In its submission to the RFA Modernisation Consultation the RFPG is sharply critical of the Independent Consultation Paper; argues strongly against the renewal of the RFAs; and outlines a range of priority policy intiatives to arrest the degradation of Victoria's state forests which could be included in a 'modernised' RFA but should be progressed regardless.

(More about the 'Modernisation' project here.  Consultation paper here.)

The RFAs have provided cover for the Commonwealth to turn a blind eye to the ongoing unsustainable logging of native forests by state governments. The Commonwealth has significant powers over taxation, expenditure, environmental protection and export control. In view of the crucial role that forests play in abating global warming and maintaining biodiversity, it is no longer tenable for the Commonwealth to abrogate its responsibility to apply these powers to ensure ecologically sustainable forests management.

The first generation RFAs have failed to achieve ecologically sustainable forest management and have failed to implement key sections of the National Forests Policy.

The RFAs should not be renewed. Moving to ecologically sustainable forest management in Victoria does not require 'modernised' RFAs.

However, if both levels of government are determined to conclude 'modernised' RFAs by March 2020 we propose the inclusion of the following provisions:

• annual independent audit of Victorian forests management against the principles of the EPBC Act and the commitments of the NFPS with provision for the lifting of export controls exemption in the event of significant breaches;
• a ban to be placed on the export of unprocessed sawlogs and restrictions on woodchip exports to ensure sufficient resources for local processing;
• immediate review of the overall representativeness and adequacy of the existing system of conservation reserves with a view to the promulgation of new 'modernised' FMPs which provide for the realisation of the CAR principles across the forest estate;
• rigorous review and revision of the Code and the MSPs; including review and reform of the handling of community reports of breaches of the Code;
• reform VicForests' governance and mandate;
• repeal of the Wood Pulp Agreement Act;
• review and revision of the principles and methods applied in developing the Resource Outlook;
• review and revision of the methodology underpinning the Allocation Order;
• the TRP and coupe plans to be appealable at VCAT;
• improved specification of silvicultural requirements in the allocation order and the FMPs;
• development of plantations;
• social impact evaluation of local harvesting activities; 
• funding for R&D with five yearly reviews of research priorities and performance; and
• fully funded transition policies.