater ecosystems get silted up, there is a decrease in diversity of macroinvertebrates, often decreasing to just populations of worms which can survive in the silt bed. Problem fish such as European Carp are best suited for seeking out these worms as Carp have a bottom grubbing feeding style.
The major effect of sedimentation is the blanketing of the stream bed (substratum) and the filling of pools and scour holes. Clogging of the stream bed removes spaces between particles which are used as rearing and habitat areas by juvenile fish, small species and stream invertebrates. The eggs of species such as Macquarie Perch (Macquaria australasica) which are deposited in gravel substrate are liable to smothering by sediment. Silt clogs mayfly gills and smothers the bed of the river (where they live) and kills algae growing on rocks (their food). Deposited silt can suffocate and kill Blackfish eggs. High turbidity levels can be lethal to blackfish larvae and juveniles. Even adults have been observed dying in highly turbid river water, their gills clogged up with fine sediment. Heavy siltation can also smother habitat, spawning grounds and food sources and can move into estuaries, smothering fish breeding grounds, particulary after periods of high rainfall..
Adult blackfish for instance live in submerged hollow logs or amongst a clump of logs/branches (called snags) or submerged tree roots. Hollow logs are used for breeding which occurs in early summer. A female and a male pair up, the female laying several hundred sticky eggs which attach in layers to the bottom of the inside of the log. Only about 500 eggs nearly 4mm in diameter are laid by a 300mm female. The eggs are then guarded by the male (not the female), who also fans away any silt which may settle on the eggs. Depositing eggs in less suitable areas such as sediment covered logs will lead to reduced egg and larvae survival.
"The most common environmental change caused by land use activities in the catchments is an increase in sediment input to rivers and streams. Increased levels of sediment can adversely affect all aspects of freshwater ecosystems by reducing water quality and degrading or destroying habitat. Increased turbidity or suspended sediment can have adverse physical, physiological and behavioural effects on stream-dwelling flora and fauna". Page 200 Gippsland - Comprehensive Regional Assessment - September 1999. Published by the joint Commonwealth and Victorian Regional Forest Agreement (RFA) Steering Committee.
Sediment (particles of material suspended in the water column or deposited in the stream bed) is a natural component of rivers and streams. Natural erosion and decay processes constantly deliver sediment to streams, so that all waterways carry some level of sediment. This is normally low in upland streams, but can be relatively higher in lowland rivers. Artificially increased loads of sediment, resulting from human activity, can have adverse effects on both the physical form of the river, and aquatic flora and fauna.
Timber harvesting is one human activity that increases sediment levels in river and streams. Depending on soil types, a lot of sediment can be washed into rivers and streams during periods of high rainfall when overland flow is generated.
The Cooperative Research Centre for Catchment Hydrology (CRCCH) has recently concluded that the main source of sediment from timber harvesting is i) unsealed roads, ii) snig tracks, iii) log landings, iv) general harvesting areas. In regards to roads and tracks “more than 80% of the rain that falls onto these surfaces is converted to runoff. These large volumes of water transport sediments through the landscape” and “Only about 10-20% of rainfall is converted to runoff in general harvesting areas, limiting sediment transport to short distances”
This difference is attributed to the fact that general harvesting areas retain a high percentage of vegetation and contact cover meaning that water accumulates more slowly. (Although it has to be said that on many clearfelled coupes that vegetation is limited and in some plantations I've witnessed in the Strzelecki's there is barely any vegetation of any kind left after harvesting at all).
The CRCCH also found that “*Sediment concentrations in road runoff were between 5 and 8 times higher on well-used roads than abandoned ones. *Roads with higher intensity traffic have greater volumes of loose material available at the surface. This is replenished after each rainfall event by continuing vehicle usage. *Roads used infrequently or abandoned have little available sediment and, in the absence of traffic are minor sources of sediment.”
The key is to minimise the impact of sediment delivery pathways. For instance the CRCCH found in the Cuttagee Creek Catchment in NSW “has an additional 10km of stream channels or gullies due to gully inititiation at road drainage outlets and because of these new channels, some 31% of the natural stream network now receives runoff and associated pollutants from road drainage outlets. 83% of gully initiation occurred at relief culverts draining cut-and-fill roads and that the combination of large contributing road length and steep hillslope gradient results in erosion and gully formation at the road-drainage outlet”. Thus it is crucial that roads must be sited away from streams.
According to the CRCCH “best management practices have to be applied in every logged forest to manage these sources and pathways." These practices include: *establishing riparian buffer-strips of variable width, *harvesting alternate coupes, *siting and designing roads and road crossings to minimise sediment input and *restricting logging activities in relation to coupe slope and soil type.
All forestry operations are supposed to be carried out in accordance to the Code of Forest Practices. There are two types of standards for public and private land. Generally the Code for private land is less strict. Standards in the Code are often a bare minimum. Department studies to justify catchment management are not accountable to peer review making independent analysis of the Code invalid. 20 metre buffer zones are inadequate and in many plantation areas there are no streamside buffers at all. Rivers and streams deserve much wider buffers.
In regards to the RFA Comprehensive Regional Assessment Report there is reference made that if the Code of Forest Practices is adhered to then water quality will not suffer.
p18 "The Victorian Parliament ratified the Code of Forest Practices for Timber Production (the Code) in May 1989 in accordance with section 55 of the Conservation, Forests and Lands Act 1987."
p18 "Since its implementation in 1989, several reviews of aspects of the Code have been undertaken (Victorian Auditor-General 1993; CNR 1995a, CNR 1995b, CNR 1995c; O'Shaughnessy 1995). Revision No. 2 (NRE 1996a) of the Code was developed by NRE involving scientific review and community consultation. This included a review of the Code by CSIRO based on scientific evidence, experience and observation of its effectiveness in achieving environmental care. The revised Code was ratified by Parliament in December 1996."
p19 "In general, the Code is implemented at a local level through a set of regional prescriptions. These detailed prescriptions take account of local conditions such as climate, forest type, topography, elevation, soil type, and various management activities. They must be consistent with the Code, based on relevant scientific input, and reviewed periodically. Regional prescriptions for the Forest Management Areas in Gippsland region were reviewed in 1997-98 to incorporate the requirements of the revised Code (NRE 1996a)."
p70 "Plantation management in Victoria must comply with the Code of Forest Practices for Timber Production (Code) (NRE 1996a). The Code provides Statewide goals and guidelines for plantation establishment and management, and a number of Statewide minimum standards (such as set back reservations along streamsides)."
p71 "Compliance with the Code on private lands and public land vested with the Victorian Plantations Corporation (VPC), including plantations licensed to Hancock Victorian Plantations Pty Ltd, is requiredthrough Planning Schemes admistered under the Planning and Environment Act 1987. Monitoring of operations on these lands is the responsibility of local municipalites through their planning scheme provisions."
p71 "The Victorian Code and associated controls have been accredited by the Commonwealth Government as the basis for removing export controls on plantation products."
p104 "The Code of Forest Practices for Timber Production (Code) requires that water quality and yield are protected in water supply catchments. . . Where Special Area Plans do not exist or specify minimum standards, the Code or regional prescriptions provide minimum requirements for seasonal closures, stream buffers, filter strips and slope limitations. Minimum widths for stream buffers and fliter strips are a function of the soil type, stream class and slope, and can vary from 10 to 40m depnding on soil permeability and potential for overland flow".
However there is no in depth discussion in the Comprehensive Regional Assessment Report about the Code and the absolute need to maintain filter and buffer strips from all logging. For instance on page 21 of the Code it states that "trees located in filter strips may be felled". This statement does not have the best interests of the waterways at heart. Filter strips in my opinion should be increased, as should buffer zones in all forest coupes. Loggers should not be given the opportunity to risk any increase in sedimentation entering our waterways. The Code in relation to private forests and buffers etc page 48 is quite appalling. Quite clearly a timber operator reading the Code in a minimalist way can log buffer strips and filter strips. This interpretation of the Code by private forest growers is leading to absolutely massive water quality problems in the Gippsland RFA area. It should also be stated that recent logging activities in public forests, for probably the last 5 years, have focused on ridges and slopes higher up in the catchments. This means that the streams upstream of these coupes are impacted and often do not have any flowing water. This is quite serious meaning that streamflow generated in the headwaters of creeks etc is reduced, meaning that less quality water is entering the catchments.
The Assessment report mentions on page 112 "However, some of the road network established prior to the Code, does not meet current standards and therefore is a potential source of sediment". This is correct, the existing roading network on many areas of private land is appalling, but many new roads and snig tracks are sub-standard as well. Much work needs to be done to tighten up roading on private land. From my observations I can generally say that roading on public forests is of a higher standard than those roads on private land.
In 1988 The State of the Environment Report on Victoria’s Inland Waters wrote that “Overall, this impact on the aquatic environment is characterised by *potentially greater input of particulate matter over time due to the increased frequency of harvesting and soil disturbance, *greater reduction in water yield and streamflow due to greater water requirements of softwood forests, *potentially greater contamination of waterways resulting from the aerial application of biocides and fertilisers, and their transport to waterways and *Changes in the diversity and abundance of macroinvertebrates, deriving from changes by pine plantations in the composition of organic matter entering streams”.
On page 70 of the Assessment Report "The total plantation area in the Gippsland region in 1998 was approximately 85 700ha. Of this area, some 54 000 ha are owned by Australian Paper Plantation Pty Ltd (APP), 26 000 ha of plantation are owned by Hancock Victorian Plantations Pty Ltd, and some 5 700 ha are in private ownership (GFP 1998)." This is a vast holding of land. I have personally witnessed some truelly horrendous logging occurring on private land owned by both Amcor and Hancock. Some of Amcor's plantations have no buffer zone on streams at all, meaning that huge amounts of sediment can wash into creeks after rainfall. This problem is increased due to the steepness of many of these plantation sites. Amcor should be made to revegetate all their buffer zones and steep hillsides with indigenous vegetation and then retire those areas from timber harvesting permanently. This is the only chance we have if we are to save the waterways and downstream water users including fishermen.
The Hancock situation is an ecological disaster, with that company targeting and then logging, the best of what remains of indigenous vegetation left in their land holdings. I have personally witnessed buffer zones and filter strips logged and remnant old regrowth cleared by that company, acting in total knowledge that local councils will find it next to impossible to prosecute breaches of the Code of Forest Practices due to the watering down of the Code. The fact that Hancock now controls the headwaters of numerous rivers and streams in the Strzeleckis will have long term impacts on the freshwater ecology of the region for many years. From details released by the Australian Securities Commission it shows that Ian Ferguson - Professor of Forestry at Melbourne University is a director of Hancock Victorian Plantations. The fact that a fellow with wide spread respect from many in the forestry field is a director of a company which is acting so environmentally irresponsibly is a sad inditement on the state of forestry in Victoria.
I understand that the timber sourced from Hancock's holdings in the Strzelecki's is sent to the Planthard mill in Morwell, where they have a licence to cut 100,000 cubic metres each year. 40,000 cubic metres of woodchips is sent to Amcor's Maryvale mill from Planthard. This amount is clearly unsustainable. On what basis was Planthard granted the rights to cut such an enourmous amount of timber? I understand that Planthard is owned by the Thomas P Clark group of companies whose Victorian directors include Roger Clark, John Clark and Lorraine Clark.
In 1996 a company called Fitzmaurice Pty Ltd directed by John and Roger Clark sold their office and land in South Melbourne to Crown Casino for $10,500,000. Crown Casino needed that land for their carpark. At this stage the Clark's apparently had invested some $20 million in refurbishing the SECV site in Morwell to begin their Planthard business, which incidently is the largest hardwood sawmill in Australia. Planthard signed a deal from the Victorian Plantation Corporation to access timber from the Strezlecki's.
A inaugral member of the VPC board was George B Little who left his position of Deputy Director of the Victorian Casino and Gaming Authority in 1993. Given that the sustainable yield calculations have been proved to be erroneous (see Age Newspaper Page 13, 16/2/00) and that VPC was brought out by Hancock, a subsidiary of the John Hancock Mutual Life Insurance Company, what happens if the sustainable yield from the Strzelecki's just doesn't add up. Does this mean that Hancock will have to cut every stick of timber out of the Strzelecki's to meet their licence agreements? Does it mean that Hancock will have to be given access to State Forests to meet this shortfall in demand. Already the Radcon mill in Yarram has been adversely affected by the sale of the state's plantations to Hancock. What impact will this forestry have on wildlife and the waterways of the Strzelecki's? The prognosis doesn't look good.
Increased levels of sediment can adversely affect all aspects of freshwater ecosystems by: reducing light penetration, increased loads of nutrients and toxic substances attached to sediment particles, clogging gills and causing asphyxiation, causing illness and reduced growth rates or death through ingestion, reduced visibility, filling spaces in the river bed and destroying important habitat, working its way into the stream bed, interfering with feeding by organisms that filter food from the water column, destroying attachment sites for animals and eggs, smothering plants.
Erosion often liberates soluble nutrients, but also sediment particles have nutrient molecules attached, which ultimately pollute the river system. Logging also effects water yield which in turn effects the temperature of the water, thereby placing further pressure on species dependent on fresh, clean water. Reduced streamflows may exacerbate water quality problems. In regards to the Otways, Otways Ranges Environment Network found that logging on an 80 year rotation basis would reduce water yield by 25 to 33% because young trees require large amounts of water to grow. In April 1998 the (CRCCH) published the results of a five year analysis of water yields in Mountain Ash forest catchments. The study concluded that old growth Mountain Ash forests have almost twice the water yield of young regrowth forests resulting from clearfelling or wildlife regeneration.
In regards to plantations it could be argued that the environmental impact of softwood and eucalypt plantation forestry is more severe on waterways than timber harvesting in native forests. This is due to logging rotations in plantations being between 15 and 40 years meaning that there is more silvicultural tending and that “growing pines appear to make a larger impact on water yield than do regenerating eucalypts”.
It is encouraging that the Assessment Report looks into the water yield issue; eg's
p108 "The potential for forest management activities to impact water quality and quantity, and aquatic values is well recognised."
p109 "The effects of 'best practice' forest harvesting and regeneration operations on water yield and water quality were investigated in the Corranderrk Experiment. . . The results to date indicate that water yield in the selectively felled catchment declined less than in the clearfelled area. However, the more intensive road network of the selectively felled catchment affected water quality for 10 years, compared with five years for the clearfelled catchment."
p109 "A study by Grayson in catchments in the Central Highlands concluded that the impact of well supervised timber harvesting on water quality is small. They noted that the suspension of logging during wet weather, the use of buffer strips, and the management of runoff from roads, snig tracks and log landings, eliminated contaminated runoff into streams."
p109-110 "O'Shaughnessy and Associates (1995) noted that roads and tracks might present a greater hazard than timber harvesting with regard to sedimentation of streams. Preliminary results of monitoring in the Traralgon Creek catchment by Sadek et al. (1998) showed that the existence of unsealed roads and associated landslides in forested catchments have an impact on stream turbidity and sediments. The research by Grayson et al. (1993) and work by Haydon et al. (1991) also suggests that there is a positive relationship between the frequency of road use and the production of coarse sediment and total sediments. This highlights the need for high standards of road construction and management to help prevent the entry of runoff into streams (Haydon et al. 1991). Also Dargavel . . . "
p110 "The literature demonstrates that different silvicultural systems have different impacts on water yield and quality within harvesting areas . . . Hydrological resaerch in the Central Highlands also indicates that large-scale regeneration or reforestation activities following timber harvesting or wildfire may reduce long-term water yields in Ash forests (Kuczera 1985), as young, fast growing forests use more water . . . As the forest regenerates, water yield decreases to a minimum of about half the original yields at 20-30 years and then steadily increases to pre-fire yields at around 150 years . . . Kuczera (1985) also showed that for every one per cent of mature forest converted to regrowth, a decline of 6mm in annual water yield could be expected some 30 years later."
However there is a lack of information in the Assessment report about the impacts of both a decline in water quality and quantity and its impacts on freshwater species. If there is less water there is likely to be less fish, thereby impacting on both the economy and ecology of the Gippsland region.
The following information was taken from SSP Technical Report No 5 - A Review of Australian Studies on the Effects of Forestry Practices on Aquatic Values. TJ Doeg and JD Koehn Fisheries Division September 1990. I did not see this publication listed in the Gippsland RFA bibliography, it should have been there.
West Barham Catchment - Otway Ranges
p6 "Mean stream turbibity (over all samples) was significantly higher in the harvested catchments than in the unharvested sub-catchment of similar size. Mean filterable solids were also significantly higher in samples from the larger disturbed catchments, but not in the smaller subcatchments . . . " p7 "The intensive post-flood sampling upstream of the monitoring sites suggested that poor drainage from compacted areas such as logging roads, snig tracks and log landings, and the influence of land slides and debris torrents were responsible for the elevated turbidity records in the harvested catchments."
p9 "In the Picaninny Creek, the concentration of suspended solids increased marginally following clearfelling, but the increase did not persist. Sediment trapped behind the Picaninny weir showed that total export of suspended material increased from 40kg/ha/annum in the pre-treatment phase to a peak of 90 kg/ha/annum in 1974, followed by a rapid return to pre-treatement levels. Additional water samples taken within the catchment showed that the increase in suspended sediment was caused by run-off from a road crossing, and not from the clearfelled area itself."
p12 "Although water quality parameters were not measured, soil erosion "increased greatly after the logging operations"
p17 "However, suspended sediment concentrations in Strinybark Creek during logging were considerably higher than in other as yet undisturbed catchments, with the actual increases being variable and differing between storms, but in the range of 0 to 300%. Estimates of suspended sediment loads also showed an increase of 150% in the disturbed catchment in the first storm after the start of treatment, but the loads appeared to be reducing towards the end of the logging."
p20 "Following clearing of the eucalypt forest, storm run-off increased by an average of 40% compared to the uncleared eucalypt catchment, and more than doubled in one of the cleared pine forest catchments . . ."
p28 "No changes in flow-weighted mean annual sediment concentrations could be determined in the April Road North Catchments, and only a small increase occurred in the year of logging in the Yerraminnup South catchment (however, larger increases were noted in this year in the control Yerraminnup North catchment). In both cases, buffer strips of 100 m and 50 m respectively had been left along the stream banks . . . "
p29 "Suspended sediment concentrations were elevated by a factor of 3 to 5 in all four catchments following cutting, reaching a maximum two years after logging, then declining in the following year due to lower rainfall and revegetation."
p32 In the Sutton trial,
where the buffer strips were completely removed, there was an increase
in organic material accession and sand deposition from road surfaces
to the stream, particulary at road crossings.
This somewhat altered the flow path and channel morphology in
the two years following the trial.
Some bank collapse was caused by trees falling across the stream
channel during logging. Algal blooms were also noted following
the trial .
Logging can also cause increased nutrients entering waterways. Algal blooms are a result of nutrient enrichment which has become a problem throughout Australia. These blooms are caused by a combination of the build up of nutrients and reduced water flows. Excessive algal growth deprives waters of oxygen, resulting in slimy, smelly water which kills fish and causes rashes and eye irritations in humans. Algal blooms can also make fish toxic for human consumption. The recent Gippsland Lakes bloom resulted in the suspension of commercial prawn fishing from both the Lakes and nearby ocean waters. Runoff from logging (including the application of fertilisers) contributes to algal blooms as does sewage and agricultural effluent.
As mentioned earlier, the amount of time devoted by the RFA process to look after the long term interests of waterways that are affected by logging activity, especially in the headwaters of many catchments, seems to have been neglected. I have selected the following quotes from the Assessment document that not enough information is at hand to be making long term decisions regarding forest agreements, when the impacts of those agreements on fish and macroinvertebrates are unknown. It is also disturbing to note that the RFA is being pushed through to be signed by March 31st, when two important studies relating to fish and macroinvertebrates will probably not be published by the Department of Conservation and Natural Resources until June this year.
More research needs to be done in relation to both matters and it appears from the invertebrate studies that the dataset is sub-optimal. Tentatively it could be said that research is leading towards suggestions that logging activities do impact on macroinvertebrate communities, however some insect populations increase downstream of logging coupes due to small increases in light, nutrients and organic debris. However much more research is required. There is also a lack of budget within the Department of Natural Resources and Environment to conduct widespread surveys. Budget cuts over the past few years have severely impacted on the Department. In researching for this submission I was alarmed that much of the research done in this area was done during the eighties.
p113 "Increased stream sedimentation is regarded as a threat to species such as the Spotted Tree Frog and Giant Burrowing Frog. Therefore management prescriptions, including special requirements, are in place for stream buffers, roads and stream crossings in catchments containing these species."
p198 "Twenty-one freshwater fish have been recorded in the Gippsland RFA Region to date, and 15 are known or suspected to migrate as part of their life cycle. There are insufficient data to estimate the total number of macroinvertebrate species in the Gippsland region."
p199 ". . . However, significant data gaps exist on life history and population characteristics for all priority fish species. The most significant gaps relate to spawning behaviour, including induction cues and location of egg laying sites, both within the catchment and within the stream. There is also limited data on cues for migration, preferred larval habitats, and reactions of priority fish species to disturbances, particulary increased sediment and turbidity."
p199 "There are still considerable gaps in the knowledge of aquatic macroinvertebrates in the Gippsland RFA Region. The lack of adequate distributional and historical data makes it almost impossible to identify other taxa that may qualify for inclusion in a priority list. Almost no comprehensive data are available for life histories of priority aquatic macroinvertebrate taxa (and most other macroinvertebrate taxa as well)."
p199 "Of the 21 native freshwater fish species recorded from Gippsland, 7 are listed as threatened fauna in Victoria (NRE 1999b), five of which are listed under the Flora and Fauna Guarantee Act 1988, and one of which is listed under the Commonwealth Endangered Species Protection Act 1992."
p199 "Eight aquatic macroinvertebrate species known from Gippsland are listed as threatened in Victoria (CNR 1995f), with two of these listed under the Flora and Fauna Guarantee Act 1988".
p200 "Priority Aquatic Fauna Species Occurring in Gippsland
Mountain Galaxias, Dwarf Galaxias (FFG), Striped Gudgeon, Cox's Gudgeon (FFG), Macquarie Perch (FFG), Australian Mudfish (FFG), Australian Grayling (FFG/ESP), Lilly Pilly Burrowing Cray, Narracan Burrowing Cray (FFG), Strzelecki Burrowing Cray, Alpine Spiny Gray, South Gippsland Sping Gray, Dragonfly (FFG), Caddisfly, Stonefly"
p201 "While the potential impacts of these activities and associated environmental changes are well established, few scientifically derived data are available that directly relate the impact of most activities to any of the priority aquatic species. Therefore, in most cases, the impact on priority species in Gippsland needs to be predicted from the results of studies conducted elsewhere. While specific date relating activities or disturbances and the impacts on priority species may not exist, sufficient information is available to adequately predict the likely impacts on priority species in the Region."
As stated earlier, the Gippsland Comprehensive Regional Assessment Report has done very little to ensure that the aquatic values of streams in the Gippsland RFA region will be adequately protected in the future. The following references, none of which appear in the Assessment Report bibliography, provide an opportuntity to understand the complexities of protecting the fauna which rely on the waterways for their survival. One has to wonder why most of these texts weren't considered in the drafting of the Comprehensive Regional Assessment Report. As it stands the Regional Assessment Report is fundamentally flawed for ignoring the majority of these reports.
Daily flow rates to maintain optimum habitat for fish assemblages in the Tambo River, Gippsland: a preliminary assessment. P.N. Hall & D.J. Harrington - Feb 1991 - Flora and Fauna Division, Vic.
(ii) "In the Tambo River system the species of the highest conservation values and the most abundant of the larger native species was the Australian Grayling (prototroctes maraena) a species classified as 'vulnerable' and listed under the State Flora and Fauna Guarantee Act (1988)."
p5 "Specimens of four native and one introduced fish species were collected at the four sites . . . 14 native and 3 introduced fish species have been collected from the Tambo system and its main tributaries, during 1969-91 . . . species which have a relatively unrestricted distribution throughout the system. Blackfish, tupong, common galaxias, smelt and both species of eel."
p6 "Species which appeared to be primarily restricted to the rivers middle and lower reaches (southern pigmy perch, estuary perch, Australian grayling and both species of lamprey. Species restricted to upper reaches - spotted galaxias, rainbow trout (brown trout)."
p9 "Preservation of the Tambo River's population of Grayling is of fundamental importance, especially because of lack of understanding of grayling genetics (Brown 1983) and the life cycle which is presumed to include a larval marine phase (Berra 1987). The grayling population of the Tambo River is believed to be a major breeding population and probably directly influences the distribution and abundance of the species at least across eastern Victorian rivers . . . Of particular importance are the adverse effects of poor water quality during low-flow summer months and maintenance of suitable flows and conditions for spawning and subsequent transfer of larvae to the rivers lower reaches during late autumn."
p10 "The Tambo River is also important because it supports a population of Australian Bass at the westerly limit of the species known geographic range. Currently classified in Victoria as potentially threatened, this species depends on seasonal high-flow events and unobstructed passage".
p15 "Fish surveys in Victoria's coastal rivers and streams during the last 20 years indicate that grayling is relatively more abundant and more consistently present in the Tambo River than in other waters surveyed. The Australian grayling is listed under the State Flora and Fauna Guarantee Act which is a state government committment to maintain important grayling habitat or to restrict processes considered to threaten the species".
p15 "Populations of spotted galaxias - a species classified as potentially threatened in Victoria are believed to occur in tributaries of the Tambo River and are known to have a marine juvenile phase . . . "
Management Plan for Freshwater Fisheries in Major Gippsland Rivers.
Water Resource Requirements D.N. Hall Jan 91
p14 "Of particular significance to water resource management in the study area is the presence of populations of Australian grayling in the Snowy, Tambo, Mitchell and lower Thomson rivers. The relatively patchy or restricted distribution of grayling now compared with that last century has been ascribed largely to water and land management practices (Jackson and Koehn, 1988)."
p16 "High priority is therefore directed towards maintenance of grayling habitat, provision of access by migrating larvae and juveniles to and from the estuaries, and maintenance of suitable flows and water temperatures during and immediately following spawning by grayling."
p16 "The freshwater populations of the Mitchell (sites 20,21) (please note that these sites are now protected under the Heritage Rivers Act), the Snowy (sites 25-22) and Tambo Rivers (sites 36-40) had the highest conservation values. Safeguarding the Mitchell River was given top priority because fish distributions in the Snowy and Tambo Rivers were deduced largely from fish collections . . . The lower Thomson (site 14) has been assigned a high conservation value because of the presence of grayling . . . Sites between the Thomson Dam and Bruntons Bridge (sites 31-35) were classified at the head of the average category because of their unusually high proporation of large blackfish (please note that these sites are now protected under the Heritage Rivers Act). The upper Latrobe River and its tributaries (Mowell and upper Tyers Rivers) had relatively high proportions of blackfish, as did the Thomson above Cowwarr (site 15), Glenmaggie Creek (site 18) and the Tanjil River (sites 27-28) . . . The Aberfeldy River (sites 29, 30) was given a higher conservation ranking than would be expected . . . owing to the catchment's excellent condition."
p17 "The State of the Environment Report 1988 (Ministry for Environmental Planning 1989) tabled a series of estimates of use (angler/day) for each river catchment across the state . . . the resulting estimates suggest that the Latrobe and Tambo basins each catered for 150 000 angler days per annum, and the Snowy, Mitchell and Thomson basins each catered for 100 000 angler days per annum."
p17 "The Upper Latrobe River (5-7) contained the best of the 'average' fish populations for anglers . . . The Thomson River downstream from Thomson Reservoir to Brunton's Bridge (31-35) (most of this area is now protected under the Heritage Rivers Act) and the Aberfeldy River (29-30) (most of this area is now protected under the Heritage Rivers Act) contained fish populations with the highest proportions of 'size' angling species. Better than average angling opportunities were also identified at Glenmaggie Creek and at sites on the Morwell (site 10), Tyers (site 12) and Tanjil (site 28) rivers in the Latrobe River catchment."
Preliminary assessment of daily flows required to maintain habitat for fish assemblages in the Latrobe, Mitchell and Snowy Rivers, Gippsland. Douglas N. Hall July 1989. Technical Report Series No. 85
p16 "Information on the occurence and distribution of fish species in the Latrobe, Thomson, Mitchell and Snowy Rivers is available from the results of surveys conducted during the 1970's and early 1980's (Tunbridge and Gleane 1982). A systematic fish sampling program was undertaken during the present study to determine the distribution and relative abundance of fish species at each of the 22 flow study sites and an additional 3 fish survey sites nominated by the DWR."
p18 "Ten native and four introduced fish species were collected from the Latrobe River and tributary sites. Previously 15 native freshwater fish species have been collected during fish surveys of the Latrobe system including the following species not collected in 1988 - Australian Grayling, broad-finned galaxias, dwarf galaxias, striped gudgeon, blue spot goby and non-parasitic lamprey and 6 introduced species. Species found included Australian smelt, Blackfish, Estuary Perch, Long finned - eel, short finned eel, short headed lamprey, southern pigmy perch and trout, carp, perch, mosquito fish."
p20 "A depauperate fish fauna - both in species richness and fish numbers was encountered from Rosedale up to Lake Narracan area mainly smelt, carp and english perch."
p21 "The fish populations of the Latrobe River downstream of Lake Narracan have decreased dramatically both in terms of numbers of fish and also biomass over the last 15 years. "The presence of relatively large numbers of blackfish, trout and small species such as smelt and pigmy perch upstream from Lake Narracan - combined with an absence or scarcity of these species and the decreased carrying capacity of the lower section of the river since 1973 . . . indicates that the ecology of the Latrobe downstream from Lake Narracan has undergone a substantial change over the last 15 years."
p21 "A hypothesis to explain the recently observed distribution of fish in the Lower Latrobe concerns the annual load of suspended solids. Poor land use practices, removal of river bank vegetation and instream debris, substantial daily flow variations induced by stream regulation, meander cuts and a variety of other industrial, agricultural and river management practices have had the cumulative effect of substantially increasing the sediment load of the river. Increased levels of sediment in streams can have a direct effect on fish populations by decreasing the survival rate of demersal embryos (Cooper 1965), by reducing rearing and reproductive habitat for juvenile and adult fish (Bjorn et al, 1977, Berkel and Rabeni 1987), by abrading gill and other tissues, by interfering with determined behavioural responses such as feeding and avoidance, and finally by reducing the stream's capacity to produce or provide food organisms.
Recent studies of increased sedimentation in streams have consistently indicated dramatic changes in species composition, diversity and total numbers of invertebrates which can be attributed to the effects of physical abrasion by organisms by suspended sediment, smothering of suitable habitat, reduction in the capacity of smothered areas to produce food organisms and the alteration of behavioural responses like drift (see Hall 1988)."
p22 "The invertebrate communities of the Latrobe downstream of Narracan are impoverished both in terms of species diversity and biomass. Robinson (1988) attributed changes in the species diversity of aquatic invertebrates downstream of Lake Narracan to increased loads of suspended sediment, altered substrate types and flow regulation practices."
p23 "The unstable and mobile nature of the Latrobe river bed below Lake Narracan, combined with the river's load of suspended sediment and subsequent impoverished macro-invertebrate fauna could provide a convenient explanation for the observed numbers of species composition of the fish fauna. Freshwater blackfish and tupong are primarily benthic insect feeders and their absence might be attributed to the lack of suitable food or their inability to locate sufficient food items."
p25 "11 native and 4 introduced species were collected from the Thomson River and tributary site. During previous surveys by the Fisheries and Wildlife Department a total of seven native and 3 exotic fish species were recorded in the Thomson River. Found Australian Grayling, Australian Smelt, blackfish, long finned eel, short finned eel, estuary perch, flat headed gudgeon, common galaxias, mountain galaxias, southern pigmy perch, tupong + brown trout, carp, english perch, mosquito fish)."
p29 "11 species of native freshwater fish were collected from the Mitchell River and no introduced species were encountered. Previously 7 native and 2 exotic species of freshwater fish have been recorded from the Mitchell. Found Australian Grayling, Australian Smelt, blackfish, long finned eel, short finned eel, estuary perch, flat headed gudgeon, short headed lamprey, common galaxias, southern pigmy perch, tupong + brown trout, carp, english perch, mosquito fish)."
p36 "The behavioural and life history activities of freshwater fish species can be divided into 4 major categories; rearing, resting, spawning and passage. Each of these activities require particular habitat features and are considered seperately."
p37 "Rearing habitat is arguably the most critical habitat type to be preserved while considering flow reductions. It invariably emcompesses the largest area of habitat in a river . . . food sources for riverine fish species can be arbitrarily divided into 2 categories - riparian for terrestrial and instream. Riparian habitat generally harbours diverse and abundant terrestrial insect fauna which commonly contribute as fish food by flying, falling or crawling to the surface water and thereby becoming available to fish."
p38 "Aquatic invertebrates are the major components of the diet of most native freshwater fish species inhabiting Victorian coastal streams. Clean gravels and cobbles in riffles are often the most productive areas in a river for macroinvertebrates . . . Aletrnatively for those rivers or sections of rivers with predominately sand substrates most invertebrate production is usually associated with instream debris such as rocks, twigs and leaves."
p39 "There is very little quantitative information available on the resting habitat requirements of native Australian freshwater fish, or the proportion of time a species rests either daily, seasonally or with age . . . "
p95 "A period of at least 2 years is a minimum estimate of the time required to generate a comprehensive assessment of instream flow material . . ."
Please note, under the Flora and Fauna Guarantee Act, an Action Statement is required for species listed. However due to time constraints every species listed doesn't necessarily have action statements written for them. This is the case for the following species, meaning that proper management of environmental conditions pertaining to the safeguarding of these creatures habitat isn't happening on an ecological footing.
Flora and Fauna Guarantee - Scientific Advisory Committee - Nomination No. 3 Item No. A4041
Final Recommendation on a nomination for Listing
Prototroctes maraena Gunther, 1864 - Australian Grayling
Date of final recommendation: 22/5/91
Criterion 1.2 The taxon is significantly prone to future threats which are likely to result in extinction
What is known of the species' breeding patterns suggest that migration between river and the ocean is required (Hall and Harrington 1989); thus the SAC is satisfied that any threat to the river systems in which the species occurs causes a significant threat to its reproduction. Those few rivers where large populations are known to occur are threatened by possible water storage development which could create barriers to fish passage (Koehn & Morrison 1990) and by other developments, as none of the major catchments are within boundaries of National Parks. Predation by introduced trout is another possible threat (Koehn & O'Connor 1990).
-Categorised as "vulnerable" in Victoria by Baker-Gabb (1991), Koehn & Morison (1990) and Cadwallader et al. (1984).
-The species is considered by the Endangered Species Committee of the Total Environment Centre to be one of the most endangered of Australia's freshwater fishes.
-CONCOM recognises the species as endangered (Burbidge & Jenkins 1984)
-Harris (1987) identifies the species as being threatened .
-The viable size of Grayling populations within Victoria is not known. Few large populations have been found.
-A congenor of this species declined rapidly to extinction in New Zealand during the 1920's. Prototroctes maraena is therefore the only extant species in the family.
Flora and Fauna Guarantee - Scientific Advisory Committee - Nomination No. 304 Item No. A4155
Final Recommendation on a nomination for Listing
Gobiomorphus coxii Kreft 1864 - Cox's Gudgeon
Sub-criterion 1.2.1 The taxon is very rare in terms of abundance or distribution
Evidence: Only 18 specimens of Gobiomorphus coxii have been collected from a total of 10 sites in the state. The species is restricted to lowland coastal areas in south-eastern Victoria from the Franklin River in South Gippsland eastward to the New South Wales border, north-east of Mallacoota in East Gippsland
-Several potentially threatening processes which have either been listed (The increase in sedimentation input into Victorian rivers and streams due to human activities . . . may represent a threat to Cox's Gudgeon.
Flora and Fauna Guarantee - Scientific Advisory Committee - Nomination No. 141 Item No. A4055
Final Recommendation on a nomination for Listing
Galaxiella pusilla (Mack 1936) - Dwarf Galaxias
Criterion 1.1 the taxon is in a state of demonstrable decline which is likely to result in extinction
Evidence: The species has declined in a qualitative number of river systems. It has suffered a demonstrable decline in the Western Port area and in South Gippsland. Freshwater wetlands in this area have been reduced by 99% since European settlement.
The species occurs mostly in swamps and billabongs . . .
p76 "Habitat: Typically in still or slow-flowing waters such as swamps, drains and backwaters of creeks and streams; often in shallow water overgrown with aquatic plants. . . "Cadwallader, PL and Backhouse GN (1983) A guide to the freshwater fish of Victoria.
Flora and Fauna Guarantee - Scientific Advisory Committee - Nomination No. 266 Item No. I4802
Final Recommendation on a nomination for Listing
Engaeus phyllocercus Smith and Schuster - Narracan Burrowing Crayfish
Although Engaeus phyllocercus can be found in State forests within its range, its habitat has been substantially modified. Any activities which damage stream banks, alter drainage patterns and water table levels or remove remnant native vegetation represent a threat to the species.
Engaeus phyllocercus is found over a 30km2 area of the highland region of the Western Strzelecki Ranges in South Gippsland. Its burrows are typically found in the flood bed region of fern tree gullies in wet sclerophyll forest .
Biological Information for Management of Native Freshwater Fish in Victoria
JD Koehn WG O'Connor April 1990
Some other listed fish species from the Gippsland region
Pouched Lamprey (Geotria australis) - Potentially threatened
Freshwater Herring (Potamalosa richmondia) - Endangered
Broad-finned galaxias (Galaxias brevipinnis) - Potentially threatened
Spotted galaxias (Galaxias truttaceus) - Potentially threatened
Dwarf galaxias (Galaxias pusilla) - Potentially threatened
Australian bass (Macquaria novemaculeata) - Potentially threatened
Freshwater Fishes of Australia - Dr Gerald R. Allen
p189 "Cox's Gudgeon: Inhabits swift-flowing streams, often in rapids. Spawning occurs in summer. The eggs are deposited on rock surfaces and are guarded by the male until hatching, which requires 3-5 days. The larvae are washed downstream to lowland rivers and estuaries. Upstream migration occurs as the young fish increase in size . . . The species penetrates well inland to altitudes of at least 700 m. Food items include aquatic insects, crustaceans and other fishes."
p47 "Australian Grayling: Inhabits creeks and rivers, usually in cool, clear waters over gravel bottoms in sections alternating between pools and rapids. They often form large schools especially prior to spawning. The reproductive period is from late summer to autumn. Each female produces about 25 000 to 68 000 eggs that sink to the bottom just downstream of the spawning site. Hatching occurs in about 10-20 days. The newly hatched larvae are apparently swept downstream to estuaries or the sea where they remain for about 6 months before returning to fresh water to complete their life cycles. . . They eat small crustaceans, insects and their larvae and algae."
Technical Report No 52. - A review of biological information, distribution and status of the Australian Grayling (Prototroctes maraena) Gunther in Victoria PD Jackson and JD Koehn 1988
(iv) Key stages in the early life history, dynamics of existing populations and habitat requirements of Australian Grayling, especially during the first 6 months of life are poorly documented. It is not known whether discrete stocks of Australian Grayling ascend different freshwater streams or whether there is one stock which ascends streams at random after larvae have mingled in coastal waters. If the latter is the case, spawning may occur only in a few freshwater streams, making the species vulnerable to environmental alteration. None of the major catchments containing Australian Grayling are within boundaries of National Parks, thus no Australian Grayling population in Victoria is adequately protected.
p8 Results from the Tambo River in 1981 show that ripe grayling were present well upstream from the end of April until the end of May.
p9 the eggs settle in interstices of the gravel bottom
p11 the most frequent food items found were immature stages of aquatic insects such as chironoids, trichopterans and ephemopterans, gastropods and abundant plant material
p14 Due to the gaps in our knowledge of the life cycle and population genetics of the species, conclusions of the status of grayling based purely on distributional data should be viewed with considerable caution. Habitat requirements for first 6 months are unknown
p15 not sure whether the species can spawn in heavily silted rivers
p15 'thus there are no totally protected grayling populations in Victoria. All rivers known to contain grayling are susceptible to some form of habitat destruction in the future.
The following information in the Comprehensive Regional Assessment Report outlined the following issues regarding protection through Heritage Rivers etc.
p105 In the Gippsland region, the corridors of the Mitta Mitta, Mitchell and Wonnangatta and Thomson Rivers have been designated as Heritage Rivers and are protected under the Heritage Rivers Act 1992.
p106 Those catchments which have not been subject to physical or biological processes that leave the environment impaired or changed, have been designated as Essentially Natural Catchments. In the Gippsland region, seven catchments were identified and recommended as Essentially Natural Catchments: Avon, Turton and Dolodrook Rivers and Ben Cruachan Creek; Stony Creek, Wongungurra River headwaters, Blue Rag Creek, Pinnacle Creek, Punchen Creek and Mount Vereker Creek . . . A draft management plan for heritage rivers and natural catchments in Gippsland was released for comment in November 1997 (NRE 1997h). . .
p106 The Environment Protection Act 1970 provides for the declaration of State Environment Protection Policies (SEPP) for defined areas in order to maintain environmental quality sufficient to protect existing and anticipated beneficial uses. State Environment Protection Policies relevant to the Gippsland region include: *State Environment Protection Policy (Waters of Victoria) 1988, including Schedule F5 (The Latrobe and Thomson River Basins and Merriman Creek Catchment and Schedule F3 (Waters of Gippsland Lakes and Catchment) . . .
p202 Following the Land Conservation Council's (LCC) Rivers and Streams Special Investigation, the corridors of the Mitta Mitta (above Lake Dartmouth), the Mitchell and Wonnangatta Rivers and the Thomson River below the dam and above Cowarr weir) were declared to be Heritage River Areas under the Heritage Rivers Act 1992 . . . Draft management plans for these heritage rivers have been produced abd include strategies to protect significant environmental values in each river.
Timber harvesting is excluded from the seven Natural Catchment Areas in the Gippsland Region declared under the Heritage Rivers Act 1992.
p236 Private landholders are responsible for controlling activities on their land. Native Vegetation Retention Controls, Flora and Fauna Guarantee and the Code provide mechanisms for protecting environmental values on private land, however, their implementation lacks coordination.