Forestry Alliance NSW sent the below letter to the NSW EPA in March 2026 to raise concerns around risks to greater gliders due to non-compliant logging operations in Glenbog State Forest.

I am writing on behalf of the Nature Conservation Council of NSW and Forest Alliance NSW to raise serious concerns about Greater Glider compliance risk in Glenbog State Forest, as well as a number of proposed logging operations scheduled for 2026.

As you will no doubt be aware, recent citizen science in Glenbog State Forest on the NSW South Coast has identified more than 120 Greater Glider den trees within proposed logging compartments. Forestry Corporation’s own surveys recorded just four.

Under NSW logging rules, each confirmed den tree requires a 50 metre exclusion zone where logging cannot occur. At the density now documented through citizen science, exclusion zones overlap extensively. When these rules are properly applied, large areas of the Glenbog operation area cannot lawfully be logged.

Greater Gliders are listed as Endangered under the EPBC Act. Their populations have suffered severe declines due to decades of logging, compounded dramatically by the 2019–20 bushfires. Remaining viable populations are now concentrated in a limited number of unburnt or less-burnt mature forest strongholds, many of which continue to be subject to logging approvals. These habitats are disproportionately important for the species’ survival.

Greater Gliders depend on large, old hollow-bearing trees that take 150–250 years or more to form. Scientific evidence demonstrates that logging reduces occupancy and long-term population persistence, particularly in high-density stronghold habitat.

Greater Gliders are particularly susceptible to forest fragmentation within their home ranges (3-4ha) as it often destroys the glide paths they use to move around in the canopy.

The scale of discrepancy between Forestry Corporation’s survey results and the findings of independent citizen science raises serious concerns regarding survey adequacy, detection methodologies and assumptions of species absence. Where dozens of den trees are present but not identified in operational surveys, the risk of unlawful impact is substantial.

Decisions affecting an endangered species must be based on the best available contemporary information. Where independent citizen science consistently identifies materially different habitat densities, that information warrants regulatory consideration.

Glenbog is unlikely to be an isolated case. Repeatedly, citizen science efforts across NSW have demonstrated that when Greater Glider den trees are properly identified, exclusion zones expand to the point where logging operations may no longer be viable. This pattern has been observed in Tallaganda and Badja State Forests, and similar outcomes are emerging in forests including Enfield and Styx River on the North Coast.

We are also concerned that when Greater Glider exclusion zones overlap and make it difficult for Forestry Corporation to access small areas scheduled for logging further downslope, the EPA has allowed snig tracks to be constructed through these exclusion zones. This has occurred in several operations in Styx River State Forest. Allowing machinery access through exclusion zones risks damaging exactly the habitat these protections are meant to safeguard.

Rather than continuing to address these issues forest by forest, a more defensible regulatory approach would be to identify and map core Greater Glider habitat at a landscape scale and reconsider the scheduling of logging operations within those areas.

Based on available ecological data and citizen science records to date, we submit that the following state forests represent core Greater Glider habitat in NSW:

Tallaganda, Tuggalo, Bulga, Enfield, Giro, Barrington Tops, Brother, Styx River, Glen Elgin, Gibraltar Range, Moogem, Badja, Cherry Tree, section of Dampier, Dingo, Flat Rock, Glenbog and Riamukka.

These forests contain mature native forest with high hollow availability and form a connected landscape supporting metapopulation stability. Ongoing logging across this network, and other forests containing core habitat, risks cumulative fragmentation and irreversible habitat loss.

We therefore request that the EPA:

1. Undertake an immediate review of Greater Glider compliance risk in Glenbog State Forest, including assessment of whether current exclusion zones reflect the best available information.
   
2. Review proposed 2026 logging operations across known or mapped Greater Glider habitat to assess whether similar high-density den tree outcomes are likely in other forests scheduled for harvest.
   
3. Evaluate whether the current survey-based regulatory model is sufficient to prevent unlawful impacts in core Greater Glider strongholds.
   
4. Clarify how the EPA intends to ensure that logging operations do not result in degradation of Matters of National Environmental Significance under federal environmental law.
5. Consider our proposal to exclude the identified core Greater Glider forests from logging operations, pending comprehensive landscape-scale assessment of habitat significance and compliance risk.
6. Withhold permission for logging machinery to traverse Greater Glider den tree exclusion zones.

We emphasise that the forests identified above represent less than 3% of the State’s native forest estate, and have been selected on the basis of ecological data, citizen science records and their role as remaining Greater Glider strongholds.

It should not fall to citizen scientists to repeatedly identify habitat that regulatory processes are intended to detect and protect.

Targeted exclusion of these core habitats would represent a proportionate and evidence-based regulatory response, reduce repeated compliance disputes, and provide greater certainty for both conservation outcomes and operational planning.

NCC and allied organisations will continue to undertake citizen science work in proposed logging areas to ensure threatened species protections are properly applied.

We welcome your response outlining how the EPA intends to address these concerns.

Yours sincerely,

Clancy Barnard

On behalf of the Forest Alliance NSW, which includes:

• The Nature Conservation Council of NSW 
• WWF-Australia 
• Wilderness Australia 
• North East Forest Alliance 
• North Coast Environment Council
• Brooman State Forest Conservation Group 
• The Wilderness Society 
• National Parks Association of NSW 
• South East Forest Rescue 
• Bob Brown Foundation