Rainforest in the Strzelecki Ranges

-  A community review of published research

Abstract

This report brings together what published research, government reports, listing documents and the State’s own maps say about rainforest in the Strzelecki Ranges.  Cool Temperate Rainforest, Cool Temperate Mixed Forest and Strzeleckis Warm Temperate Rainforest are all listed as threatened in Victoria, and by 1999 only about 40 per cent of Gippsland’s original Cool Temperate Rainforest remained. Today about 10 per cent of the rainforest mapped in the Strzelecki Ranges bioregion is in parks and reserves, and between about 20 and 40 per cent is on Crown land licensed for plantation forestry. Neither of the State’s two rainforest maps has been checked on the ground in the Strzeleckis. The report sets out how rainforest is identified in the field, what harms it, the buffer widths found in the rules and what research sources recommend as well as outlining relevant (voluntary) forestry certification requirements.

Contents

About this report

The different kinds of rainforest of the Strzeleckis

A short history of rainforest in the Strzeleckis

How to identify rainforest from surrounding forest

Where does rainforest grow

What harms rainforest

How to protect rainforest

The limits of what we know

Implications arising from this report

References

Glossary

Appendix A. How this report was prepared

Appendix B. FSC cross-reference table

About this report

Purpose

This report is a review of published literature. It brings together what government reports, scientific studies, legislation, listing documents and State maps say about rainforest in the Strzelecki Ranges: what it is, where it grows, how it is identified, what harms it and how it can be protected. It does not present new research, apart from a simple overlay of the State's own maps (Appendix A), and it does not make recommendations.

The report is intended as a summary of the best available information. Under the Forest Stewardship Council (FSC) standard for Australia, certified forest managers "shall" assess and record "the presence and status" of high conservation values in the land they manage.^1(p55) The standard defines "shall" as indicating "requirements to be strictly followed".^1(p96) The assessment must follow the standard's framework for high conservation values, and the first step is to use the best available information: "Consult the Best Available Information to identify relevant datasets and prepare lists and maps of potential HCV".^{1(pp55,58,67)} The standard defines best available information as "Data, facts, documents, expert opinions, contact information and results of field surveys, review of publicly available records or consultations with stakeholders that are most credible, accurate, complete, and/or pertinent and that can be obtained through reasonable effort and cost, subject to the scale and intensity of the management activities and the Precautionary Approach".^1(pp12,83) The list of high conservation values in the standard covers many things. Of most relevance here is "Ecosystems (including rainforests) that are threatened, depleted or poorly reserved at the IBRA bioregion scale".^1(p65)

The standard's guidance for this category notes that areas "that are more vulnerable and subject to higher threat levels are more likely to require operational-level field assessment, verification of desktop data, harvest exclusions, and/or site-specific actions".^1(p67) It also requires management strategies to be adapted "when monitoring or other new information show these strategies and actions are insufficient to ensure the maintenance and/or enhancement of High Conservation Values".^1(p57) This report is not itself a high conservation value assessment, and it makes no finding about whether any forest manager complies with the standard.

Key points

• Cool Temperate Rainforest, Cool Temperate Mixed Forest and Strzeleckis Warm Temperate Rainforest are all listed as threatened communities under Victoria's Flora and Fauna Guarantee Act 1988.^2(p71) Cool Temperate Mixed Forest has not been mapped on a statewide basis, but the committee that recommended its listing says it may be present in the Strzeleckis.^3(pp2-3)

• The West Gippsland Native Vegetation Plan (2003) lists Cool Temperate Rainforest in the Strzelecki Ranges bioregion as Endangered. It says that for Endangered vegetation "all remaining areas need to be protected", and sets a target of formally protecting all of its current extent by 2040.^{4(pp6,50,101)}

• The 1999 regional forest assessment for Gippsland found that only about 40 per cent of the region's original Cool Temperate Rainforest remained.^5(p157)

• A large share of what remained was outside conservation reserves, on land that included plantation leases and licences. The plantation estate was not treated as public forest, and was not included in the draft reserve system for the Gippsland Regional Forest Agreement.^{5(pp156-157),6(p29)} Current government mapping shows about 10 per cent or less of the rainforest mapped in the Strzelecki Ranges bioregion is in formal parks and conservation reserves, and between about 20 and 40 per cent is on Crown land under plantation licence, depending on which of the State's two maps is used (Appendix A).^7,8,9

• David Cameron's A Field Guide to Rainforest Identification in Victoria (referred to in this report as the field guide) says protection depends on finding the rainforest boundary reliably, and that the buffer is measured from that boundary into the surrounding forest.^10(pp1,6,8)

• The State has not verified its newer rainforest map in the Strzeleckis. Its description says that, outside the reserve system, forest management planners "will need to confirm in the field the presence and extent of the rainforest community prior to any forest or fire management activity commencing".⁸ The two State maps agree on only about 550 ha of the 7,209 ha that one or the other maps as rainforest (Appendix A).

• The sources reviewed here recommend rainforest protection zones of between 100 m and 250 m in the Strzeleckis,^{11(pp68-69),12(p29)} and a Tasmanian study suggests zones of 50 m to 250 m around core stands of Myrtle Beech, the main tree of cool temperate rainforest, to limit the spread of Myrtle Wilt.^13(p263) The minimum buffers set for public land depend on the size of the stand: 20 m for linear stands of 0.2 to 0.4 ha, and 40 m for stands of 0.4 ha or more.^14(pp19-20) These figures are not directly comparable: they come from different settings and threats, and include both minimum prescriptions and precautionary recommendations. The sources do not set a single buffer width for all rainforest in the Strzeleckis.

About the authors

Gippsland Forest Guardians is a community-based environmental advocacy group with a strong grounding in ecology. Our members include ecologists, and we work closely with scientists who know the Strzeleckis. We base our advocacy on published evidence, and this report sets out that evidence for rainforest in the Strzelecki Ranges, quoted and referenced so readers can check every source. It reflects what we could find as at the date of publishing. If you know of research we have missed, or see something we have got wrong, please tell us at [email protected].

We would like to acknowledge the Brataualung clan of the Gunaikurnai People as the Traditional Custodians of the land on which Gippsland Forest Guardians live and work, and pay our respect to Elders past, present, and future. We recognise all First Peoples continuing connection to land, water, air and sky, and acknowledge that sovereignty was never ceded.

How this report was prepared

Our searches were targeted rather than exhaustive and were completed in November 2026. Every quotation and figure has been checked against the original document. Appendix A sets out how we searched, what we included and left out, and how we analysed the State's maps.

We thank Julie Constable of Save Our Strzeleckis for access to her archive of Strzelecki material, which led us to several of the primary sources cited here.

The different kinds of rainforest of the Strzeleckis

Two kinds of rainforest have been recorded and mapped in the Strzelecki Ranges. Cool Temperate Rainforest is dominated by Myrtle Beech and Southern Sassafras and grows in the wettest, most sheltered gullies. Strzeleckis Warm Temperate Rainforest is a lowland community, typically of Sweet Pittosporum and Mutton-wood, found along creeks on the lower slopes of the ranges. A third listed community, Cool Temperate Mixed Forest, is Cool Temperate Rainforest with an emergent canopy of eucalypts such as Mountain Ash.^3(pp1-2) When recommending it for listing in 2012, the Scientific Advisory Committee said it "may be present in the Strzelecki ranges",^3(p2) although Peel had earlier noted its "apparent absence" there.^15(p22) The Committee also noted that it was "not mapped on a statewide basis",^3(p3) and neither of the State's two maps used in this report includes it as a mapping class anywhere in Victoria.^7,8 We found no survey that has looked for it in the Strzeleckis. The State's 2022 risk assessment of threatened species and communities for forestry found that "No reliable statewide mapping of this community exists". It said Cool Temperate Mixed Forest is hard to map from aerial imagery "due to the eucalypt overstorey, with stands likely to be currently recorded as Wet Forest or Montane Wet Forest", and that "it is plausible that it is overlooked for protection in some circumstances".^16(pp42,44) The Committee regards Cool Temperate Mixed Forest as part of Cool Temperate Rainforest, and Victoria's Code of Practice for Timber Production treats it as "a recognised subset of rainforest".^17(p18)

All three are listed as threatened communities under the Flora and Fauna Guarantee Act 1988.^2(p71) When the Scientific Advisory Committee considered Cool Temperate Rainforest, it found that the community "has undergone a gross geographical decline, particularly in the Otways and Strzeleckis, as a result of land clearing and the effects of fire and timber harvesting".^14(p2)

The Strzelecki Ranges Biodiversity Study, prepared by Biosis Research in 2001, drew on the then-draft West Gippsland Native Vegetation Plan in describing the local form of Cool Temperate Rainforest as "endemic to Victoria, endangered" and saying it "requires all remaining remnants to be protected".^11(p62) The final plan, published in 2003, lists both Cool Temperate Rainforest and Warm Temperate Rainforest in the Strzelecki Ranges bioregion as Endangered, and states that for Endangered vegetation "all remaining areas need to be protected".^4(pp50,101) Citing Peel's 1999 account of Victoria's rainforests, Biosis says Strzeleckis Warm Temperate Rainforest "is endemic to the state and is restricted to the lowland valleys of the Strzelecki Ranges", and describes it as naturally rare and "significantly depleted by clearing".^11(pp27,59) Biosis adds that "Small isolated occurrences of Warm Temperate Rainforest are of National conservation significance".^11(p59) Peel's own account describes the Warm Temperate Rainforest of the Strzeleckis as "smaller remnants surviving agricultural clearing".^15(p23)

Rainforest supports many rare and threatened plants

Rainforest is an ecological community that matters well beyond its size. A state government fact sheet notes that "Covering just 0.14 per cent of the State, rainforests are home to 30 per cent of Victoria's rare or threatened plant species".^18(p1) The rainforest action statement records 84 Victorian plant species that depend on rainforest and its edges, "since they rarely occur outside these habitats".^14(p8) In the Strzeleckis these include the Slender Tree-fern, listed as Critically Endangered in Victoria.^2(p33) Surveys at Turtons Creek in 2024 recorded 554 Slender Tree-ferns, which the authors describe as "the largest population of Cyathea cunninghamii ever documented in Australia" and "approximately 30% of the known Australian population".^12(p14) Biosis also records the nationally rare Sticky Wattle in Strzelecki warm temperate rainforest.^11(p59)

Photograph. Slender Tree-fern (Cyathea cunninghamii) in Cool Temperate Rainforest at Thomas Track, Strzelecki Ranges, 11 July 2026. Photograph: Gippsland Forest Guardians.

A short history of rainforest in the Strzeleckis

Before European settlement the ranges were covered in tall wet forest, with rainforest in the gullies. Much of the Strzelecki Ranges lies within the Country of the Gunaikurnai, who are recognised by the Federal Court and the State of Victoria as the Traditional Owners of a large area of Gippsland. The Lands of the Brataualung clan in South Gippsland run "From Cape Liptrap and Tarwin Meadows, east to the mouth of Merriman Creek; inland to near Mirboo; at Port Albert and Wilsons Promontory".²³ The West Gippsland Regional Catchment Strategy notes that the Strzelecki area also includes the Country of the Bunurong Traditional Owners, and that parts of it do not yet have formal recognition.²⁰

Clearing and abandonment. Colonising settlers moved into the hill country in earnest from 1883 and 1884, cutting scrub by axe, ringbarking trees and burning the debris before sowing grass into the ash.^11(p10) The 1999 regional assessment records that "Wildfires in 1898 destroyed much of the forest on the Strzeleckis, in some ways aiding the clearing attempts", and that many blocks on the rugged eastern side had been abandoned by 1905.^5(p14) By 1930, Biosis reports, "about 60,000 hectares of land had been abandoned and a further 64,000 hectares were in a neglected condition".^11(p10) The rainforest action statement says clearing for agriculture in the nineteenth and early twentieth centuries "had the greatest impact in South Gippsland hills",^14(p9) and the 2008 rainforest field guide says warm temperate rainforests in the region "were almost eliminated through land clearance" and "remain highly depleted".^10(p8)

Parks. Bulga and Tarra Valley National Parks were reserved in 1904 and 1909, "protecting vegetation communities which were characteristic of the Strzelecki Ranges prior to European settlement".^5(p16) They were joined and enlarged as Tarra-Bulga National Park in 1986.^11(p11) The park is one of fourteen parks and reserves in Gippsland jointly managed by the State and the Gunaikurnai.²⁴

Reforestation. The Forests Commission began buying freehold land in the early 1930s, and large-scale planting began in 1946 at Childers and Allambee. APM Forests began planting in the ranges in 1960.^5(p15) The policy, Biosis writes, "was to replant abandoned properties with pine and hardwood forests".^11(p11) In 1993 the Land Conservation Council recalled that when it recommended the Strzelecki Mountain Ash reforestation for hardwood timber production, it had "noted that the objective of the hardwood planting program was to restore the forest so that it will eventually have a similar structure to the original forest. A range of uses were to be provided and no differentiation was made between reforested areas and areas retaining the original forest cover."^25(pp6-7)

From public to private management. In 1993 the Victorian Plantations Corporation was formed, and 7,416 ha of hardwood plantations in the Strzelecki Ranges, mainly 20 to 30 year old Mountain Ash, were transferred to it.^5(p36) During debate on the Victorian Plantations Corporation Bill in May 1993, a letter from the Minister for Natural Resources to the Victorian National Parks Association was incorporated in Hansard. It noted the association's request for "an assessment of the plantation land with its remnant native forest made to determine the presence of any important conservation values in those remnant areas prior to a sale proceeding", and offered an undertaking that the 180 maps of plantation boundaries would be reviewed by the Land Conservation Council.^{26(pp1355-1356)} A Land Conservation Council review that year found that "the greater majority of vested land areas include areas of native forest", most often beside watercourses, and that the "most notable and extensive areas of included native forest" were in the Strzeleckis.^25(pp8-9) The native forest beyond the softwood plantation areas had been set aside "to provide for a range of uses including nature conservation, water production and catchment protection, education, and preservation of scenic values".^25(p8) The Council noted that the Victorian Plantations Corporation Act 1993 "does not prescribe requirements for the protection and management of non-plantation values, nor empower the Corporation to undertake such tasks".^25(p8) When the Legislative Assembly debated the Victorian Plantations Corporation (Amendment) Bill in April 1998, ahead of the sale of the plantations, one member said "There is at least 20 000 hectares of native forest in the Strzelecki Ranges" and that "much of it is rainforest, old-growth forest or regrowth".^27(p1402) Figures from the Department of Treasury and Finance, given to the Assembly in reply, put the Corporation's land in the Strzeleckis at 40,000 ha, of which 13,000 ha was pine plantation and 7,500 ha hardwood plantation, "leaving a residual area of native vegetation of some 14 000 hectares. Of that, 12 000 hectares consists of stream-side areas and gullies with a slope of greater than 20 degrees, which would not be permitted to be logged under the Code of Forest Practices."^27(p1417) The Gippsland Regional Forest Agreement consultation paper of January 2000 records that "During 1998, the Victorian Government sold the plantations formerly managed by the Victorian Plantations Corporation to Hancock Victorian Plantations. Areas of native forest within the general plantation estate have also transferred to management by Hancock Victorian Plantations. Ownership of the underlying Crown land remains with the State."^6(p28) Local reporting at the time put the price at $550 million.²⁸ The consultation paper notes community concerns about "the appropriateness of transfer of public native forest management to private companies".^6(p28) The West Gippsland Native Vegetation Plan of 2003 records that the licence covered 38,000 ha of the Strzelecki State Forest, of which 13,000 ha was softwood and 7,400 ha hardwood. Because HVP is "legally entitled to manage these plantations for commercial purposes", the plan states that the plantation areas "can not be used in the target setting process"; only the remaining 17,600 ha of native vegetation was counted.^4(p48)

Research and rules. Victoria's first Code of Forest Practices was ratified in 1989 and revised in 1996 and 2007. "The first and second versions included prescriptions for rainforest protection. The 2007 version does not: rather, it requires adherence to the conservation measures specified in approved Flora and Fauna Guarantee Action Statements".^14(pp11-12) Statewide sites of significance for rainforest were proposed in 1990 (as cited by Biosis).^11(p51) Peel's statewide account of Victoria's rainforests, which records Warm Temperate Rainforest remnants in the Strzelecki Ranges, was published in 1999.^15(p23) In 2001 Biosis Research, engaged by the Strzelecki Working Group, assessed the conservation values of the plantation estate and surrounding land and recommended protection zones around rainforest, described under How to protect rainforest.^11(p7)

Certification. In 2004 the Hancock Victorian Plantations (HVP) estate was certified against FSC standards by the SmartWood Program of the Rainforest Alliance. Its public summary records that a biodiversity study in the Strzeleckis "has identified critical core areas (high conservation value forests) for conservation of Cool Temperate Rainforest", and that HVP "has a voluntary moratorium in place on timber harvesting in the identified core areas of high biodiversity value in the Strzeleckis".^29(p8) It states that "As a precautionary approach to minimize impact on HCVF areas before their identification, all custodial lands will be treated as HCVF".^29(p5) It also found that HVP "has not systematically assessed HCVF values throughout its estate, though it has done so in the part of its estate most highly regarded by conservation specialists (the Strzelecki Ranges)", and that "There is also a need for stronger monitoring of HCVF values in the Strzeleckis".^29(p25)

A field guide to identifying rainforest boundaries was published in 2008,¹⁰ and the action statement for Victoria's rainforest communities and Myrtle Wilt in 2009.¹⁴ The Scientific Advisory Committee recommended the statewide listing of Warm Temperate Rainforest in 2023.³¹ In 2022 the State published a risk assessment of threatened species and communities for forestry, which included the listed rainforest communities.¹⁶ In 2024 two vegetation surveys of rainforest at Turtons Creek were prepared for the Friends of Turtons Creek and the Gippsland Threatened Species Action Group.^12,32 The surveys recorded Cool Temperate Rainforest along more than 7.5 km of gully lines in the Scenic Reserve, about 36.5 ha,^12(p29) and along more than 4.5 km on the Trust for Nature properties, about 14.5 ha.^32(p29) Across these and adjoining sites, they recorded 554 Slender Tree-ferns.^{12(p14),32(p14)}

In 2025 Assurance Services International (ASI), which accredits certification bodies for FSC, assessed SCS Global Services' certification of the estate. Its final report raised a major non-conformity against SCS for not identifying, in SCS's 2022 to 2024 audits, non-conformities by HVP with eight indicators of the Australian standard (6.2.3, 6.3.3, 6.4.2, 6.5.1, 7.5.2, 7.6.3, 9.1.2 and 9.2.3).³⁰ In the evidence for that finding, ASI stated that HVP's operating standard for identifying rainforest "does not follow the guidance for assessment of rainforest communities" in the field guide, and that "the drone surveys used by [HVP] for initial identification of rainforest for further evaluation are not an appropriate method to assess and identify rainforest".³⁰ The report records the major non-conformity as "On hold".³⁰

How much rainforest remains, and how much is protected

The 1999 Comprehensive Regional Assessment for the Gippsland Regional Forest Agreement estimated that 893 ha of Cool Temperate Rainforest remained in the Gippsland region, out of a modelled 2,207 ha before European settlement, or 40.5 per cent.^5(p157) Of the 893 ha that remained, about 338 ha was in conservation reserves, 179 ha in State forest and 375 ha on private land (our calculation from the assessment's percentages), so only about 38 per cent of what remained was reserved. Private land was defined as including "freehold land and land leased or licensed for plantation purposes".^5(p156) It rated Cool Temperate Rainforest as endangered and rare, including on the criterion that "90 per cent of area is in small patches subject to threatening processes and unlikely to persist", and listed its threats as "Fire, clearing, indirect effects of timber harvesting and of road construction and maintenance".^5(pp164-165)

These figures cover the whole Gippsland region, including Wilsons Promontory. The national reserve criteria used in that assessment say that "All remaining occurrences of rare and endangered forest ecosystems should be reserved or protected by other means as far as is practicable".^5(p150)

The plantation estate sat outside that reserve system. The consultation paper for the Gippsland Regional Forest Agreement explains that land managed by the plantation companies did not meet the national definition of public forest: "Accordingly, areas within the estate have not be [sic] identified as a part of the draft CAR reserve system through the RFA process, although the pre 1750 extent of native forests in the area is considered in establishing reserve targets". The paper records that the Victorian Government "has indicated its intention to ensure full protection of all conservation areas in the Strzelecki Ranges" and would refer the issues raised about the Strzelecki Ranges to the proposed Environmental Assessment Council "to examine future opportunities for protection of native forests in the region".^6(p29)

Current government mapping gives a picture for the Strzelecki Ranges bioregion alone, but the State has two rainforest maps for the area and they differ. The older is the modelled vegetation map for 2005, mapped at 1:100,000.⁷ The newer is the State's statewide rainforest mapping, modelled from satellite imagery taken in 2018 and 2019 and released publicly in 2024.^8,19(p6) We overlaid each map with the State's map of public land management.⁹ All three rainforest types in the bioregion are rated endangered on the 2005 map.⁷

Source: our analysis of DEECA modelled 2005 Ecological Vegetation Classes (NV2005_EVCBCS), DEECA Rainforest Mapping for state-wide Victoria (RAINFOR), DEECA public land management mapping (PLM25) and DEECA bioregion mapping (VBIOREG100), downloaded October 2026. Parks and conservation reserves are areas with an IUCN protected area category of I to IV. "Other public land" includes State forest (including Brataualung Forest Park), creek frontages and other Crown land. The method and full results are in Appendix A. Rows may not add to 100 per cent because of rounding.

On either map, only a small share of the rainforest is in parks and conservation reserves: about 9 per cent on the 2005 map and about 10 per cent on the newer map (Appendix A). The newer map places more of the Cool Temperate Rainforest on Crown land under plantation licence, 1,370 ha or 39 per cent, compared with 27 per cent on the 2005 map. The West Gippsland Regional Catchment Strategy describes the Strzelecki Ranges as "a fragmented landscape with a low proportion of habitat protected through the reserve system".²⁰

The two maps largely disagree about where the rainforest is. Of the 7,209 ha mapped as rainforest on one map or the other, about 550 ha is mapped as rainforest on both (Appendix A). The 7,209 ha is the area mapped as rainforest, not a verified estimate of the rainforest present on the ground. About a quarter of the Cool Temperate Rainforest on the 2005 map is also mapped as Cool Temperate Rainforest on the newer map, and the two maps share almost none of their Warm Temperate Rainforest. Some of the difference will come from the coarse scale of the 2005 map.

Neither map has been checked on the ground in the Strzeleckis. Biosis found that Cool Temperate Rainforest was under-represented in mapping of the 2005 kind.^11(p25) The State's description of the newer map says the Strzelecki Ranges is "the only area of the state that hasnt [sic] been verified" and that "No field validation of this dataset has been undertaken to date". It also says the model over-predicted rainforest, and that misclassified areas such as tree-fern gullies "persist in the modelled rainforest extent in the Strzelecki Ranges".⁸ The same description sets out how the map is to be used: "For areas of modelled rainforest that have been mapped outside of the formal Comprehensive, Adequate and Representative (CAR) reserve system; forest management planners will need to confirm in the field the presence and extent of the rainforest community prior to any forest or fire management activity commencing."⁸ The State's 2022 risk assessment describes its 2018 satellite mapping of rainforest as "generally shown to be accurate", and says it "should be used as the basis for policy and active management in preference to earlier mapping".^16(p42) For the Strzeleckis, the same assessment records the experts' view that "the spatial information regarding rainforest communities in the Strzelecki Ranges is currently poor and that further on-ground assessment is required to determine rainforest boundaries".^16(p48)

In this report, "Crown land under plantation licence" means Crown land that the State licenses to the plantation company. The term describes the legal arrangement, not the vegetation: as the history above shows, the licensed land includes native forest. Land tenure shows who holds the land, not whether, or to what extent, rainforest on that land is protected. Outside parks and conservation reserves, protection depends on the rules that apply to each kind of land, summarised in a table under How to protect rainforest, and on how those rules are applied in the field. The public land map cannot show who manages land under licence, and it cannot separate freehold plantation land from other freehold.⁹ Brataualung Forest Park, including the land declared a forest park in October 2026, is counted as other public land (Appendix A).

The plantation licence for this land is held by HVP Plantations (HVP, formerly Hancock Victorian Plantations), which bought the plantations of the Victorian Plantations Corporation in 1998 and took over management of the native forest within them (see A short history of rainforest in the Strzeleckis).^6(p28) HVP is by far the largest plantation manager in the region. An industry information sheet on the Gippsland forestry hub states that "More than 90% of the plantation area in Gippsland is owned and managed by Hancock Victoria [sic] Plantations".^21(p3) HVP reports that its Gippsland region covers 127,680 ha, of which 84,763 ha is plantation and 32,786 ha is managed for conservation, and it publishes maps of its estate on its website.²² HVP is named often in this report for that reason: it manages almost all of the plantation land in the region.

Figure 1. Rainforest mapped in the Strzelecki Ranges bioregion, shown by land tenure. Source: our analysis of DEECA Rainforest Mapping for state-wide Victoria (RAINFOR), modelled 2005 Ecological Vegetation Classes (NV2005_EVCBCS), public land management mapping (PLM25) and bioregion mapping (VBIOREG100), October 2026. Coloured patches show the statewide rainforest map, enlarged so that they are visible at this scale; grey shows native vegetation on the 2005 map.

Relevant FSC requirements: Criterion 9.1; Annex G, HCV 1.1 and HCV 3.1; Indicators 6.4.1 and 6.5.1.

How to identify rainforest from surrounding forest

Victoria's Code of Practice defines rainforest as closed broadleaved forest with more than 70 per cent foliage cover, "of at least 0.1 ha in area and 20 metres width", including "closed transitional and seral communities with emergent eucalypts (including Cool Temperate Mixed Forest as a recognised subset of rainforest), that are of similar botanical composition to mature rainforests in which eucalypts are absent".^17(p18) Under this definition, a stand with eucalypts emerging above a rainforest canopy can still be rainforest. In practice the hard part is finding the edge of a stand, because rainforest grades into the wet eucalypt forest around it.

The main method used in Victoria is set out in David Cameron's A Field Guide to Rainforest Identification in Victoria. It explains why the method was needed: protecting rainforest "is dependent on the reliable identification of rainforest and, in particular, on the consistent and unambiguous delineation of rainforest boundaries at operational scales in the field".^10(p1) The guide uses "differential species", plants that are much more likely to be found on one side of the boundary than the other, and describes keys of this kind as "the most reliable means of identification of rainforest and adjacent forest vegetation at the operational field scale".^10(p1)

The Ecological Consultants Association of Victoria's draft guideline for comment takes the same approach.¹⁹ It tells assessors to use the Cameron method where rainforest may be present but is not evident from the canopy, and "where the boundary between rainforest and sclerophyll forest is not obvious".^19(p6) It calls the differential species approach "The primary method used to validate" the State's rainforest mapping, and says field sampling "should be undertaken by suitably qualified and experienced ecologists with the ability to identify the key differential species".^19(p7) The guideline notes that it is not endorsed by any government or regulatory body.^19(p4)

The guide also says where a protective buffer begins. "The boundary is where the rainforest margin and the sclerophyll forest margin meet. This is the point at which the rainforest buffer commences and extends, typically upslope, into the sclerophyll forest."^10(p6) It explains that boundaries drawn from plant species are preferred to boundaries drawn from canopy structure alone, which "are almost impossible to manage by prescription".^10(p6)

The rainforest action statement adopts the same approach for public land. Where a boundary is unclear, "the boundary can be determined by using the 'differential species approach'". Where fire, disease or windthrow has temporarily removed the rainforest canopy, "the differential species approach will be the best indicator of the long-term rainforest boundary".^14(p19)

Rainforest identification in the Strzeleckis

The field guide does not suggest that the differential species method is unsuited to identifying Cool Temperate Rainforest, but it describes limitations in determining boundaries at recently disturbed sites and in identifying Warm Temperate Rainforest. "Floristic keys cannot be guaranteed to perform reliably in grossly or recently disturbed sites."^10(p8) Strzelecki warm temperate rainforest remnants "are vanishingly small, highly disturbed, often severely weed invaded and exposed on their margins to edge effects. Consequently, they are very poorly represented in the quadrat database. Their mature condition is almost impossible to define with any confidence".^10(p8) The guide explains that where disturbance "has been extreme and recent, such as in a logging coupe, road verge, logging track, fire line or immediately following a holocaust wildfire event", the floristic signal "is unlikely to accurately reflect the true nature of the long-term vegetation pattern at the site".^10(pp6,8) Its step-by-step instructions say to "Avoid grossly or recently disturbed sites such as timber harvesting coupes and associated tracks, road verges, fire lines or recently burnt sites".^10(p17)

The draft consultants' guideline gives a Strzelecki example of how disturbance affects identification. At a fern gully mapped by the State as Wet Forest, close to what the guideline calls "'mixed' forest dominated by Mountain Ash", the assessors recorded seven differential species for rainforest and three for wet sclerophyll forest, and concluded that the dominant signal was rainforest. The guideline says: "A partial eucalypt canopy does not rule out rainforest, particularly in examples like this where the forest was subjected to significant land disturbances such as extensive logging, fires and clearing." The listed Cool Temperate Rainforest Community was found to be present, "requiring consideration for impacts and permitting".^19(pp9-10)

The guide warns against identifying warm temperate rainforest from one species. Sweet Pittosporum spreads upslope into Damp Forest, and "uncritical application of a single-species definition" can lead to mistakes. True warm temperate rainforest in the region is "typically co-dominated by both Pittosporum undulatum and Myrsine howittiana (Mutton-wood) in riparian settings".^10(p8) In these disturbed stands, five plants that usually indicate eucalypt forest, including Blackwood, Blanket Leaf and Hazel Pomaderris, "swap allegiance to become differential for these disturbed rainforest remnants".^10(p8) The Scientific Advisory Committee likewise notes that White Elderberry, Hazel Pomaderris and Blanket Leaf "may be present" in Strzelecki warm temperate rainforest.^31(p2) The State's 2022 risk assessment describes mapping of Warm Temperate Rainforest in the Strzeleckis as "notoriously challenging and unreliable", and says that upslope Damp Forest invaded by Sweet Pittosporum is "often contiguous with and confused with small and fragmented riparian stands of highly degraded Warm Temperate Rainforest".^16(p48)

Mapping from aerial photographs is a second method. Biosis used it in 2001 to find Cool Temperate Rainforest missing from the draft vegetation maps, looking for the "distinctly dark green canopy" of Myrtle Beech, which is "not as tall as the surrounding Mountain Ash forest and is more closed".^11(p18) The study found that Cool Temperate Rainforest "appears to be under represented by existing mapping".^11(p25)

Photograph. Myrtle Beech at the edge of the Cool Temperate Rainforest at Thomas Track, with a young radiata pine in the foreground, 11 July 2026. Photograph: Gippsland Forest Guardians.

Relevant FSC requirements: Indicators 9.1.1 and 6.4.2; Annex G 1.4, 1.6 and 1.7.

Where does rainforest grow

The rainforest action statement describes Cool Temperate Rainforest as "almost entirely restricted to deeply dissected foothills, gully systems of mountain ranges and montane plateaus". It needs 1200 to 2000 mm of rain a year "and is largely restricted to environments where severe fire occurs at intervals greater than 400 years".^14(p2) In the Strzeleckis, Biosis found it "only found in the highest rainfall areas of Wet Forest associated with the most topographically protected sites", typically on south and south-east facing slopes and in sheltered gullies.^11(p145) Strzeleckis Warm Temperate Rainforest grows lower down, in "the lowland valleys of the Strzelecki Ranges".^11(p59)

The field guide notes that rainforest usually lies downslope of the eucalypt forest beside it, so that "the boundary tends to follow the contour". It recommends searching along the contour rather than up or down the slope when locating a boundary.^10(p10)

Where rainforest has been mapped

Maps show where rainforest has been modelled or recorded, not everywhere it exists. Both of the State's maps are models: the 2005 map was modelled at 1:100,000, and the newer map from satellite imagery (see How much rainforest remains, and how much is protected). The description of the 2005 map says "This is a landscape scale dataset, site verification is required for site based projects".⁷ The rainforest action statement notes that in statewide mapping at 1:100,000, "linear strips of rainforest mapped at this scale are likely to be inaccurate".^14(p14) The action statement recognises stands as small as 0.1 ha, and linear stands 20 to 40 m wide.^14(p19) Rainforest is confirmed on the ground, using the field methods described under How to identify rainforest from surrounding forest, and the description of the State's newer map says that forest management planners "will need to confirm in the field the presence and extent of the rainforest community prior to any forest or fire management activity commencing".⁸ We found no published field survey of rainforest across the plantation estate since the Biosis study of 2000 (see The limits of what we know).

Biosis identified five core areas of high biodiversity value in and around the plantation estate in the central Strzeleckis: Gunyah Gunyah, Jack River, College Creek, Tarra-Bulga National Park and Upper Merriman Creek.^11(p51) It describes Gunyah Gunyah and College Creek as "of National conservation significance".^11(p51) College Creek, mostly outside the estate, is "a site of national significance", and Slender Tree-ferns are recorded there.^11(p54) At Turtons Creek, surveys in 2024 recorded Cool Temperate Rainforest along more than 7.5 kilometres of gully lines, "with a total area of approximately 36.5 hectares".^12(p29)

Mapping is uneven. Biosis built its rainforest map from draft government mapping, field observations, hand mapping by naturalists and aerial photographs, and notes that the data came "from a range of different sources, with non-uniform mapping standards".^11(p39) It found Cool Temperate Rainforest to be under-represented on existing maps.^11(p25) A 2019 state government fact sheet says "Victoria's maps are outdated due to the impacts of bushfires" and that accurate mapping is needed "for delineating buffer areas for forest planning".^18(p2) Statewide rainforest mapping was prepared by the Arthur Rylah Institute in 2018 for the renewal of the Regional Forest Agreements, and found that forest dominated by rainforest species makes up "no more than 0.153% of the land surface of Victoria". The draft consultants' guideline says this layer, released publicly in 2024, should be used in place of vegetation class mapping, and that the older layers "are now out of date (but not yet superseded)".^19(pp1,6)

The boundaries of rainforest can move

Several sources describe rainforest boundaries as changing over time. The rainforest action statement says "it is the relative absence of fire rather than the abundance of rainfall which characterises the environmental niches occupied by rainforest".^14(p8) The Arthur Rylah Institute describes absence of fire as "the most potent factor that determines rainforest distribution over a broad scale".³³ Biosis records that "On some southern slopes that remain long-unburnt, the community can extend upslope beyond its usual gully refuge, even to minor saddles".^11(p145) The field guide similarly notes that "small groves or copses of Nothofagus cunninghamii (Myrtle Beech) often occur upslope of core stands of Cool Temperate Rainforest in tall open-forests dominated by Eucalyptus regnans (Mountain Ash)".^10(p6)

The reverse also happens. After high-severity fire in the O'Shannassy catchment, the Arthur Rylah Institute found that eucalypt regeneration was so prolific "that around two thirds of the rainforest mapped pre-fire could no longer be classified as such and has been lost".³³

Biosis described its 250 m zones around rainforest as "a precautionary management strategy to protect this endangered community from the spread of Myrtle Wilt, to allow the natural ecosystem processes to operate and to allow this rainforest to expand its current extent".^11(p69) It expected that over time a precautionary approach would "allow areas of Cool Temperate Rainforest to increase in area".^11(p5) The 250 m figure came from Tasmania. Biosis reports that Packham (1991) "observed the spread of Myrtle Wilt from damage due to roading or logging activities and recommended a minimum buffer zone of 250 metres to control its spread". Cameron and Turner (1996) did not recommend a buffer width, but Biosis reasoned that, because they found the community more vulnerable in Victoria than in Tasmania, "a minimum buffer of 250 metres is required to minimise the extinction threat to this EVC".^11(p43) The field guide's description of the boundary as the point where the buffer "commences and extends, typically upslope" is relevant here.^10(p6)

The forest around the rainforest

In the Strzeleckis, rainforest gullies sit within tall Mountain Ash forest. Biosis found Cool Temperate Rainforest only "in the highest rainfall areas of Wet Forest associated with the most topographically protected sites".^11(p145) The field guide places the protective buffer in that surrounding forest, extending "typically upslope, into the sclerophyll forest".^10(p6) Biosis described a buffer of two tree heights as the minimum needed to protect rainforest "and its ecotone", the transition zone between the two forest types.^11(p69)

Mountain Ash forest has itself been assessed as at risk. Applying the IUCN Red List of Ecosystems criteria, Burns and colleagues rated the Mountain Ash forest of the Central Highlands of Victoria as Critically Endangered, finding that all 39 scenarios they modelled "indicated a ≥92% chance of ecosystem collapse by 2067".^34(p386) The assessment is recorded in the IUCN Red List of Ecosystems, which lists the Mountain Ash forest of the Central Highlands as Critically Endangered and describes it as covering about 157,000 ha.^35(pp2,4) Both the paper and the listing cover the Central Highlands only. The paper notes that Mountain Ash also dominates forests elsewhere in Victoria and in Tasmania, but that "several key aspects differentiate those forests" from the Central Highlands ecosystem.^34(p387)

The Australian Government is assessing a wider ecological community, "Mountain ash forests of central and eastern Victoria", for possible listing as threatened under the EPBC Act. A preliminary information sheet for local government lists where it occurs as "Central Highlands, Strzelecki Ranges, Wilsons Promontory, and East Gippsland", gives its status as "National (Not listed); Vic (Not listed)", and names "activities associated with timber harvesting" among the main threats across its range or parts of its range.³⁶ The Minister has extended the timeframe for the assessment to 30 April 2027, to allow more information to be collected and for public consultation.³⁷

A paper by Lindenmayer and colleagues, published online in 2023, which makes the case for listing the Central Highlands forests as a threatened ecological community under the EPBC Act, also reports figures for the Gippsland Regional Forest Agreement area, where Mountain Ash grows "primarily across the Strzelecki Ranges".^38(pD) Of the 50,468 ha of Mountain Ash forest it records there, 14 per cent is in nature conservation reserves and 24,394 ha, almost half, is plantation forestry land.^38(pC) It estimates that 44 per cent of the former extent of the Wet Forest in which Mountain Ash dominates has been lost in that area, mostly in the Strzeleckis, and that "Remaining areas of Mountain Ash in the Strezlecki [sic] Ranges are mostly located in areas designated as plantation land tenure".^38(pG)

Relevant FSC requirements: Indicators 9.1.1 and 6.4.2; Glossary, High Conservation Value Areas; Annex G 1.5.

What harms rainforest

The rainforest action statement lists the risks of harvesting trees adjacent to rainforest as "changes to the rainforest microclimate, physical damage from tree felling or windthrow, spread of weeds and/or disease, altered hydrology, sedimentation" and related effects.^14(p10) The Scientific Advisory Committee also found that "streamside reserves and buffer strips are frequently logged or damaged".^14(p2) The main threats described in the sources are set out below.

Myrtle Wilt

Biosis describes Myrtle Wilt as "a fatal disease of Myrtle Beech Nothofagus cunninghamii, the structural dominant of CTR". "As fungal spores are wind dispersed, rainforest near edges created by clearfelling may be exposed to elevated levels of inoculum, and any forest activity that causes wounds to Myrtle Beech trees also has the potential to elevate disease incidence rates."^11(p43) "Human activity [such as forestry] which results in artificially elevated or epidemic levels of Myrtle Wilt within Nothofagus-dominated Cool Temperate Rainforest" remains a listed potentially threatening process.^39(p3)

In Tasmania, Kile and colleagues found that "the proportion of diseased trees decreased with distance from the road" in a severely affected roadside area, and that where disease levels in logged and thinned areas fell back to normal, "it took an average of 9 years (range 4-13.5 years)".^13(p258) They concluded that "Prevention of wounds on N. cunninghamii in any operations in rainforest is an essential element in any strategy to minimise disease development".^13(p262) They also noted that plots to measure how fast the disease spreads "have only recently been established in Tasmanian rainforest".^13(p263)

The action statement says Myrtle Wilt occurs "to a lesser degree, in the Strzelecki Ranges", where stands with Southern Sassafras or Blackwood are less susceptible in undisturbed conditions.^14(p9) Biosis, drawing on Cameron and Turner (1996), notes that small isolated patches leave the community "particularly vulnerable to local and possibly regional extinction if the infection level of Myrtle Wilt is raised above existing levels", and that Myrtle Wilt "needs to be managed as a threatening process at a landscape scale as well as an edge effect in a local context".^11(p43)

Drying, wind damage and trees falling into rainforest gullies at the edge

The 2024 Turtons Creek survey states that "CTR requires an adequate buffer of native vegetation to prevent exposure to sunlight and strong winds, both of which can lead to drying of CTR. Strong winds can also lead to increased tree fall, causing damage to CTR understorey and further exposure to sunlight."^12(p28) The action statement summarises a University of Melbourne study by Parry (1997) that measured radiation, temperature and humidity "across the first 100 m of edge environment" in wet forest, which "can be used to assess the effectiveness of buffers of various widths".^14(p14) At Nadgee State Forest in New South Wales, a Slender Tree-fern gully's rainforest canopy deteriorated, which Peacock and colleagues describe as "most likely a response to intensive harvesting without adequate buffering".^40(p15)

Weeds, deer and herbicide

The Turtons Creek survey recommends annual monitoring and control of feral deer and regular control of high-threat weeds, including Wandering Tradescantia, Tutsan and Forest Blackberry.^12(p29) It warns that without adequate buffers, rainforest "will likely be degraded by increased exposure, strong winds, tree fall and herbicide drift".^12(p29)

Fire

The 1999 regional assessment lists fire first among the threats to both Cool and Warm Temperate Rainforest.^5(p165) After the 2019 to 2020 bushfires, "78% of WTR was impacted by fire, with 33% impacted by high severity fire".^31(p3) The Slender Tree-fern action statement notes that forestry operations "may alter structure and composition of adjacent vegetation, leading to increased risk of bushfire severity and drying of the habitat".^41(p3)

High impact land uses adjacent to rainforest

In the Strzeleckis, much rainforest adjoins land in the plantation estate. Biosis notes that Mountain Ash trees "require more than 120 years of growth before hollows develop, while the current harvesting rotation times in the Strzelecki Ranges are about 30 years".^11(p62) Biosis made that observation in 2001, 25 years ago. The 1999 regional assessment records that the Mountain Ash plantations transferred to the Victorian Plantations Corporation in 1993 were mainly 20 to 30 years old,^5(p36) so any of those stands not harvested since would now be about 53 to 63 years old.

Relevant FSC requirements: Indicators 9.2.1, 6.2.3 and 6.4.3; Annex G 1.8.

How to protect rainforest

What the rules say

Victoria's Code of Practice for Timber Production treats rainforest differently on different kinds of land, depending on land tenure. In State forest, "Rainforest communities must not be harvested".^17(p38) In private native forest, "Rainforest communities in Victoria must not be harvested. Rainforest communities must be protected from the impacts of harvesting through the use of appropriate buffers to maintain microclimatic conditions and protect from disease and other disturbance".^17(p58) For plantations, harvesting planning must "address the conservation of biodiversity, including rainforest, in accordance with relevant laws", and "Retained native vegetation must be protected from damage caused by timber harvesting operations".^17(p70)

The sources describe the reach of these rules differently. The 2008 field guide says the requirement "applies to rainforest in both public forests and private native forests or plantations".^10(p1) The 2009 action statement describes it as applying "in public and private native forests", and says that "In private native forests and plantations, the Code recommends the application of protection measures specified in relevant Flora and Fauna Guarantee Act Actions Statements, as applicable to private land".^14(pp12-13) For private land, the action statement's objective is "To plan and undertake activities on private land to avoid impacts on FFG-listed rainforest communities", with the target of a "net gain achieved for FFG-listed rainforest communities on private land".^14(p16)

On public land, the action statement sets minimum buffers. Linear stands of 0.2 to 0.4 ha "must be protected by a 20 m buffer". "Rainforest stands (including linear stands) equal to or exceeding 0.4 ha must be protected by a vegetated buffer of a minimum width of 40 m." In the core of National Sites of Significance for Rainforest, whole sub-catchments are protected, "with buffers to the nearest watershed".^14(pp19-20)

The Code treats land "licensed or vested under the Victorian Plantations Corporation Act 1993" as private land, not public land.^17(pp17-18) Timber harvesting on private land is covered by Chapter 3 of the Code for native forest and Chapter 4 for plantations.^17(p26) The table below summarises the rules the sources describe for rainforest on each kind of land outside parks and conservation reserves.

What the research recommends

Biosis reviewed the older Code prescription of "a 60 metre buffer, or a 40 metre buffer and a further 40 metres of lower intensity harvesting" and wrote: "we do not consider this prescription to be an adequate precaution for these significant and sensitive stands of vegetation (see also Burgman and Ferguson 1995). From an ecological perspective, a buffer of two tree heights or about 100 metres is necessary to provide the minimum protection for this threatened community and its ecotone."^11(p69) It applied protection zones of 250 m to all rainforest mapped at 1:25,000 as "a precautionary management strategy to protect this endangered community from the spread of Myrtle Wilt".^11(p69)

Sources describe two kinds of protection zone, measured in different ways.

• A rainforest buffer is measured outward from the rainforest boundary: the boundary "is the point at which the rainforest buffer commences and extends, typically upslope, into the sclerophyll forest".^10(p6)

• A species management area, such as the one prescribed for the Slender Tree-fern, is a radius around a population: "a management area of 200 m radius over populations".^41(p6) A radius around a population and a buffer around a stand of rainforest are measured from different points, so their widths cannot be compared directly.

The table brings together the widths recommended or required in the sources. The widths are not directly equivalent: they relate to different vegetation types, threats and settings, and include minimum prescriptions, recommendations from studies and a species management radius.

Biosis also proposed a short-term moratorium on harvesting "within 250 metres of Cool Temperate Rainforest and records of any significant flora species".^11(p5) Its other interim measures included retaining mature trees, retiring selected coupes, lengthening rotations and not harvesting adjacent coupes at the same time.^11(pp64-67)

Two further points recur. The field guide places the start of any buffer at the floristic boundary, extending "typically upslope, into the sclerophyll forest".^10(p6) And the Turtons Creek survey, drawing on Peacock and colleagues, notes that prescriptions that may buffer Slender Tree-ferns "are only effective if adequate pre-harvesting surveys are first undertaken to identify the species occurrence".^12(p14) The State's 2022 risk assessment notes that the Slender Tree-fern "can be difficult to identify in the field and may have been overlooked in preharvest surveys".^16(p39)

What the largest plantation manager's plan says

HVP's High Conservation Values Assessment and Management Plan, revised in April 2026 after stakeholder consultation, covers its whole estate in Victoria.^43(p2) It records 1,734 ha of HCV 3.1, "Threatened or depleted ecosystems or habitats", across that estate.^43(p17) It says HCV 3.1 includes "Rainforest communities, including Cool Temperate Rainforest and Warm Temperate Rainforest types", and that these ecosystems "are protected from harvesting and managed through buffers, weed control, hydrological protection and, where appropriate, ecological burning or restoration".^43(p29) It assigns "All rainforest areas" to HCV 1.6 (refugia), and says these areas "are protected from harvesting and managed to retain canopy cover, hydrological function and habitat integrity".^43(p25) It records the Slender Tree-fern on its estate in the Strzeleckis, including "along riparian corridors in Turtons Plantation".^43(p23)

On how rainforest is found, the plan says that where site values assessments identify areas that potentially contain high conservation values, "targeted field validation is undertaken using survey methods appropriate to the value type to confirm presence prior to operations".^43(p20) Its measures for HCV 3 include "Detailed native vegetation mapping and ongoing field verification" and "Rainforest identification and protection procedures with applied buffers".^43(p30) The plan does not state the buffer widths applied to rainforest or the method used to locate rainforest boundaries, so a reader cannot tell from these documents alone what widths are applied or how boundaries are found. It refers to a technical addendum for the detailed assessment.^43(pp23,51)

The technical addendum, dated April 2026, has not been published on HVP's website; HVP provided a copy to Gippsland Forest Guardians.⁴⁴ It assigns HCV status to "vegetation communities listed under the EPBC Act 1999 or the Flora and Fauna Guarantee Act 1988", and lists Cool Temperate Rainforest, Cool Temperate Mixed Forest and Strzeleckis Warm Temperate Rainforest among the communities "assigned HCV status where detected".^44(pp54-55) It says that "Rainforest communities are protected by buffers where they are confirmed to exist in the field",^44(p61) but it does not state buffer widths either. Its list of spatial datasets includes HVP's own layer of "Areas that have been confirmed as Cool Temperate Rainforest" and the State's modelled layer of threatened communities.^44(p7)

The 2025 ASI assessment (see A short history of rainforest in the Strzeleckis) quotes HVP's 2018 "Operating standard for the identification and protection of rainforest on company land". Where the foliage cover of rainforest canopy species is 70 per cent or less, the standard considers whether Myrtle Beech is "present as mature individuals with evidence of regeneration", whether "The stand is at least 40 metres wide (measured horizontally) and greater than 3 hectares in area", and whether "populations of at least 5 differential Rainforest understory species are present".³⁰ By comparison, the Code's definition of rainforest applies to stands "of at least 0.1 ha in area and 20 metres width".^17(p18)

The precautionary principle

Both the legislation and voluntary sustainability standards covered in this report include the concept of a precautionary principle. It is a principle of the Flora and Fauna Guarantee Act 1988 that decisions, policies, programs and processes give proper consideration to "the precautionary principle, such that if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation".⁴² The Code of Practice uses the same definition, and requires that in State forest "The precautionary principle must be applied to the conservation of biodiversity values".^17(pp17,38) The FSC standard requires certified forest managers to maintain or enhance high conservation values "through applying the precautionary approach". It defines this as taking "explicit and effective measures to prevent the damage" when "the available information indicates that management activities pose a threat of severe or irreversible damage to the environment", "even when the scientific information is incomplete or inconclusive".^1(pp55,94)

This report does not recommend buffer widths. It sets out the widths found in the published research and in the rules, and the gaps in knowledge that the sources themselves describe (see The limits of what we know).

Where the evidence is incomplete, each of the instruments above provides for a precautionary principle.

Relevant FSC requirements: Indicators 9.2.2, 9.2.3, 9.3.1, 9.3.2, 9.3.3, 6.3.3 and 6.4.4; Annex G, management guidance for HCV 3; Principle 9 (precautionary approach).

Watching for change

The rainforest action statement sets out several monitoring actions. One is to "Progressively map and monitor on a periodic basis the extent of Myrtle Wilt throughout the range of Myrtle Beech, using the methods of Cameron and Turner (1996)". Another is to establish monitoring at representative sites. A third is to continue annual Code of Practice audits and, where rainforest is a prominent feature, to "ensure that the audits focus on rainforest protection issues".^14(p15) It also calls for research on how effective buffers are in "protecting these communities from changes in microclimate and physical disturbance".^14(p17)

The 2019 fact sheet describes improved mapping as "a baseline measure for monitoring change in rainforest distribution over time".^18(p1) The Turtons Creek survey recommends annual monitoring of feral deer and regular weed control.^12(p29) The Tasmanian study's finding that disease levels took an average of nine years to settle after logging gives some idea of the period over which effects on Myrtle Beech can show.^13(p258) A condition of the 2004 certification of the plantation estate required that "Throughout the certification period, HVP will join with State Government programs to monitor the incidence of myrtle wilt in cool temperate rainforest on HVP estate".^29(p30)

Relevant FSC requirements: Criteria 9.4 and 8.2; Indicator 7.6.3; Annex F (monitoring under Criteria 6.4 and 9.1); Annex G 1.9.

The limits of what we know

The sources are open about the gaps. The field guide says the data available for the Strzelecki Ranges "are quite incomplete", especially at warm temperate elevations, and that its methods were relaxed to cope.^10(p4) The rainforest action statement lists, among knowledge gaps, information on the disturbance history and condition of important stands, which "would further inform judgements regarding, for example, effective buffer widths".^14(p11) The 2019 fact sheet describes Victoria's rainforest maps as "outdated".^18(p2) In 2022 some of the State's experts considered that "more evidence is needed to demonstrate the effectiveness of rainforest buffers in protecting rainforest stands and their component species".^16(p43) For Strzeleckis Warm Temperate Rainforest, the assessment found that the level of risk from forestry "could not be reliably assessed", and listed as a priority action "accurate mapping, including on-ground verification, of Warm Temperate Rainforest stands in the Strzelecki Ranges in consultation with Hancock Victorian Plantations".^16(p48)

Where the information is incomplete or unclear, the Flora and Fauna Guarantee Act, the Code of Practice (for State forest) and the FSC standard all call for a precautionary approach. Under the Act and the Code, "lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation",^42,17(p17) and the FSC standard requires measures to prevent damage "even when the scientific information is incomplete or inconclusive".^1(p94)

The Biosis study was also limited, as its authors explain. The report "relies heavily on existing data sets", including draft vegetation mapping, and "should not be seen as a conclusive and comprehensive document".^11(p13) Fieldwork on the plantation estate was two trips in August 2000, of five and four days.^11(p15) The authors note that late winter and early spring is "not considered to be optimal for vegetation surveys", that "only main roads were utilised, as many of the tracks are impassable during these months", and that survey sites were limited to relatively major roads "and not in relatively inaccessible areas such as forested gullies".^11(pp14-15) Forested gullies are where Cool Temperate Rainforest grows in the Strzeleckis (see Where does rainforest grow). The fauna survey was "conducted during poor weather, with rainfall and strong winds on most days", and "Many of the roads within the study area were impassable due to wet conditions and fallen trees".^11(p17) The vegetation survey recorded thirty quadrats,^11(p22) and the authors state that "It was not possible, therefore to fully describe the attributes of the estate".^11(p15)

How current is the evidence

Much of the evidence is old. The main Strzelecki-specific study, by Biosis, was carried out in 2000 and published in 2001. The government vegetation map is modelled at 1:100,000 and dates from 2005. The State's newer rainforest map is based on satellite imagery from 2018 and 2019 and has not been verified in the Strzeleckis.⁸ The rainforest action statement dates from 2009 and describes the 2007 Code, so it should be read alongside the 2022 Code. The regional reserve figures date from 1999. Only the listing documents and threatened lists used here are current editions.

Neither of the rainforest maps takes account of recent fires. The newer map is based on imagery from 2018 and 2019 and its metadata gives a publication date of November 2019, before the 2019 to 2020 bushfires,⁸ which affected 78 per cent of Warm Temperate Rainforest across Victoria.^31(p3) After severe fire in the O'Shannassy catchment, the Arthur Rylah Institute found that around two thirds of the rainforest mapped before the fire could no longer be classified as rainforest.³³ In researching for this report, we found no published assessment of how fire since 2019 has affected rainforest in the Strzeleckis.

Documents we could not obtain

We were not able to read several documents that later sources rely on: Cameron's 1990 proposed sites of significance for rainforest; Burgman and Ferguson's 1995 review of rainforest protection measures; Cameron and Turner's 1996 survey of Myrtle Wilt; Packham's 1991 report on Myrtle Wilt; Parry's 1997 study of edge effects; the floristic community descriptions in Peel's 1999 account of Victoria's rainforests (we have read only its third chapter); and the forest certification audit reports for the Strzelecki plantation estate from 2004 to 2007. Where this report refers to them, it relies on how they are described in sources we have read.

Relevant FSC requirements: Indicators 6.1.1 (item 8), 6.4.2 (item 4), 6.5.1 and 9.3.2; definition of precautionary approach.

Implications arising from this report

Questions for land managers

The sources raise a number of questions for anyone managing land beside rainforest in the Strzeleckis.

• How is rainforest looked for and when found, how are rainforest boundaries located? Is the differential species method used as recommended?^10(p1)

• Where are the starting points for any buffer measured, and does it extend from the floristic boundary into the surrounding forest as the field guide describes?^10(p6)

• Where the forest beside a stand of rainforest has recently been harvested, so that the field guide's method cannot be applied there, how is the boundary located?^10(pp8,17)

• How do buffers that are applied next to rainforest compare with the 20 m and 40 m public land minimums, the 100 m and 250 m recommended by Biosis, and the 200 m recommended by Just and Osler?^{14(pp19-20),11(pp68-69),12(p29)}

• How are the different descriptions of the Code's requirements being applied to rainforest on land under plantation licence?^{17(pp58,70),10(p1),14(pp12-13)}

• Are pre-harvest surveys for all types of rainforest, and for Slender Tree-ferns, carried out before any disturbing activities take place and buffers are determined?^8,12(p14)

• Is Cool Temperate Mixed Forest looked for before harvesting in Mountain Ash forest beside rainforest, given that it is not mapped and may be recorded as Wet Forest?^{3(p3),16(p42)}

• Has rainforest modelled on land under plantation licence been confirmed in the field before harvesting, as the description of the State's rainforest map says planners will need to do?⁸

• Are Myrtle Wilt, edge conditions and weed spread being monitored beside harvested areas?^14(p15)

• With effective buffer widths still listed as a research question, how is the uncertainty taken into account when planning and implementing activities such as forestry?^14(pp11,17)

See the FSC cross-reference table in Appendix B.

Who and where are the experts who hold further knowledge?

The organisations below hold data, records or expertise relevant to rainforest in the Strzeleckis.

• Department of Energy, Environment and Climate Action (DEECA). Holds the state vegetation mapping, the Victorian Biodiversity Atlas and the threatened species lists, and is responsible for action statements.

• Arthur Rylah Institute for Environmental Research. The state's environmental research institute; its work includes rainforest mapping and the effects of fire on rainforest.

• Flora and Fauna Guarantee Scientific Advisory Committee. Assesses nominations for listing threatened communities and species.

• Royal Botanic Gardens Victoria. Holds the National Herbarium of Victoria and the VicFlora online flora.

• Parks Victoria. Manages Tarra-Bulga National Park and other reserves containing rainforest.

• Trust for Nature. Holds and covenants private land at Turtons Creek where rainforest has been surveyed.

• Friends of Turtons Creek and the Gippsland Threatened Species Action Group. Commissioned the 2024 Turtons Creek surveys.

• Biosis. Prepared the 2001 Strzelecki Ranges Biodiversity Study.

• Gunaikurnai Land and Waters Aboriginal Corporation. The Registered Aboriginal Party for Gunaikurnai Country.²³ The Scientific Advisory Committee notes that knowledge of Warm Temperate Rainforest "may be held by Indigenous Australians who are the custodians of this knowledge and have the rights to decide how this knowledge is shared and used".^31(p2)

Relevant FSC requirements: definition of best available information (expert opinions, contact information); Indicators 9.1.2, 9.2.3 and 7.6.3.

References

1. Forest Stewardship Council Australia. FSC National Forest Stewardship Standard of Australia (FSC-STD-AUS-01-2018 EN). Forest Stewardship Council Australia; 2018. Accessed October 12, 2026. https://open.fsc.org/handle/resource/263 Copy held by Gippsland Forest Guardians: GFG copy.

2. Department of Energy, Environment and Climate Action. Flora and Fauna Guarantee Act 1988 Threatened List: July 2026. Department of Energy, Environment and Climate Action; 2026. Accessed October 5, 2026. https://www.environment.vic.gov.au/conserving-threatened-species/threatened-list Copy held by Gippsland Forest Guardians: GFG copy.

3. Flora and Fauna Guarantee Scientific Advisory Committee. Final Recommendation on a Nomination for Listing: Cool Temperate Mixed Forest Community (Nomination No. 825). Department of Sustainability and Environment; 2012. Accessed October 18, 2026. https://www.environment.vic.gov.au/__data/assets/pdf_file/0035/587429/Nom825_Cool_Temperate_Mixed_Forest_Community_FRR.pdf

4. West Gippsland Catchment Management Authority. West Gippsland Native Vegetation Plan. West Gippsland Catchment Management Authority; June 2003 (vegetation class and conservation status information updated February 2008). Accessed October 17, 2026. https://wgcma.vic.gov.au/wp-content/uploads/2023/03/2003-Native-Vegetation-Plan.pdf Copy held by Gippsland Forest Guardians: GFG copy.

5. Commonwealth and Victorian Regional Forest Agreement Steering Committee. Gippsland Comprehensive Regional Assessment Report. Commonwealth of Australia; September 1999. Accessed October 11, 2026. https://www.agriculture.gov.au/sites/default/files/sitecollectiondocuments/rfa/regions/vic-gippsland/regional-assessment/vic_gippscra.pdf

6. Joint Commonwealth and Victorian Regional Forest Agreement Steering Committee. Gippsland Regional Forest Agreement Consultation Paper. Joint Commonwealth and Victorian Regional Forest Agreement Steering Committee; January 2000.

7. Department of Energy, Environment and Climate Action. Native Vegetation: Modelled 2005 Ecological Vegetation Classes (with Bioregional Conservation Status) [dataset]. Department of Energy, Environment and Climate Action. Accessed October 5, 2026. Metadata record: https://metashare.maps.vic.gov.au/geonetwork/srv/api/records/a502df15-7b90-5e96-b1a0-ba29e95558b2/formatters/xsl-view?root=div&view=advanced. Data available from: https://discover.data.vic.gov.au/dataset/native-vegetation-modelled-2005-ecological-vegetation-classes-with-bioregional-conservation-sta

8. Department of Energy, Environment and Climate Action. Rainforest Mapping for State-wide Victoria (RAINFOR) [dataset and metadata]. Published November 16, 2019; updated November 25, 2025. Accessed October 10, 2026. Metadata record: https://metashare.maps.vic.gov.au/geonetwork/srv/api/records/ce5f8bb3-a66d-5c23-bb50-29d99f0ad6c3/formatters/xsl-view?root=div&view=advanced. Data available from: https://discover.data.vic.gov.au/dataset/rainforest-mapping-for-state-wide-victoria

9. Department of Energy, Environment and Climate Action. Public Land Management (PLM25) [dataset]. Department of Energy, Environment and Climate Action. Accessed October 5, 2026. Metadata record: https://metashare.maps.vic.gov.au/geonetwork/srv/api/records/7cb9cfb1-86ff-5432-bf9b-e3070d04f507/formatters/xsl-view?root=div&view=advanced. Data available from: https://discover.data.vic.gov.au/dataset/public-land-management-plm25

10. Cameron D. A Field Guide to Rainforest Identification in Victoria: Differential Species Keys for the Delineation of Rainforest Boundaries. Department of Sustainability and Environment; 2008. Accessed October 5, 2026. https://assets.nationbuilder.com/gfg/pages/727/attachments/original/1761793686/A_Field_Guide_to_Rainforest_Identification_in_Victoria_-_David_Cameron_reduced.pdf?1761793686

11. Hill A, Timewell C, McCormick S, et al. Strzelecki Ranges Biodiversity Study. Report prepared for the Strzelecki Ranges Working Group. Biosis Research; 2001. Accessed October 5, 2026. https://www.southgippsland.vic.gov.au/download/downloads/id/1749/strzelecki_ranges_biodiversity_study_2001.pdf Copy held by Gippsland Forest Guardians: GFG copy.

12. Just K, Osler D. Vegetation Survey of Cool Temperate Rainforest Occurring Within the Turtons Creek Scenic Reserve. Report prepared for the Friends of Turtons Creek; 2024. Accessed October 5, 2026. https://assets.nationbuilder.com/gfg/pages/727/attachments/original/1767165840/Report-_Turtons_Creek_Scenic_Reserve_Vegetation_Assessment_-_December_2024.pdf?1767165840

13. Kile GA, Packham JM, Elliott HJ. Myrtle wilt and its possible management in association with human disturbance of rainforest in Tasmania. New Zealand Journal of Forestry Science. 1989;19(2/3):256-264. Accessed October 5, 2026. https://www.scionresearch.com/__data/assets/pdf_file/0008/59984/NZJFS192-and-31989KILE256_264.pdf

14. Department of Sustainability and Environment. Action Statement No. 238: Victorian Rainforest Communities and Myrtle Wilt. Flora and Fauna Guarantee Act 1988. Department of Sustainability and Environment; 2009. Accessed October 5, 2026. https://bio-prd-naturekit-public-data.s3.ap-southeast-2.amazonaws.com/actionstmts/Cool_Temperate_Rainforest_TC_007-011-036-037-038-039.pdf Copy held by Gippsland Forest Guardians: GFG copy.

15. Peel B. Rainforests and Cool Temperate Mixed Forests of Victoria. Department of Natural Resources and Environment; 1999. Chapter 3 consulted. Copy supplied by the National Library of Australia, Nq 577.3409945 P641.

16. Department of Environment, Land, Water and Planning. Threatened Species and Communities Risk Assessment: Tranche 1 Permanent Protections. Department of Environment, Land, Water and Planning; September 2022. Accessed October 19, 2026. https://www.environment.vic.gov.au/__data/assets/pdf_file/0032/595193/TSCRA-Tranche-1-Permanent-Protections-Report-September-2022.pdf

17. Department of Environment, Land, Water and Planning. Code of Practice for Timber Production 2014 (as amended 2022). Department of Environment, Land, Water and Planning; 2022. Accessed October 5, 2026. https://www.forestsandreserves.vic.gov.au/__data/assets/pdf_file/0032/573818/Code-of-Practice-for-Timber-Production-2014-as-amended-2022.pdf Copy held by Gippsland Forest Guardians: GFG copy.

18. Department of Environment, Land, Water and Planning. Fact Sheet 2: Mapping Victoria's Rainforests. Department of Environment, Land, Water and Planning; 2019. Accessed October 5, 2026. https://www.delwp.vic.gov.au/__data/assets/pdf_file/0022/413095/2-Rainforest-factsheet-FINAL.pdf Copy held by Gippsland Forest Guardians: GFG copy.

19. McCaffrey N. Guideline: Identifying and Assessing Rainforest in Victoria. Draft for comment. Ecological Consultants Association of Victoria; 2024. Accessed October 10, 2026. https://ecavic.org.au/wp-content/uploads/2024/12/Guideline-identifying-and-assessing-rainforest-in-Victoriax.pdf

20. West Gippsland Catchment Management Authority. Strzelecki. West Gippsland Regional Catchment Strategy. Accessed October 11, 2026. https://westgippsland.rcs.vic.gov.au/local-areas/local-area-6/

21. Greenwood Strategy Solutions. Private Forestry Guidance Materials, Information Sheet 10: Gippsland Forestry Hub. Forest and Wood Products Australia; October 2023. Accessed October 13, 2026. https://fwpa.com.au/wp-content/uploads/2024/01/FWPA_Information-Sheet_10-Gippsland-Forestry-Hub.pdf

22. HVP Plantations. Maps & Area. Accessed October 13, 2026. https://www.hvp.com.au/hvp-forest-management/area-maps/

23. Gunaikurnai Land and Waters Aboriginal Corporation. Our story. Accessed October 6, 2026. https://gunaikurnai.org/our-story/

24. Gunaikurnai Land and Waters Aboriginal Corporation. Tarra-Bulga National Park. Accessed October 11, 2026. https://gunaikurnai.org/our-country/joint-management/tarra-bulga-national-park

25. Land Conservation Council. Review of Victorian Plantations Corporation Vested Lands. Report to the Minister for Planning. Land Conservation Council; 1993. Accessed October 11, 2026. https://assets.nationbuilder.com/gfg/pages/727/attachments/original/1791691402/LCC_1993_Review_VPC_Vested_Lands.pdf?1791691402

26. Victoria, Legislative Council. Parliamentary Debates (Hansard). May 26, 1993;412:1347-1356. Accessed October 10, 2026. https://hansard.parliament.vic.gov.au/images/stories/volume-hansard/Hansard%2052%20LC%20V412%20May1993.pdf (Hansard pages 1347 to 1356 are pages 285 to 294 of the PDF.)

27. Victoria, Legislative Assembly. Parliamentary Debates (Hansard). April 29, 1998;439:1399-1418. Accessed October 10, 2026. https://hansard.parliament.vic.gov.au/images/stories/volume-hansard/Hansard%2053%20LA%20V439%20Apr-May1998.pdf (Hansard pages 1399 to 1418 are pages 409 to 428 of the PDF.)

28. Ryan lauds sale of VPC: but not all share his views. The Great Southern Star (Leongatha). November 24, 1998:9.

29. SmartWood Program. Forest Management Public Summary for Hancock Victorian Plantations Pty. Limited. Certification code SW-FM/COC-1128. Rainforest Alliance; January 2004.

30. Assurance Services International. FSC FM/COC Compliance Assessment of SCS Global Services at Hancock Victorian Plantations Pty Ltd, Australia, 2025: ASI Final Assessment Report (Assessment No. A-20250549013). Assurance Services International; August 2025. Available from the FSC certificate database (certificate SCS-FM/COC-007709, Documents tab): https://search.fsc.org/en/certificate/a0240000005sU0eAAE/?tab=documents. Copy held by Gippsland Forest Guardians: GFG copy.

31. Flora and Fauna Guarantee Scientific Advisory Committee. Final Recommendation on a Nomination for Listing: Warm Temperate Rainforest Community (Nomination No. 898). Department of Energy, Environment and Climate Action; 2023. Accessed October 5, 2026. https://www.environment.vic.gov.au/__data/assets/pdf_file/0020/691301/Nom.-898-Warm-Temperate-Rainforest-Community-FRR_signed.pdf Copy held by Gippsland Forest Guardians: GFG copy.

32. Just K, Osler D. Vegetation Survey of Cool Temperate Rainforest Occurring on Trust for Nature Properties at Turtons Creek. Report prepared for the Gippsland Threatened Species Action Group; 2024. Accessed October 5, 2026. https://assets.nationbuilder.com/gfg/pages/727/attachments/original/1761341303/Report-_Turtons_Creek_Vegetation_Assessment_-_TFN_properties-_December_2024-1-3.pdf?1761341303

33. Arthur Rylah Institute for Environmental Research. Rainforests: will they cope with a changing fire regime? Department of Energy, Environment and Climate Action. Accessed October 5, 2026. https://www.ari.vic.gov.au/research/fire/rainforests-will-they-cope-with-a-changing-fire-regime

34. Burns EL, Lindenmayer DB, Stein J, et al. Ecosystem assessment of mountain ash forest in the Central Highlands of Victoria, south-eastern Australia. Austral Ecology. 2015;40:386-399. doi:10.1111/aec.12200

35. IUCN Red List of Ecosystems. Mountain Ash Forest in the Central Highlands of Victoria, South-eastern Australia. Assessment by Burns EL, Lindenmayer DB, Stein J, et al. Critically Endangered (D1+D2a+D3+E); last assessed 2015. Accessed October 10, 2026. https://assessments.iucnrle.org/assessments/16 Copy held by Gippsland Forest Guardians: GFG copy.

36. Department of Climate Change, Energy, the Environment and Water. Preliminary Information Sheet: Consultation on the Assessment of an Ecological Community for National Listing. Mountain Ash Forests of Central and Eastern Victoria. Department of Climate Change, Energy, the Environment and Water; 2026. Information sheet provided to local government; not published online. Copy held by Gippsland Forest Guardians.

37. Department of Climate Change, Energy, the Environment and Water. Extensions to EPBC Act listing assessment and decision timeframes. Updated September 4, 2026. Accessed October 20, 2026. https://www.dcceew.gov.au/environment/biodiversity/threatened/nominations/extensions#ecological-communities

38. Lindenmayer D, Taylor C, Bowd E, et al. The case for listing Mountain Ash forests in the Central Highlands of Victoria as a threatened ecological community. Pacific Conservation Biology. 2024;30(1):PC23010. doi:10.1071/PC23010 (The article's pages are lettered, not numbered.)

39. Department of Energy, Environment and Climate Action. Flora and Fauna Guarantee Act 1988 Potentially Threatening Processes List: July 2026. Department of Energy, Environment and Climate Action; 2026. Accessed October 5, 2026. https://www.environment.vic.gov.au/conserving-threatened-species/threatened-list Copy held by Gippsland Forest Guardians: GFG copy.

40. Peacock RJ, Downing A, Brownsey P, et al. Distribution, habitat preferences and population sizes of two threatened tree ferns, Cyathea cunninghamii and Cyathea x marcescens, in south-eastern Australia. Cunninghamia. 2013;13(1):1-24. Accessed October 5, 2026. https://www.botanicgardens.org.au/sites/default/files/2023-06/Cun131pea001.pdf

41. Department of Energy, Environment and Climate Action. Action Statement: Slender Tree-fern (Cyathea cunninghamii). Flora and Fauna Guarantee Act 1988. Department of Energy, Environment and Climate Action; 2023. Accessed October 6, 2026. https://bio-prd-naturekit-public-data.s3.ap-southeast-2.amazonaws.com/actionstmts/Slender_Tree-fern_AS_500896.pdf Copy held by Gippsland Forest Guardians: GFG copy.

42. Flora and Fauna Guarantee Act 1988 (Vic), ss 3, 4A. Accessed October 12, 2026. https://www.legislation.vic.gov.au/in-force/acts/flora-and-fauna-guarantee-act-1988

43. HVP Plantations. High Conservation Values Assessment and Management Plan. HVP Plantations; April 2026. Accessed October 19, 2026. https://www.hvp.com.au/wp-content/uploads/2026/05/HVP-High-Conservation-Values-Assessment-and-Management-Plan-.pdf

44. HVP Plantations. Technical Addendum: High Conservation Values Assessment and Management Plan. HVP Plantations; April 2026. Unpublished; copy provided to Gippsland Forest Guardians by HVP Plantations.

45. Department of Agriculture, Fisheries and Forestry. Gippsland Regional Forest Agreement. Accessed October 11, 2026. https://www.agriculture.gov.au/agriculture-land/forestry/policies/rfa/regions/victoria/gippsland

46. Department of Energy, Environment and Climate Action. Victorian Bioregions - Mapped at 1:100,000 (version 3.0, May 2004) (VBIOREG100) [dataset]. Department of Energy, Environment and Climate Action. Accessed October 20, 2026. Metadata record: https://metashare.maps.vic.gov.au/geonetwork/srv/api/records/3508ad58-e66b-50e4-9717-0338845ded77/formatters/xsl-view?root=div&view=advanced. Data available from DataVic.

47. Department of Energy, Environment and Climate Action. Brataualung Forest Park. Forests and Reserves Victoria. Updated October 12, 2022. Accessed October 9, 2026. https://www.forestsandreserves.vic.gov.au/initiatives/brataualung-forest-park

48. Declaration of reserved forest to be a forest park. Forests Act 1958, Order in Council. Victoria Government Gazette. October 8, 2026;G41:2475. http://www.gazette.vic.gov.au Copy held by Gippsland Forest Guardians: GFG copy.

Glossary

Action statement. A plan prepared under the Flora and Fauna Guarantee Act 1988 that sets out what will be done to conserve a listed species or community, or to manage a listed threatening process.

Bioregion. A large area with broadly similar climate, geology, landforms and vegetation, used by the State to map and report on biodiversity. This report uses the Strzelecki Ranges bioregion.

Buffer. A strip of retained vegetation around rainforest, intended to protect it from the effects of activity beyond.

CAR reserve system. The comprehensive, adequate and representative system of reserves set up under the Regional Forest Agreements.

Cool Temperate Mixed Forest. Cool Temperate Rainforest with an emergent canopy of eucalypts such as Mountain Ash. It is listed as a threatened community in Victoria.

Crown land under plantation licence. Crown land that the State licenses to a plantation company. In the Strzeleckis it includes native forest as well as plantations.

Custodial lands. The term HVP used in 2004 for the native forest on its estate, which it said was managed for conservation.

Differential species. A plant that is much more likely to occur on one side of a vegetation boundary than the other, used to locate the boundary.

Ecological Vegetation Class (EVC). The unit used to map and classify native vegetation in Victoria.

Ecotone. The transition zone between two vegetation types, such as rainforest and eucalypt forest.

High conservation value forest (HCVF). The term used in FSC standards in 2004 for forest with high conservation values. The current Australian standard refers to high conservation values (HCVs) and HCV areas.

High conservation values (HCVs). Under FSC standards, values of outstanding significance that forest managers must identify and protect. HCV 3 covers rare, threatened or endangered ecosystems, habitats and refugia.

HVP. HVP Plantations, formerly Hancock Victorian Plantations, which has held the plantation licence for the former Victorian Plantations Corporation estate since 1998.

Mountain Ash. Eucalyptus regnans, a very tall eucalypt that dominates much of the Wet Forest around rainforest gullies in the Strzeleckis.

Myrtle Beech. Nothofagus cunninghamii, the main canopy tree of Cool Temperate Rainforest.

Myrtle Wilt. A fatal disease of Myrtle Beech caused by the fungus Chalara australis.

Precautionary principle. The principle that a lack of full scientific certainty should not be used as a reason for postponing measures to prevent serious or irreversible environmental damage (see The precautionary principle under How to protect rainforest).

Regional Forest Agreement (RFA). An agreement between the Commonwealth and a State on the management of forests in a region. The Gippsland RFA was signed in 2000 and was terminated on 31 December 2024.⁴⁵

Sclerophyll forest. Forest dominated by hard-leaved plants, in this context eucalypt forest.

Slender Tree-fern. Cyathea cunninghamii, a tree-fern of rainforest gullies, listed as Critically Endangered in Victoria.

Appendix A. How this report was prepared

Searching and selecting sources

We searched government websites, library catalogues, the publications of the Arthur Rylah Institute and the Royal Botanic Gardens, reference lists of the key studies and the requirements of the Forest Stewardship Council. The searches were targeted rather than exhaustive, and were completed in October 2026. We included published research, government reports, listing documents and commissioned studies. We left out opinion pieces and advocacy material, including our own. The photographs are our own. Every quotation and figure has been checked against the original document. Where a source reports another author's work, we say so. Several older documents could not be obtained and are listed under The limits of what we know. The full list of sources, with links, is on our website.

Mapping method and full results

Purpose. The overlay asks two questions: how the rainforest mapped by the State in the Strzelecki Ranges bioregion is distributed across land tenures, and how far the State's two rainforest maps agree. It measures mapped rainforest, not rainforest confirmed on the ground.

Data. Native Vegetation: Modelled 2005 Ecological Vegetation Classes (NV2005_EVCBCS), using Cool Temperate Rainforest (EVC 31), Warm Temperate Rainforest (EVC 32) and Riparian Forest/Warm Temperate Rainforest Mosaic (EVC 123);⁷ Rainforest Mapping for State-wide Victoria (RAINFOR), all rainforest types;⁸ Public Land Management (PLM25);⁹ and Victorian Bioregions (VBIOREG100).⁴⁶ All four were downloaded from DataVic in October 2026 in the GDA2020 VicGrid projection.

Step 1. The Strzelecki Ranges bioregion is the "Strzelecki Ranges" polygon in VBIOREG100 (342,199 ha). NV2005 rainforest is the three EVCs above with the bioregion attribute "Strzelecki Ranges"; all of it lies within that boundary.

Step 2. RAINFOR polygons that overlap the bioregion were clipped to the VBIOREG100 boundary, so only the part of each polygon inside the bioregion is counted.

Step 3. Each rainforest layer was intersected with PLM25 and the area of each piece calculated in hectares. Land was classed in this order: parks and conservation reserves (PLM25 IUCN category IA, IB, II, III or IV); Crown land under plantation licence (management group "VESTED VPC" or a general management type containing "PLANTATION"); State forest (management type containing "STATE FOREST", which includes Brataualung Forest Park); and other Crown land (all remaining PLM25 land, mainly water frontages). Rainforest not covered by any PLM25 polygon is counted as freehold.

Step 4. Agreement between the maps is the area where the two rainforest layers overlap.

The analysis used Python with the geopandas, shapely and pyogrio libraries. The scripts are available from Gippsland Forest Guardians on request.

Hectares are rounded, so rows and columns may not add exactly. In the table under How much rainforest remains, and how much is protected, "other public land" combines State forest and other Crown land.

Agreement between the maps. Cool Temperate Rainforest is mapped on both maps over 490 ha, which is 27 per cent of the area on the 2005 map and 14 per cent of the area on the statewide map. Warm Temperate Rainforest, including the riparian mosaic, is mapped on both over 33 ha (2 and 4 per cent). Any type of rainforest is mapped on both over about 550 ha of the 7,209 ha mapped on one map or the other. Of that 550 ha, about 524 ha is mapped as the same type on both maps. The other 27 ha is mapped as Cool Temperate Rainforest on one map and Warm Temperate Rainforest on the other. The two maps use different classification systems, so comparisons by rainforest type are approximate.

Notes. The public land map records Brataualung Forest Park as State forest that is not a protected area,⁹ although the State describes the park as protecting "important areas of cool temperate rainforest and damp forest".⁴⁷ On 8 October 2026 a further 2,156 ha of reserved forest in the parishes of Gunyah Gunyah, Binginwarri and Bulga was declared a forest park.^48(p2475) The public land map already showed this land as a proposed addition to Brataualung Forest Park, so the declaration does not change the figures above.

The public land map records who holds land, not who manages it under licence, and it cannot separate freehold plantation land from other freehold. The statewide rainforest map has not been verified in the Strzelecki Ranges, and the 2005 map is modelled at 1:100,000 (see How much rainforest remains, and how much is protected).

Appendix B. FSC cross-reference table

For readers interested in forest certification, this table shows where each section of the report relates to the FSC National Forest Stewardship Standard of Australia (FSC-STD-AUS-01-2018). It is a guide to where the standard is relevant, not an assessment of whether any forest manager complies with it.