What are the coastal IFOAs?

The draft Coastal Integrated Forestry Operations Approval (Coastal IFOA) are the rules that set out how native forestry operations are proposed to be managed and regulated in state forests in the coastal regions of NSW.

It sets out proposed rules to protect native plants, animals, important habitat and ecosystems, soils and water during native forestry operations on State Forests and other Crown-timber lands.

The Coastal IFOA is proposed to replace four exiting IFOAs for the Eden, Southern, Upper North East and Lower North East regions. 

Why are the Coastal IFOAs being remade?

The current IFOAs were developed almost 20 years ago and contain more than 2,000 conditions each. They have not kept pace with regulatory best practice and are no longer efficient or effective in the way we consider environmental impacts from a regional perspective. They also lack the ability to adapt and respond to emerging issues and changes in operational practices and technology.  

To ensure State forests are managed in an ecologically sustainable way into the future the NSW Government committed to remake the four current Coastal IFOAs. This draft Coastal IFOA is the result of this review process.

What will the proposed draft Coastal IFOA achieve?

The development of the draft Coastal IFOA was very complex, as the NSW Government was committed to ensuring it maintained environmental values, wood supply and social outcomes. The NSW Government has conducted a rigorous process in developing the new draft Coastal IFOA and has sought independent expert advice to ensure the right balance is struck.

The draft Coastal IFOA seeks to establish practical, effective and enforceable licence conditions that are not open to interpretation and are clear both to industry operators and the community. 

How will the Government be consulting with the public on the draft Coastal IFOA?

The NSW Government wants everyone in NSW to have the chance to comment on the draft Coastal IFOA. The consultation approach focuses on providing everyone with the same information via the NSW Government’s easy to access online consultation platform Have Your Say. This website will be updated regularly with new information to assist you in your review of the draft Coastal IFOA.

All submissions need to be lodged via the Have Your Say portal before close of business on Friday 29 June 2018.

The new draft Coastal IFOA is a highly technical document. It comprises of two separate documents, proposed licence conditions and its accompanying protocols. The NSW Government has also prepared a series of supporting case studies and factsheets to help explain some of the major themes and key changes proposed in the draft Coastal IFOA.

If you have a question about the draft Coastal IFOA or would like more information on specific rules it proposes, please email ifoa.remake@epa.nsw.gov.au

How was the Natural Resource Commission involved in the remake process?

It was important that the draft Coastal IFOA was based on the best available scientific and independent expert advice which considered both the technical aspects of forestry practices and environmental impacts. The NRC is the government’s independent expert advisory body on natural resources matters – and is experienced in providing the NSW Government advice on forest management matters.

In 2016 and again in 2018, the NRC was asked to provide independent advice on a suite of proposed Coastal IFOA settings and additional measures to assist the NSW Government in meeting its commitments of maintaining both wood supply and environmental values.

The NRC has provided two reports to the NSW Government, which can be downloaded from the NRC’s website at www.nrc.nsw.gov.au/ifoa.

The NSW Government Response to the Natural Resources Commission Reports can be found on the ‘Have Your Say’ website in the document library.

The NSW Government has accepted the NRC’s recommended IFOA settings set out in their 2016 report and these have been included in the draft Coastal IFOA, along with a range of other environment protection, forest management and monitoring requirements.

The NSW Government has also accepted the NRCs recommendation to commence a process for improving the accuracy of old growth forest maps in select State forest sites on the NSW North Coast. This work will address potential impacts of the draft Coastal IFOA on wood supply, whilst maintaining robust environmental protections for areas with special conservation value. The NRC will oversee this process, and will consult further with the public on this proposal in 2019.

How will this new draft Coastal IFOA protect the environment?

For the first time ever, the draft Coastal IFOA proposes to set minimum thresholds for the permanent protection of threatened species across the landscape, as well as in each harvesting site. These permanent protections provide improved protection for native plants, animals and their habitat, streams and aquatic habitat.

The draft Coastal IFOA proposes a multi-scale approach to delivering a comprehensive biodiversity protection model for the coastal timber production forests of NSW. It provides important habitat protections at the site, local and broader landscape management scales.

This approach ensures the maintenance of multi-aged forests across the landscape and the permanent retention of undisturbed habitat, providing areas of refuge, as well as connectivity and dispersal opportunities for native species.

Continuous improvement of these rules will be facilitated through the increased flexibility that the proposed Coastal IFOA licensing framework offers. The draft Coastal IFOA can enable an efficient and effective response when negative impacts or impractical outcomes are demonstrated, new information comes to hand or a better methodology for achieving an outcome is identified. This approach will complement a robust monitoring program that will implemented to ensure the Coastal IFOA delivers its intended outcomes into the future.

Does the draft Coastal IFOA include new restrictions on intensive harvesting?

The draft Coastal IFOA proposes to apply new limits on intensive harvesting activities that are much more specific, not open to interpretation and balanced with improved environmental protections. The draft Coastal IFOA proposes to distribute the impacts of intensive harvesting over time and across the landscape by prescribing harvesting limits at the site, local and broader landscape scales.  

The harvesting limit settings in the draft Coastal IFOA will also be supported by forest regeneration standards and a comprehensive monitoring, evaluation, review and implementation framework, to ensure any potential environmental impacts are identified and adaptively managed into the future.

How does the new draft coastal IFOA protect koalas and their habitats?

The remade Coastal IFOA will ensure that rules for managing koala habitat are modern and that protections are always in place to manage the impacts of native forest harvesting on important koala habitat across the landscape.

The draft Coastal IFOA proposes to move away from survey driven approaches to koala protection, which has been shown to have limitations. Instead it will identify and protect places in the landscape where koalas are more likely to occur. This approach will differ on the North and South coast.

On the North Coast of NSW, it is proposed that koala protection will make use of new koala maps. Koala maps will expand the area where koala protections are proposed to apply, and will provide a more consistent and precautionary approach to retaining koala habitat across the landscape.

The draft Coastal IFOA proposes to set a minimum rate of koala feed trees to be retained, based on different types of potential koala habitat. These protections apply regardless of koalas being identified in the harvesting area. Areas with important koala habitat will be prioritised for inclusion in new wildlife habitat and tree retention clumps – providing permanent protection for important koala habitat.

On the South Coast, the Forest Corporation of NSW will be required to survey for koalas using contemporary koala survey methods. Should koalas be identified, the NSW Environment Protection Authority will develop new koala conditions that are specific to the harvest site. These requirements will be adaptively managed once koala maps become available on the south coast.

How will these new harvesting rules secure wood supply and support the continuation of the state’s coastal timber industry?

The NSW Government is committed to the long term and sustainable management of NSW’s forestry estate, for the benefit of the community, environment and the forestry and product manufacturing industry.

The four current coastal IFOAs are process-focused and have not allowed forestry operations to keep pace with changes in technology, harvesting practices and best practice.

The draft Coastal IFOA proposes outcome-focused rules and proposes to move from a reliance on detailed and prescriptive rules towards stated principles and outcomes to be achieved. These principles and outcomes will set the standards of practice and make the identified measures of success clear to the timber industry, the regulatory authority and the community.

This approach provides a simpler and more efficient operating environment for the timber industry. Further operational efficiencies will result from the implementation of modern technologies.

The draft Coastal IFOA proposes new forest regeneration standards. These standards will ensure harvested sites are regenerated to their full potential, providing long term security of the forest resource in NSW. In addition, the draft IFOA proposes a comprehensive monitoring, evaluation, review and implementation framework, to ensure any potential wood supply impacts are identified and adaptively managed into the future.

How does this new draft IFOA plan to improve compliance from industry?

The NSW Government recognised that over time, experience in implementing, monitoring and enforcing compliance with the Coastal IFOAs has shown they were not achieving their original purpose. Each of the current IFOA’s contains over 2000 conditions, creating an overly complex operating environment that is costly to implement and difficult to enforce. 

The draft Coastal IFOA is more efficient, effective, enforceable and provides an appropriate balance between maintaining environmental values and wood supply.

The draft Coastal IFOA proposes outcome-focused regulation and has moved from a reliance on detailed and prescriptive rules towards stated principles and outcomes to be achieved. These principles and outcomes will set the standards of practice and make the identified measures of success clear to the Forestry Corporation of NSW, the regulatory authority and the community.

The language used is clear, transparent and easy to understand and implement. The rules require all habitat features to be digitally mapped. By moving to map-based protections, there is greater transparency in what is being protected and where. It provides greater ability for the EPA to regulate efficiently and effectively, and provides safety and efficiency benefits to Forestry Corporation of NSW and the timber industry.

What timber supply volume did the Natural Resources Commission use in its analysis to determine whether the twin commitments could be met?

The Natural Resource Commission was asked to determine whether proposed settings for the coastal IFOA remake would, or would not, deliver on the Government’s commitment of no net change to wood supply, and no erosion of environmental values. The Commission determined that settings would have a negative localised impact on wood supply.

The Commission used the figure of ~180,000 m3/pa (avg. harvest volumes over 100years) in its analysis based on wood supply volume from only the north coast native forest estate. As the IFOA settings do not apply to plantations, the Commission did not consider impacts on wood supply volumes from plantations.

What is the NSW Governments current total wood supply commitment in North East NSW, and what is included in this calculation?

The NSW Government updated its model for long-term sustainability of timber supply on the North East NSW (both Upper and Lower North East Regions) between 2012 and 2016 and summary of this work is available here.

The North East Long-term Wood Supply Model (see p48, NRC Report 2016) combines all High Quality Logs including; large sawlogs (those with a centre diameter under bark > 40 cm), small sawlogs (cdub <40cm) , veneer logs, poles, girders and piles.  This model includes hardwood timber volumes available from both the plantation and native forest areas.  The modelled high quality volume averages around 237,000m3 per annum.  The model shows the proportion of high quality timber available from plantations increases over time, reaching as high as 25% of the total high quality volume in some later periods. 

The first increase in supply from plantations occurs as a result of volumes becoming available from the plantations established with funding provided under the RFA beginning to mature and reach commercial size from around 2025.  The second increase is modelled to occur around 2050 from plantings where older flooded gum plantations, originally established in the 1960s and 1970s are being harvested and replanted with high value commercial species such as blackbutt.

The increase in the proportion of timber sourced from plantations leads to a projected increase in proportions of smaller sized sawlogs in later periods of the model.  Over the next 20 years the model predicts 30% of the high quality logs are small whilst the average is around 45% over the full hundred years and reaching close to 50% in some periods.

This model informs wood supply allocation agreements made by the Forestry Corporation with timber processors. Timber is supplied under a range of commercial contracts, called Wood Supply Agreements with individual timber customers.  Current commitments for high quality timber under wood supply agreements for the North East are shown in Table 1.

Table 1.  Wood Supply Allocations from State Forests in North East NSW – 2018.

High Quality Product Allocation

Base Wood Supply Agreement Allocation

(m3/annum)

Large Sawlogs (>40 cm)

127,145

Small Sawlogs (<40 cm)

46,096

Poles

31,600

Veneer

11,202

Girders

4,150

Piles

260

Total

220,423

Other volumes sold under a range of supply agreements

High Quality Log Volume sold under parcel sales – note these are included in the sustained yield model

~10,000

Annual Salvage log, pulpwood and residue sales

~average 300,000

These agreements typically include clauses around indicative area of supply, species mix, annual variation to deal with annual supply fluctuations associated with weather and other logistical issues.  This means annual supply can vary but the base allocation represents the long-term average yields that can be provided under those agreements.

Lower Quality Log Agreements

Whilst sustainability modelling is based around high quality log product volumes, there are also significant volumes of lower grade sawlogs, pulpwood and residue products sold each year that arise during harvesting operations primarily conducted to produce high quality products.  Low quality logs are sold to customers under a range of supply agreements with different lengths and levels of requirements for supply. The total annual volume sold tends to be more variable than high quality products but typically represents 50-60% of annual log sales.

This response was prepared by the Natural Resource Commission, The Department of Primary Industries and Forest Corporation NSW.

Can I get an extension to make a submission

The NSW Government has extended the consultation period from 29 June to 5.00pm Friday 13 July 2018.

This extension is in recognition that this is a once-in-a-generation reform, and that the NSW Government want to ensure it hears all the community’s views on the draft Coastal IFOA. No further extension to the consultation period will be available.

Where will intensive harvesting be carried out and how many hectares are available?

Under the draft Coastal IFOA, intensive harvesting will be restricted to Blackbutt dominated forests between Grafton and Taree in Northern NSW. Forestry Corporation of NSW have identified a zone of about 140,000 hectares (the intensive harvesting zone) where further assessments will be undertaken to identify and map area where intensive harvesting may occur. It is estimated that about 50,000 hectares of forest will be mapped and available for intensive harvesting.

The draft Coastal IFOA proposes additional limits on the application of intensive harvesting to distribute its impacts over time and across the landscape. This includes annual limits of no more than 2,200 hectares of forests, and/or a maximum of 5% of each management zone (and area of around 50,000 hectares), may be intensively harvested in any financial year. Rules around the size of individual intensively harvested areas and cumulative impacts are also specified.

For more information on intensive harvesting, see the Timber factsheet.

There are many forestry reforms occurring, what should I consider first?

The draft Coastal IFOA is the only forestry reform that is currently open for public consideration. This is an important reform that will inform how native forestry operations are carried out in State forestry for the next 20 years. Submissions on the draft Coastal IFOA close on 13 July 2018.

Whilst the NSW Government has announced that there will be work undertaken by the Natural Resources Commission (NRC) on reassessing old growth forest in State forests on the NSW north coast – this work is yet to commence. Further public consultation opportunities will occur on this reassessment work over the next 12-months.

Public consultation on the review and extension of the NSW Regional Forest Agreements is complete. The public’s views on the RFAs are currently being considered by both the Australian and NSW governments.

What are the conditions reducing buffers for streams, and if so, in what context is this proposed?

The current mapping of streams is outdated and the rules for protecting them are inconsistent, resulting in some streams not being afforded any protection.

Under the draft Coastal IFOA, LiDAR technology has allowed for more accurate mapping of streams. This mapping has picked up a larger amount of headwater streams than that used in the current IFOAs, impacting on how streams should be classified in the draft Coastal IFOA.

In developing the draft Coastal IFOA, the NSW Government and Forest Corporation NSW looked at other jurisdictions and designed a stream classification system based on catchment area.  This means that as the catchment gets bigger, the stream exclusion zones get bigger. 

Area thresholds were examined to provide an equivalent area protection outcome and to match the old stream order, both in total and at the stream order level.  This approach gives the best equivalent outcome for larger streams.  The draft Coastal IFOA conditions maintain the current 20, 30 and 50-metre-wide buffer widths for these larger streams.   

Currently, unmapped features and headwater streams receive a mixture of no exclusion zone or a 10-metre-wide exclusion zone.  With the improvement of mapping of these headwater streams, the draft Coastal IFOA proposes a minimum of a 5 metre stream exclusion zone on each side of them all. In areas where there is threatened fish habitat, more intensive harvesting practices applied, and in the Eden sub-Region, these streams will have increased 10-metre-wide stream protections.

Additionally, it is proposed that all stream protections will be applied from the edge of the bank using the ‘bankfull concept’ meaning exclusion zone widths are applied each side of  the stream bank edge not the centre line.

Overall the proposed Coastal IFOA provisions ensure a minimum level of protection to all streams, more accurate mapping to simplify implementation and consistent protection to the larger features. 

More information about stream protections is available in the Landscape Factsheet and the Coastal IFOA Briefing Session Narrated Presentation (slides 31-34).