Submissions

From time to time Forestry Australia corresponds and prepare submissions to Federal and Local Governments, as well as Inquiries and Royal Commissions, copies of our recent submissions are listed below:

Submission: Inquiry into the ACT environment’s bushfire preparedness
Forestry Australia’s ACT Branch wrote a Submission to the Inquiry into the ACT environment’s bushfire. The submission highlights the importance of proactive bushfire management, integration of traditional practices, and strategic resource allocation to mitigate increasing risks posed by bushfires. Additionally, Forestry Australia provided its Position Statement on Forest Fire Management.

To view the submission, click HERE
February 2024

Submission: Preliminary recommendation by the Scientific Advisory Committee (SAC) for ‘Salvage Logging of Burnt Forests’
Forestry Australia’s Victorian Branch wrote a Submission on the preliminary recommendation by the Scientific Advisory Committee (SAC) for ‘Salvage Logging of Burnt Forests’ to be listed as a threatening process under the Flora and Fauna Guarantee Act (1988).

Key issues raised include clarity surrounding salvage harvesting activities and the types of forests affected, as well as acknowledgement of established definitions and regulatory frameworks such as the Code of Practice for Timber Production, Management Standards, Regional Forest Agreements, and Action Statements.

Forestry Australia recommends that the SAC reconsider its preliminary recommendation that the nomination of Salvage Harvesting of Burnt Forests is eligible for listing as a threatening process.

To view submission, click HERE
December 2023

Submission the the ACCU Scheme Review
Forestry Australia’s Carbon Working Group wrote a Submission to the Australian Carbon Credit Unit (ACCU) Scheme Review.

To view submission, click HERE
October 2023

Submission to Clarence Valley Council re: Native Forest Harvesting
In response to the motion by Clarence Valley’s Biodiversity Advisory Committee to phase out native forest harvesting on public land, Forestry Australia made a submission. Forestry Australia framed their submission through a series of questions that we proposed the Clarence Valley Council should seek to answer prior to forming any position regarding changes to management of public forests in NSW. This due diligence is required to ensure policies do not precipitate unintended negative consequences for forests and the communities who rely on them.

To view the submission, click HERE
August 2023

Submission on the draft Victorian Bushfire Management Strategy
The Victorian Department of Energy, Environment and Climate Action sort feedback on the draft of Victoria’s Bushfire Management Strategy. Forestry Australia’s submission stated that … bushfire management needs to change. Current practices are not improving outcomes. Bushfire management is fundamentally a forest management challenge. We must shift emphasis from responding to events as they occur to actions to better prepare for and to limit the extent and impacts of bushfires. This task is immense, complex and difficult but must be faced with truth and honesty.

To view the submission, click HERE
August 2023

Submission to the Consultation on the Draft Legislation
In this submission, Forestry Australia recommends that the Indirect and Industry Tax Policy Unit, Personal and Indirect Tax and Charities Division of Treasury, move with priority to support small forest growers; and considers the intent of the Government’s National Forest Industries Plan (2018) to review “legislation, policies and processes that may be unintentionally restricting plantation expansion” and “work with states and industry to help farmers explore opportunities for expanding farm forestry, creating future wood and fibre supplies, improving increasing economic returns for farmers”.

To view submission, click HERE
March 2023

Urban Forest Bill
To view submission, click HERE
September 2022

Senator Pocock Correspondence
Forestry Australia wrote to Senator David Pocock regarding his concerns about the integrity of the 2022 Plantation Forestry method, reinforced the critical role forests play in climate change mitigation and introduced the Registered Forestry Professional (RFP) scheme as an integrity control in the 2022 Plantation Forestry Method.

To View Letter, click HERE
September 2022

WA Bauxite Mining
The WA Branch made a submission to the WA Environment Protection Authority relating to proposed expansion of bauxite mining by South 32 in the eastern jarrah forest.

To View Submission, click HERE
August 2022

Draft Integrated Farm Management Method
To View Submission, click HERE
August 2022

NSW Draft Forest Management Plan
A Submission in Response to an Invitation to Comment on Forestry Corporation NSW Forest Management Plan

To View Submission, click HERE
July 2022

Draft Urban Forest Bill
To view submission, Click HERE
June 2022

Draft Action Plan to Prevent the Loss of Mature Native Trees in the Territory
To view submission, Click HERE
May 2022

Victorian Koala Management Strategy 2022
To view submission, Click HERE
April 2022

National Farm Forestry Strategy
Forestry Australia provided feedback on what to include in the National Farm Forestry Strategy. An integrated, long-term ‘whole-of-country’ approach to investment by all levels of government is required to ensure our forests (both natural and planted), and the communities that depend on them, continue to expand and are well managed.

To view submission, Click HERE
January 2022

NIFPI Feasibility
Forestry Australia Vice President, Dr Kevin Harding prepared a submission on behalf of Forestry Australia members to the NIFPI Feasibility Study Consultation Paper – Iceni.

To view submission, Click HERE
November 2021

Victorian Regional Forest Agreements Major Event Review
Congratulations to the VIC Division on their submission to the RFA Major Event Review.

* To view cover letter, click HERE

* To view submission, click HERE
August 2021

Code of Forest Practice Timber Production
On behalf of members, the IFA/AFG Victorian Division made a submission to DELWP on the proposed Variation of the Code of Forest Practice for Timber Production. The IFA/AFG strongly supports codes of practice as an effective tool to regulate forest management and indicated our willingness to be actively involved in its continual development.
July 2021

Precautionary Approach: Australian Standard for Sustainable Forest Management
Following consultation with members, the IFA/AFG commented on the revision of the Australian Standard for Sustainable Forest Management in relation to the precautionary approach.
June 2021

NSW Enquiry into the Long-Term Sustainability & Future of the Timber Forest Products Industry
Addressing the forestry science, environmental, economic and community impacts and opportunities for timber and forest products in NSW.
June 2021

Feedback: Karri Forest Management Plan
The IFA/AFG made a submission to provide Feedback on the on Karri Forest Management Plan.
May 2021

Submission: Farm Management Deposits Scheme FMDS
The IFA/AFG’s submission to the Farm Management Deposits Scheme (FMDS) review addresses the elements of the FMDS that are most relevant to private forest growers. Conceptually, the FMDS is a sensible policy designed to assist primary producers manage the risks and variability inherent in primary production. However the IFA/AFG submission highlights that the FMDS does not currently embrace forestry as a form of primary production, nor recognise the unique characteristics of long term forestry enterprises.

Consequently, despite years of advice and representations from AFG, the scheme has not been adapted in any way to accommodate private forestry. The IFA/AFG submission draws attention to limitations of the current scheme and provides recommendations as to how these should be addressed.
May 2021

Submission: Environment Protection & Biodiversity Conservation Amendment (EPBC) RFA
The IFA/AFG made a submission in strong support of the Environment Protection and Biodiversity Conservation Amendment.
March 2021

Submission: Tasmanian Draft Bushfire Mitigation Measures Bill 2020
The IFA/AFG FFMC and Tas Division were invited to make comments on the draft Tasmanian Bushfire Mitigation Measures Bill 2020
October 2020

Submission: Draft ACT Urban Forest Strategy
The ACT Division made a submission to the draft ACT Urban Forest Strategy
August 2020

Submission: Inquiry into Ecosystem Decline in Victoria
IFA/AFG Submission to the Victorian Legislative Council Environment and Planning Committee
August 2020

AS/NZS 4708- 2020 Sustainable Forest Management Standard – For Public Comment

Public Comment Covering Letter

Draft ASNZS 4708 – 2020 Sustainable Forest Management Standard

Public Comment Submission Sheet
August 2020

Submission: Inquiry into Timber Supply Chain Constraints in the Australian Plantation Sector
Standing Committee on Agriculture and Water Resources; Timber Supply Chain Constraints
August 2020

IFA/AFG Submission to the Discussion Paper
National Agricultural Workforce Strategy
August 2020

Correspondence from Senator the Hon. Jonathon Duniam
$40 million Forestry Recovery Development Fund
23 June 2020

Submission: Climate Change Authority
Review of the Emissions Reduction Fund
June 2020

Submission: Australian Government’s Senate Inquiry
Lessons to be learned from the Australian Bushfire Season 2019 – 20
May 2020

Submission: NSW Department of Planning, Industry and Environment
Koala Habitat Protection Guideline (2019)
April 2020

Submission: Tree Management Policy, National Capital Authority
The ACT Division made a submission to the development of the NCA Tree Management Policy.
March 2020

Letter to Hon. David Kelly Minister for Forestry, WA
Responding to sudden announcement that harvesting of a specific class of coupes in karri forest would be suspended in the 2020 harvest plan.
March 2020

Emission Reduction Fund: Consultation Paper Proposed Amendments to Regulations Applying to Forestry Projects
Submission to the Department of Industry, Science, Energy and Resources
February 2020

Update on ERF (Water Rule) submission – 7 April 2020

Amendments to Emission Reduction Fund rules on water interception requirements
The IFA/AFG has joined the plantation industry in welcoming news of a Regulation Amendment designed to reduce the regulatory burden for new plantation forestry and farm forestry projects proposed under the Federal Government’s Emissions Reduction Fund (ERF).
The amendment has been made to the existing water interception requirements established under the Carbon Farming Initiative (CFI). The amendment allows new projects in areas with over 600mm of annual rainfall to proceed with registration if they are located in a region declared by the Minister for Energy and Emissions Reduction to be a region where material risks to water availability are likely to be addressed. This change removes a key constraint on ERF eligibility for new plantation projects within medium to high rainfall areas, notably within Regional Forestry Hubs. Project proponents will still need to address water interception requirements in accordance with State and regional planning provisions, and other ERF eligibility requirements.
The amendment was made following a consultation process conducted by the Australian Government Department of Industry, Science, Energy and Resources in February this year. The IFA/AFG made a submission to the Department to support the proposed amendment.
For further information: The amendment is contained in the Carbon Credits (Carbon Farming Initiative) Amendment (Excluded Offsets Projects) Regulations 2020,
2 April 2020.

Plantation Development Concessional Loans IFA/AFG Forest Managers and Growers Inputs and Replies to Discussion Question
Submission to the Department of Agriculture Consultation
December 2019

Submission: NSW Coastal IFOA Monitoring Program NSW Integrated Forestry Operations Approvals Monitoring Program
November 2019

Submission: Inquiry into Australian Forest Industry
April 2011