Module 5 - VicForests

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Module 5 - Harvesting and Closure Appendix I Auditee responses to matters of fact I VicForests Comments on the Draft Forest Audit Program Report 25/02/11 Comment Page Coupe General Comments Auditors consideration Ref 1 13 n/a The level of compliance graph illustrates that our lowest level of compliance is biodiversity conservation. This is largely due to document control and not value protection as the term biodiversity conservation implies. Can the graph be altered to A new EIA category of "No impact" has been added to the EIA tool for those issues where there it is assessed that there is no actual environmental impact as a result of a non-compliance, to distinguish them from non-compliances that result in a negligible actual or potential environmental impact. reflect what the findings were, such as weed survey documentation, machine wash down documentation etc 2 13 n/a This section focuses on crossing the tape line even though the buffers were marked wider than the minimum prescribed width and the minimum with is in no way compromised The operation has therefore not impacted on the buffer. The audit has focused on the input rather than the outcome of this issue. The objective of the Environmental Assessment tool is to assess environmental impact and in this case there has been none. This 'depth' of audit goes beyond the scope of the audit against the Code and Management Procedures for this element. Coupe reconnaissance and marking cause 19% of VicForests OH&S incidents and 30% of our lost time injuries. The focus on the marked or taped boundary line as being sacrosanct exacerbates this potential for injury when we need to look for other, safer ways of establishing the correct boundary. In accordance with the FAP methodology, non-compliances are not limited to those areas where environmental impact is noted, but where a Code, MP or salvage prescription requirement is assessed as not having been met. The Auditor considers that there must be no ambiguity about the way that coupe boundaries are managed in terms of which tape lines can be crossed and which can not. Assessment of breached taped boundaries as non-compliances is consistent with the way that assessments have been made in past EPA audits that have been limited to Code compliance. However, the Auditor accepts that crossing of taped boundaries is technically not a noncompliance with Code or Management Procedure requirements if the required buffer remains intact. Therefore, this non-compliance has been removed and text added that the Auditor considers the culture and practice of accepting that taped boundaries may be crossed carries a risk of leading to a non-compliance. 3 15 n/a Table 4.1 of total non-compliances shows no comparison to the total number of audit elements or total compliance. It also does not identify that the results are for 25 VicForests coupes and only 2 DSE coupes. Please add further context and information to this table. 4 17&1 8 n/a At the bottom of page 17 it states that there may be a weakness in planning or mapping processes, although the top of page 18 it states that all 27 coupes were assessed as complying with the requirements pertaining to planning. How is it that there is a weakness if planning requirements comply Can this comment be removed or amended to resolve the inconsistencies especially as there is again no environmental impact. The number of compliances and total number of coupes for each of VicForests and DSE have been added. Sentence about weakness in planning remains. Further clarification that the 'Exclusion Zones' requirements address protection of exclusion zones has been added. 5 21 n/a If there has been no environmental impact why has incorrect tape colour resulted in a non-compliance We do not believe this is a non-compliance as the buffers meet the requirement of the Code and Management Procedures. 6 21 n/a Harvest debris was pushed over the taped boundaries but they were marked wider than the prescribed width. Therefore there was no impact on the buffer or the value being protected. We do not believe this is a non-compliance and goes beyond the scope of the audit against the Code and Management Procedures. 7 21 n/a One buffer was taped at an insufficient width, but there was no harvesting activities in the area between the taped boundary and where the boundary should have been marked. Therefore there has been no environmental impact to the buffer and this goes beyond the scope of the audit against the Code and Management Procedures 8 28 n/a The report states that there was no documentary evidence of soil having been removed from machinery before floating to or from a fire salvage coupe. In the Coupe Monitoring Records there is evidence of machine wash down. If more evidence is preferred, should this be a recommendation for improvement instead of a non-compliance 9 43 n/a Can the dot point "trees pulled out of buffer without documentation" be worded better as it sounds like harvesting occurred in the buffer Trees were felled within the coupe but slid down a hill into a buffer. The contractor removed the trees but there was not sufficient documentation on the incident 10 25 n/a If there is evidence of weeds prior to harvesting in our records we do not believe we should be issued a non-compliance for weeds located within the coupe post harvest 11 26 n/a The default field for marking habitat trees states that the variation for marking should be viewed. Foresters can update this field with comments. The coupes listed below have comments in this field detailing what the marking methods were and where the habitat trees are located. If this has been identified in the coupe plan and the correct number of trees have been retained and protected the we do not believe this is noncompliant The Code requires that "the location of buffer and filter strips must be easily distinguishable in the field" and be identified in the Forest Coupe Plan. The FCP states that the buffers are marked with red tape, however they were marked in orange tape. The Auditor considers that there must be no ambiguity in relation to harvest boundaries. In accordance with the FAP methodology, non-compliances are not limited to those areas where environmental impact is noted, but where a Code, MP or salvage prescription requirement is assessed as not having been met. In this instance, the introduction of a new EIA category of "No impact" will enable the actual environmental impact (none) to be reflected. See response to comment #2. Text has been changed accordingly. See response to comment #2. Text has been changed accordingly. Where further information has been provided to the Auditor (CMRs) the audit finding has been reassessed and in all but one instance the non-compliance has been reversed, noting however that this is based on limited information. Text also added at end of paparagraph 'The Auditor notes that this presents an opportunity for improvement in the documentation of machinery wash-down activities'. See the coupe specific comments for results. Text has been changed to: "Inadequate evidence that authorisation was given to remove trees felled into buffers" All non-compliances related to weed management during harvest operations and preand post-harvest weed surveys were reassessed based on further information and comments on MOF provided by audittees: 1. Where information on occurrence of weeds before harvest has been provided in the FCP or MIR, no non-compliance for pre-harvest weed surveys has been recorded, noting that at times this was based on limited information; 2. Where a weed species is identified in the pre-harvest surveys and was observed by the Auditor on the coupe, a non-compliance has been recorded for the lack of evidence of management during harvest operations and the lack of post-harvest weed inspections; and 3. Where a weed species is not identified in the pre-harvest surveys and was observed by the Auditor on the coupe, a non-compliance has not been recorded for the lack of evidence of management during harvest operations but a non-compliance has been recorded for the lack of post-harvest weed inspections. The report text has been updated Where further information has been provided to the Auditor (Contractor directions) the audit finding has been reassessed and in all but one instance the non-compliance has been reversed. See the coupe specific comments for results. Identified as an area for improvement. 42807504/01/01
Comment Ref Page Coupe General Comments Auditors consideration Page Coupe Coupe Specific Comments 12 20 C6 This is a temporary stream, not a permanent stream, and therefore the 20m buffer is additional to the requirements. See documentation provided. The Auditor agrees that this waterway is a temporary stream and therefore does not require a 30m buffer. This non-compliance has been removed. 13 22 C15 The audit found this coupe to have more than 10% of the area greater than 30 degrees. VicForests would like to know how was this value calculated as our GIS data shows that C15 has less than 10% harvested over 30 degrees. Contractor rates are affected by slope and rock and contractors are quick to alert VicForests if a coupe exceeds 30 degrees over any significant area. See documentation provided. The assessment was based on visual assessment during the coupe inspection. This noncompliance has been removed, based on GIS slope analysis data provided by VicForests. 14 34 C3 Topsoil not road construction fill was stockpiled on the edge of the road for use in rehabilitation of the road. An active coupe is currently using the road and it will be rehabilitated when use of the road is no longer required. There is no evidence of erosion or impact on the rainforest. DSE is aware of the planned rehabilitation activities and that the road will be rehabilitated once access is no longer required. We do not believe this should be a major noncompliance as there are plans in place to use the topsoil to rehabilitate the road The stockpiled soil appears to be subsoil rather than topsoil, however discussions with a local senior DSE officer with knowledge of the issue, during the 'comments on matters of fact' period advised that it is both topsoil and subsoil. Erosion of the soil stockpiles was visually evident during the site inspection and evident in the photo included in the audit report. The DSE officer advised the Auditor that VicForests, at the time of road construction, had discussed with DSE options to minimise disturbance to the several wet gullies that the road crosses. The DSE officer advised that it was verbally agreed that the best option would be to stockpile topsoil in order to rehabilitate (including ripping and spreading of topsoil) the road after completion of harvesting in an adjacent coupe, which also used the road. He also advised that the stockpiling of the soil against the trees was agreed as the option of least impact, compared with increasing the clearing width. However, these decisions were not documented and plans were not developed and authorised. 14 continued 14 continued from above Based on this limited information, the Auditor acknowledges the apparent consideration that was given to various options to minimise impact and that VicForests plans to rehabilitate the road to a higher level than the minimum required. In light of this information, the Auditor considers that the main deficiency appears to be in documenting plans and obtaining approvals for this work, given that the activities have resulted in outcomes not aligned with the Code and Management Procedures (soil stockpiles not appropriately stabilised, soil stockpiled against live trees). The Auditor has reviewed the assessment of this issue in light of the apparent planning that has been undertaken with the aim of minimising environmental impact and based on this inf ormation, that the impact is likely to be medium term (12-36) months rather than long term (>36 months). Therefore, the EIA has been reduced from Major to Moderate and recommends that, when complete, the rehabilitation of this road, including timeliness of rehabilitation, be reviewed by DSE as the regulator, against what was said to have been agreed. 15 37 C23 The report states that the auditor considers that the loading bays should have been managed as landings and rehabilitated accordingly, but has the loading bay from the thinning operations increased in size Our prescriptions outline that loading bays require rehabilitation according to landing requirements if they exceed 600 square metres. The nonrehabilitation of these areas is no different, in this clearfall situation, from that of a final cut following a thinning. If the auditors sees this as an area of improvement, it should be a recommendation not a non-compliance. 16 38 C2 The Management Procedures do not state if topsoil should be spread before or after ripping. The Utilisation Procedures states that topsoil should be spread after ripping unless otherwise directed by a VicForests representatives. This was authorised by VicForests staff, on these coupes, as discussed in the field, due to compaction while spreading topsoil 38 continu ed Continued from above 17 38 C3 The Management Procedures do not state if topsoil should be spread before or after harvesting. The Utilisation Procedures states that topsoil should be spread after ripping unless otherwise directed by a VicForests representatives. This was authorised by VicForests staff, on these coupes, as discussed in the field, due to compaction while spreading topsoil. 18 38 C4 The Management Procedures do not state if topsoil should be spread before or after harvesting. The Utilisation Procedures states that topsoil should be spread after ripping unless otherwise directed by a VicForests representatives. This was authorised by VicForests staff, on these coupes, as discussed in the field, due to compaction while spreading topsoil. 19 38 C5 The Management Procedures do not state if topsoil should be spread before or after harvesting. The Utilisation Procedures states that topsoil should be spread after ripping unless otherwise directed by a VicForests representatives. This was authorised by VicForests staff, on these coupes, as discussed in the field, due to compaction while spreading topsoil. We believe these should not be non-compliances as they comply with our requirements Agreed that a final cut following a thinning is effectively the same as a clearfall operation in terms of stocking result. Non-compliance has been removed. One loading bay area was larger than 600 square metres (700 square metres), however the area also incorporated a turnaround for trucks. The Utilisation Procedures state that topsoil should be spread after ripping and the Silvicultural Guidelines #11 recommend that topsoil be spread after ripping. The Auditor agrees that the UPs include a statement that this can be varied if directed by a VicForests representative. This direction was not documented, however the Auditor agrees there is no specific requirement that documentation is required. Therefore the reference to respreading topsoil has been altered, however the non-compliances remain in that they are due to the landings having an insufficient cover of topsoil. Text has been changed to: On four coupes (C2, C3, C4 and C5), topsoil had been replaced before landings were ripped. The relevant procedural documents recommend that topsoil be spread after ripping, but there is provision for the Forest Officer to vary this practice. VicForests staff stated that the decision to spread topsoil before ripping on these coupes was taken in response to landing compaction through ripping after topsoil replacement. The Auditor considers that this practice is likely to have contributed to the lack of topsoil on the rehabilitated landings, but acknowledges the operational challenges of achieving both alleviation of compaction and replacement of topsoil, particularly on soils where there is a naturally thin layer of topsoil. as above as above as above
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Report Environmental Audit - Forest
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Table of Contents Executive Summary
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Executive Summary Table 4-24 Table
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Executive Summary This report docum
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0 Introduction environmental impact
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0 Introduction Element group (Opera
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1 Introduction 1 This report docume
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1 Introduction their objectives of
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2 Audit scope 2.3 Beneficial uses I
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Audit Approach 3 3 3.1 Audit overvi
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3 Audit Approach Log landings and
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3 Audit Approach audit criteria in
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3 Audit Approach 4.2.1 Environmenta
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3 Audit Approach Major Two non-comp
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3 Audit Approach Details of audit f
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3 Audit Approach Table 4-5 summaris
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4 3BAudit Findings Table 4-6 Summar
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4 3BAudit Findings Biodiversity con
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4 3BAudit Findings The audit identi
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4 3BAudit Findings Table 4-14 Summa
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4 3BAudit Findings The Auditor made
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4 3BAudit Findings Table 4-22 summa
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Conclusions 5 5 5.1 Overall assessm
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6 Glossary 6 Auditee An auditee is
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6 Glossary quality; for the provisi
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Module 5 - Harvesting and Closure A
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CONTENTS 1 MODULE 1 - OVERVIEW 5 1.
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FOREST AUDIT PROGRAM TOOLBOX Module
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1 MODULE 1 - OVERVIEW 1.1 BACKGROUN
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2 OBJECTIVES AND SCOPE OF THE FORES
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• Timber harvesting practices und
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2.2.4 Segments and Elements of the
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2.3.2 Module Compliance Elements Au
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3 STATUTORY OVERVIEW The following
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3.4 FLORA AND FAUNA GUARANTEE ACT 1
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The Fire Salvage Harvesting Prescri
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4 GLOSSARY Auditee Auditor Biodiver
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State Forest Thinning Timber Releas
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NGO OA SAP SFMS SFRI SMZ SOP SPZ ST
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Annex A Electronic Toolbox CD FORES
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Prepared by Environmental Resources
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Forest Audit Program Toolbox Module
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FOREST AUDIT PROGRAM TOOLBOX 5 PRES
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FOREST AUDIT PROGRAM TOOLBOX FOREST
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FOREST AUDIT PROGRAM TOOLBOX For ti
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FOREST AUDIT PROGRAM TOOLBOX Health
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FOREST AUDIT PROGRAM TOOLBOX • Co
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FOREST AUDIT PROGRAM TOOLBOX The pr
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FOREST AUDIT PROGRAM TOOLBOX Final
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FOREST AUDIT PROGRAM TOOLBOX Audito
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FOREST AUDIT PROGRAM TOOLBOX • Ma
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FOREST AUDIT PROGRAM TOOLBOX Water.
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FOREST AUDIT PROGRAM TOOLBOX 3 SELE
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FOREST AUDIT PROGRAM TOOLBOX 4 SELE
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FOREST AUDIT PROGRAM TOOLBOX ensure
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FOREST AUDIT PROGRAM TOOLBOX Regene
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FOREST AUDIT PROGRAM TOOLBOX Table
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FOREST AUDIT PROGRAM TOOLBOX Enviro
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Module 5 - Harvesting and Closure A
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CONTENTS 1 MODULE 5 - HARVESTING AN
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FOREST AUDIT PROGRAM TOOLBOX Module
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1 MODULE 5 - HARVESTING AND CLOSURE
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2 COMPLIANCE ELEMENTS The relevant
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• Identification of waterways and
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3 AUDIT APPROACH AND TOOLS An audit
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• Interviews, where appropriate,
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NFSG #13 - Native Forest Silvicultu
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Annex A Compliance Element Paramete
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Compliance Element Parameter Measur
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Reserved Area Protection • Assess
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Annexures B - G Electronic CD Annex
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Prepared by Environmental Resources
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ENVIRONMENTAL AUDIT FOREST AUDIT PR
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FOREST AUDIT PROGRAM, AUDIT WORKBOO
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Forest Coupe Plans - Mandatory Acti
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Forest Coupe Plans - Mandatory Acti
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Forest Coupe Plans FOREST AUDIT PRO
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Water Quality, River Health and Soi
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Module 5 - VicForests

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