1. Introduction
The Forest Alliance NSW welcomes the opportunity to comment on the proposed Matters of National Environmental Significance (MNES) National Environmental Standard.
Forest Alliance NSW is a coalition of national, state-wide and local environmental organisations and community groups working to protect native forests and the species and communities that depend on them.
This submission focuses on the application of the MNES standards to native forest logging.
Our central contention is straightforward:
MNES standards must not allow native forest logging to continue in the core habitat of nationally threatened species. Allowing logging in these areas would accelerate population decline and increase the risk of extinction, contrary to the purpose of the Act, which is to ensure the protection and recovery of these species.
2. Context and significance of the reforms
For more than two decades, native forest logging has been exempt from effective federal environmental oversight.
We welcomed the Commonwealth Government’s 2025 decision to remove the long-standing exemption that allowed native forest logging to avoid federal environmental law under Regional Forest Agreements. This reform has the potential to correct a decades-long failure of national environmental protection.
However, this reform will only succeed if the national environmental standards contain clear, enforceable prohibitions on activities that destroy or degrade nationally significant habitat.
The draft MNES does not do so.
The MNES standard must be outcomes-based, clear and enforceable, as recommended by the Samuel Review. It must require decision-makers to comply with the standard, not merely “have regard to” it or be satisfied that decisions are “not inconsistent with” it. Discretionary language risks inconsistent application and would undermine the purpose of national environmental standards.
If the MNES standards merely replicate existing state forestry rules, rely on discretionary decision-making, or permit ongoing habitat destruction subject to mitigation or offsets, then the removal of the exemption will not deliver meaningful protection for threatened species.
We submit that the standards must result in real, enforceable limits on destructive activities, and that native forest logging is incompatible with effective protection of Matters of National Environmental Significance.
3. Native forest logging and MNES species
Native forest logging has a well-established and extensively documented impact on threatened species and ecological communities. These impacts include:
- removal of hollow-bearing trees critical for shelter and breeding
- fragmentation of forest landscapes
- long-term degradation of forest structure
- disruption of food resources and movement corridors
- cumulative impacts that undermine recovery efforts
These impacts are not hypothetical or speculative. They are widely documented in the scientific literature and reflected in multiple national recovery plans.
For many threatened forest species, habitat loss and degradation from logging is a primary driver of decline.
In NSW, many nationally threatened species persist primarily within public native forests that remain subject to logging. In these landscapes, logging is not a marginal or incidental pressure. It is a dominant driver of habitat loss and population decline.
The MNES standard must also require robust assessment of cumulative impacts. In forest landscapes already heavily affected by logging, bushfire and fragmentation, incremental additional impacts can be ecologically decisive and incompatible with species recovery.
Therefore, any MNES standard that allows logging to continue in core threatened species habitat is inconsistent with the objects of the EPBC Act and with the stated purpose of the national environmental standard.
4. The key test: protection of core threatened species habitat
Forest Alliance NSW submits that the ultimate test of the MNES standards is whether they protect core habitat for nationally threatened species.
In particular, we urge the Government to assess the standards against species that have been proven to be disastrously impacted by logging, especially the endangered Southern Greater Glider.
Southern Greater Glider (Petauroides volans)
The Southern Greater Glider is listed as Endangered under national law. It is highly dependent on mature forests with abundant large hollow-bearing trees. Scientific evidence consistently shows that logging significantly reduces glider occupancy and survival, particularly where hollow availability is diminished.
Greater Glider populations have suffered catastrophic declines following the 2019–20 bushfires, and heat stress and drying of forests exacerbated by global heating. Remaining strongholds are now concentrated in unburnt or less-burnt forest areas, many of which continue to be logged under state-based approvals.
Decisions affecting Greater Glider habitat must be based on the best available information, including contemporary field surveys and peer-reviewed science. Assumptions of species absence, or reliance on outdated or incomplete data, are not appropriate where an Endangered species is concerned.
We submit that the following state forests form part of the core habitat of Greater Gliders, and that their protection from logging is critical to the species’ ongoing survival:
Tallaganda, Tuggalo, Bulga, Enfield, Giro, Barrington Tops, Brother, Styx River, Glen Elgin and Gibraltar State Forests, as well as the connected forest landscapes of Badja, Cherry Tree, Dampier (parts), Dingo, Flat Rock, Glenbog and Riamukka.
These forests contain mature native forest with high hollow availability and form part of a connected landscape supporting Greater Glider populations. Ongoing or proposed logging across this landscape risks further fragmentation and cumulative loss of core habitat.
If the MNES standard permits logging to proceed in mapped or known Greater Glider habitat, subject only to mitigation measures or offsets, it cannot be said to protect Matters of National Environmental Significance. The standard must therefore prohibit actions that result in the loss or degradation of core Greater Glider habitat.
Swift Parrot (Lathamus discolor)
The Swift Parrot is listed as Critically Endangered and relies on mature eucalypt forests in NSW during winter, particularly Spotted Gum–dominated forests.
Because Swift Parrots aggregate in a small number of key foraging forests depending on flowering events, logging in these areas can have disproportionate population-level impacts. We specifically submit that the Forests along the Clyde River on the NSW south coast, Brooman and surrounding areas, contain nationally significant Swift Parrot foraging habitat that should be protected from logging.
Koala
NSW contains some of the last intact koala strongholds on the east coast. Of particular concern are koala habitat areas in the Richmond River catchment (specific locations to be updated), where logging continues to fragment and degrade habitat critical to recovery.
Koala habitat is also well documented in the lowland forests in the Hastings, Manning and Karual/Great Lakes catchments.
Regent Honeyeater
Critically endangered, with NSW forest remnants essential for feeding and breeding. Habitat loss and degradation continue to drive population decline.
Spotted-tailed Quoll, Yellow-bellied Glider, Hastings River Mouse
Species dependent on large, connected forest landscapes that are being progressively fragmented by logging.
Threatened frogs and reptiles
Species such as the Giant Barred Frog, Fleay’s Barred Frog and Stuttering Frog are highly sensitive to disturbance, changes in moisture regimes, and habitat fragmentation caused by logging operations.
Threatened plants and forest communities
Numerous nationally threatened plant species and ecological communities occur within NSW state forests and rely on intact forest structure and fire refuges.
Under the new national framework, these habitats should finally receive meaningful protection.
6. Recovery plans must be binding, not advisory
The MNES standard must require that any action occurring within threatened species habitat is demonstrably consistent with the relevant recovery plan.
At present, logging operations routinely proceed in areas identified as important or critical habitat under recovery plans, with the assumption that mitigation measures are sufficient. This approach has demonstrably failed to halt declines.
Recovery plans exist because incremental damage is incompatible with species survival. Where recovery plans call for habitat protection, restoration, or the maintenance of mature forest structure, logging cannot be considered consistent with those objectives.
The standard should explicitly state that actions inconsistent with recovery plans are prohibited.
7. Why state-based logging rules are inadequate
The need for strong national standards is underscored by the failure of existing state-based forestry regulations.
In NSW:
- forestry rules were significantly weakened in 2018
- hollow retention and exclusion zones are inadequate to maintain viable populations
- the ability of the NSW EPA to establish and strongly enforce habitat protection provisions in the state’s Coastal Integrated Forestry Operations Approvals and Site Specific Biodiversity conditions are hamstrung by Forestry Corporation NSW demanding light-touch regulation to ensure it meets statutory objectives of delivering contracted wood supplies under the Forestry Act 1916 (NSW).
- enforcement relies heavily on self-reporting
- cumulative and landscape-scale impacts are not properly assessed
- post-fire forests continue to be logged despite species vulnerability
These systemic shortcomings demonstrate why federal oversight is essential. The MNES standard must not defer to state regulatory frameworks that have failed to protect nationally significant species.
8. From exemption removal to real protection
The recent removal of the long-standing exemption that allowed native forest logging to avoid federal environmental law is a critical reform. However, its success depends entirely on the strength of the national environmental standards.
If the MNES standard allows business-as-usual logging to continue under a new regulatory label, the reform will not deliver meaningful outcomes for nature.
In particular, impacts on Endangered and Critically Endangered species and their core habitat must be deemed unacceptable and ineligible for offsetting. For species such as the Greater Glider and Swift Parrot, offsets cannot compensate for the loss of irreplaceable mature forest habitat.
The intent of national environmental law is to prevent actions that cause unacceptable harm to matters of national significance. Native forest logging that destroys or degrades core threatened species habitat is fundamentally incompatible with that intent.
9. Recommendations
Forest Alliance NSW recommends that the MNES National Environmental Standard:
- Explicitly prohibit native forest logging in nationally significant threatened species habitat where it causes habitat loss or degradation.
- Establish clear, enforceable thresholds that trigger mandatory refusal of approval, rather than discretionary mitigation.
- Require strict consistency with threatened species recovery plans.
- Prohibit the use of offsets for impacts on Endangered and Critically Endangered species and their core habitat, including mature native forests critical to species survival.
- Recognise cumulative and landscape-scale impacts, not just site-level assessments.
- Ensure that the removal of the RFA exemption results in real, on-ground protection for threatened species.
10. Conclusion
Australia is facing an extinction crisis. Native forest logging is a significant and ongoing driver of biodiversity loss.
The proposed MNES standard presents a once-in-a-generation opportunity to align forest management with national environmental law and scientific reality.
If the standard protects core habitat for species like the Greater Glider, Koala and Swift Parrot, it will represent genuine reform. If it does not, the removal of the logging exemption will be largely symbolic.
Forest Alliance NSW urges the Commonwealth to ensure that the MNES standard delivers the protection that nationally significant species and ecosystems urgently require.