Pre- and post-harvest burns: hollow-bearing trees and large fallen logs

This webpage supports the implementation of Protocol 23.3(7) of the Coastal Integrated Forestry Operations Approval (Coastal IFOA) which requires pre-harvest and post-harvest burns be undertaken in a manner that does not damage a hollow-bearing tree and retains shelter and refuge habitats provided by large fallen logs within the operational area.

This is intended to:

  • assist the Forestry Corporation of NSW (FCNSW) in implementing Coastal IFOA conditions 64, 85, 86, 87 and 113 and Protocol 23.3(7)
  • guide the NSW EPA when regulating Coastal IFOA conditions 64, 85, 86, 87 and 113 and Protocol 23.3(7).

Note: This guidance does not affect the legal requirements of the Coastal IFOA conditions and protocols. This guidance is not a substitute for the Coastal IFOA conditions and protocols and does not modify their terms or effect. Terms used in this guidance document have the same meaning as defined in Coastal IFOA Protocol 39.

Burning operations covered by the Coastal IFOA

Burning operations in the form of pre-harvest burns or post-harvest burns are forestry operations covered by the Coastal IFOA only if FCNSW has elected to the apply the terms of the Coastal IFOA to burning operations in the operational plan, and the burning operations satisfy the criteria in condition 13.1(e)(i)-(iii) of the Coastal IFOA.

If the operational plan does not state that the Coastal IFOA applies to pre-harvest burns or post-harvest burns, the requirements of the Rural Fires Act 1997 and the Bush Fire Environmental Assessment Code must be applied.

Coastal IFOA requirements for burning operations

Conditions 85, 86, 87 and 113 of the Coastal IFOA place requirements on the conduct of burning operations under the Coastal IFOA.

Conditions 85-87 must be interpreted in a manner that is consistent with achieving and giving effect to the following outcome statement:

Environment features, habitat, landscapes and communities are maintained through the implementation of best management practices for pre-harvest burns and post-harvest burns.

Condition 113 must be interpreted in a manner that is consistent with achieving and giving effect to the following outcome statement:

ESAs and important habitat are managed during burning operations to maintain their intended, specific environmental values and provide short term refuge habitat.

Protocol 23.3(7) of the Coastal IFOA requires that:

A pre-harvest burn or post-harvest burn must be undertaken in a manner that:

  1. does not damage a hollow-bearing tree retained under condition 64 of the approval; and
  2. retains shelter and refuge habitats provided by large fallen logs within the operational area.

Note: The impact described by Protocol 23.3(7) relates to where the ecological features and functions are substantially destroyed or removed. FCNSW must consider associated guidelines to support the implementation of this condition.

Condition 87 of the Coastal IFOA, prohibits burning operations within an environmentally significant area (ESA) (including exclusion zones retained around nest, roost or den identified in Table 4 of the Coastal IFOA) and ground protection zones, unless approved as a restricted activity under Protocol 5.

In addition, FCNSW must stabilise and rehabilitate any area in an ESA or ground protection zone disturbed by a pre-harvest or a post-harvest burn irrespective of whether this disturbance was unintended or was carried out intentionally in accordance with Protocol 5.

Guidelines to support implementation of Protocol 23.3(7)

The following guidelines may be used to support the implementation of Protocol 23.3(7):

  • Condition 86.5 prohibits pre-harvest burns or post-harvest burns from being ignited where immediately prior to the planned start time for the burn:

    • the recorded McArthur Forest Fire Danger Index within the burn area is greater than 12; or
    • the McArthur Forest Fire Danger Index is predicted to be greater than15 at any time during the intended duration of the burn; or
    • the McArthur Forest Fire Danger Index is predicted to be greater than 15 at any time in a 24-hour period following the planned completion of the burn.

    However, in areas with high numbers of hollow-bearing trees or large fallen logs which provide shelter and refuge habitats, consider avoiding burning operations when conditions are likely to result in burnt canopy (moderate severity or greater).

  • Consider implementing ignition patterns that reduce burn area and severity of fire to the minimum extent required in areas with hollow-bearing trees and large fallen logs. For example, this may involve burning around these features at low severity to establish a break.
  • Where access permits it may be appropriate to use a wetline (a line doused in water to stop the advance of a fire) in locations where the planned burning operation may put hollow-bearing trees and large fallen logs at risk.
  • Where other options are not available, consider using mechanical fuel reduction methods such as rake-hoeing for protection of individual hollow-bearing trees and large fallen logs within the net harvest area, particularly where these provide shelter and refuge habitats, and the planned burning operation is considered likely to put the feature at risk.
  • In the net harvest area, best management practices should be implemented to achieve the outcome statement for burning operations.