IN THE MATTER of the Resource Management Act 1991
IN THE MATTER of an application by Timberlands West Coast Limited
FOR land use consent to undertake sustainable beech forest management, including selective felling of trees, aerial extraction of logs by helicopter, and ancillary upgrading, extension and use of road access and helicopter landing sites, in both the Buller and Tasman Districts.
STATEMENT OF EVIDENCE BY P L GLASSON
- My full name is Peter Lloyd Glasson. I am a Director of Glasson Potts Group Ltd, an Environmental Engineering & Resource Management Consulting Company based in Christchurch. I hold the qualifications of Bachelor of Science (Botany and Ecology), Masters of Science (Honours) (Environmental Science), and Bachelor of Town Planning. I am a full member of the New Zealand Planning Institute.
- I have had over fourteen years experience in resource management and environmental planning and consulting in the private sector. This has involved considerable experience in the field of the preparation of resource consent applications and Environmental Effects Assessments for major projects.
EXPERIENCE WITH TIMBERLANDS APPLICATION
- I have also had considerable experience working in the area of forest conservation in New Zealand working for many years voluntarily for the Native Forests Action Council (now renamed the Maruia Society). In this role I was a committee member of the Auckland Branch, and prior to my resignation, was the Auckland Branch Chairman and a member of the National Executive of the Native Forests Action Council. My total active involvement in the Native Forests Action Council was over a period of more than six years. In this role I was intimately involved in the native forest conservation issues of the 1980's up to the end of 1986.
- I visited the site of one of the areas of recent beech timber extraction trials, similar to that proposed in these applications, on 10 November 1998. Following that site visit, staff of Glasson Potts Group Limited prepared scoping reports on the project, and then the Environmental Effects Assessment (AEE) that accompanied the applications for resource consent. I personally managed the preparation of those reports. Furthermore, I have read the Council Planner's report. In addition, I have also been involved in consultation with Transit New Zealand in relation to their submission to these applications. In preparing this evidence, I have been mindful of the extensive amount of evidence being prepared by other experts assisting the applicant. I have therefore confined my evidence strictly to the resource management issues of the application, while also providing a broad overview of the environmental effects of the project as is usually required by a project of this magnitude. I have also not repeated much of the information that has been set out in the Planner's report, as this will simply involve repetition of accepted information and interpretation.
- My overall conclusion is that the application should be granted consent but with appropriate conditions to mitigate any adverse effects. I consider that the application represents an activity that is envisaged under the definition of sustainable management of the Resource Management Act and is in accordance with the agreements signed under the Forests Accord.
STRUCTURE OF MY EVIDENCE
- In particular, this application relates to the sustainable management of New Zealand's natural environment, the central principle of the Resource Management Act. I consider that the application fits within the principles of the Act, in that seeks to use a natural resource, potentially in perpetuity, but to mitigate the potential adverse effects of the activity.
- My evidence to this hearing is structured in the following way:
THE APPLICATION AREA
- The Application Area
- The Proposal
- Buller District Plans
- Tasman District Plans
- Other relevant resource management documents
- Statutory Considerations
- Assessment of Environmental Effects
- Conditions of Consent
Grey Working Circle comprises forests on both sides of the Grey River Valley generally to the east of SH 7 between Ikamatua and Reefton. The forests are located in both Grey and Buller Districts. However, only those forests within Buller District are covered by this application. There are 6 separate non-contiguous forest areas within Buller District.
Inangahua Working Circle comprises forests on both sides of the Inangahua River Valley, generally to the east and west of SH 69 between Reefton and Inangahua Junction, and to the north and south of the state highway between Inangahua Junction and Hawks Crag. The forests are all located within Buller District and comprise 12 non-contiguous forest areas.
Maruia Working Circle comprises forests on both sides of the Maruia River Valley between Springs Junction in the south and Murchison in the north. The forests are located in part within Buller District and in part within Tasman District. Station Creek forest is split between the two districts with a further three smaller non-contiguous forest areas being located within Tasman District. Approximately 40% of the total area of this working circle is located within Tasman District.
- The application area falls within both the Buller and Tasman Districts. Plans showing the location of the application area are included in Maps 1 û 4 in Volume 1 of the application, as well as in Appendix 1 of the planning report. The sustainable management estate comprises a number of distinct and discontinuous land areas that have been grouped into working circles. These working circles are areas of relatively uniform forest composition, landform, geographic location and operational cost structure. Three of these working circles comprise the application area as follows:
- In addition to the actual crown owned forests in the sustainable management estate, the application area also includes some access roads and helicopter landing sites on adjacent private land and unformed legal roads. These areas are all shown on maps contained in Appendix 1, Volume 2 of the application.
- Timberlands seeks 35 year resource consents to undertake sustainable management of Crown owned beech and beech/podocarp forests within the Buller and Tasman Districts. In short, sustainable management will involve the extraction of beech and a very small amount of rimu trees in a range of diameter classes. The extraction will be undertaken at a rate and in such a manner so as to ensure that extraction does not exceed the natural rate of replenishment of the forest, and so that the forest ecosystem, and associated resources, are maintained in perpetuity.
- Extraction of beech and rimu trees will be selective and will almost exclusively use aerial extraction by helicopter, the exception being extraction of trees adjacent to road lines. The proposal comprises two distinct and different management regimes depending on whether or not the forests are in an unmodified "old growth" state, or if they have been subject to past catastrophic disturbance such as clear felling or earthquake. The latter category of forests are referred to as "recovery forests". The theory behind the sustainable management concept and how this will be applied to these two types of forest has been discussed in detail in the evidence of Mr Richards.
- Management of old growth forests will not involve clear felling or unsustainable partial felling. Instead, between 1 to 10 mature trees will be felled at each location and the canopy gap size will not exceed 0.05 ha. On average, approximately 15 trees per hectare will be extracted from any given hectare once every 10 to 15 years. The trees will be extracted in proportion across different diameter classes to retain the multi-aged structure of the forest (i.e. harvesting will not focus on just the large old trees). There are a number of other significant mitigation measures detailed in the application designed to avoid, remedy and mitigate the effects of the activity on the environment. These are included in Section 8 of Volume 1 of the application, and have in general been discussed in the evidence of other witnesses for Timberlands.
- Management of recovery forests takes more of a thinning approach with a view to returning even aged forests to a multi-aged and thus more ecologically balanced forest structure. This management regime includes safeguards such as maximum numbers of stems per hectare which may be harvested, a maximum percentage basal area of trees per hectare which may be harvested and a minimum harvesting return period of 10 years for stands of trees. Once a multi-aged forest structure is achieved, these forests will convert to an old growth forest management regime.
- In addition to sustainable forest harvesting, the proposal comprises implementation and management of a network of forest roads and helicopter landing sites. The roading network requires river and stream crossings resulting in consents also being required under s13 of the Act. Application for such has been made to the Tasman District Council in terms of its Regional Council functions, while applications for river and stream crossings within Buller District are being sought from the West Coast Regional Council independently of these applications.
BULLER DISTRICT PLANS
- A comprehensive list of proposed conditions is included in the planners report which is based on the extensive range of mitigation measures outlined in Section 8, Volume 1 of the application. In general I consider the recommended conditions to be appropriate and representative of the mitigation measures proposed by Timberlands in the application. Some minor amendments are suggested in the final section of my evidence.
TRANSITIONAL BULLER DISTRICT PLAN
- I do not propose to repeat all of the resource management analyses that have already been covered in the Councils' planning report. However, I do wish to emphasise the main points of the application compared to the provisions of the Buller District Plan.
PROPOSED BULLER DISTRICT PLAN
- The Proposed Buller District Plan is very near to being operative. However, due to some outstanding matters, the Buller County and Inangahua County sections of the Transitional Buller District Plan still have effect. However, for the reasons outlined shortly in relation to the proposed plan, full weight should be attributed to the rules and matters for discretion included in the Proposed Plan with regard to the actual sustainable management activity. The proposed sustainable management regime can be classified as a permitted activity under both of these sections of the Transitional District Plan, and therefore not requiring a resource consent.
Limited Discretionary Activity
- All of the sustainable management estate (within Buller District) falls within the Rural Zone in the Rural Character Area of the Proposed Buller District Plan.
"Indigenous forestry extraction and incidental earthworks (including the construction and formation of stockpiling areas, skid sites, access points and tracking) undertaken in accordance with an approval under Part IIIA of the Forests Act 1949, or in the case of Timberlands West Coast Limited, a sustainable management plan certified by the Director-General of Agriculture and Forestry as complying with the requirements of Part IIIA of the Forests Act 1949."
as a limited discretionary activity. The Council's discretion is limited to the following matters:
- As amended by consent order from the Environment Court in August 1999 Rule 220.127.116.11.2 provides for:
- Effects on waterbodies, wetlands and riparian margins;
- Effects on habitats of any threatened or protected species;
- Effects on archaeological, cultural or historic sites within the extraction area;
- Protection of outstanding natural features and landscapes;
- Protection of areas of significant indigenous vegetation or significant habitats of indigenous fauna identified using the criteria in Policy 18.104.22.168 as a guideline;
- Effects on ecological functioning and the life supporting capacity of air, water, soil, and ecosystems;
- Effects on the intrinsic values of ecosystems;
- Effects on recreational values;
- The location, extent and methods to be employed in harvesting operations in so far as these are relevant to the matters listed à above.
- As these rules are beyond the point of further challenge in the Plan review process, they should be given full weight in assessing the application.
District Wide Rules
- The Environmental Effects Assessment contained in Section 6, Volume of the AEE document attached to these applications is extensive and cannot for practical reasons be repeated here. However, in summary, the application can be compared against the matters set out above. In most instances, I have used the material set out in the AEE and contained in the evidence of other experts to summarise the proposed activity against the matters of discretion above. I have further examined these matters in the Assessment of Environmental Effects section later in my evidence.
- The District Wide Rules in Part 7 of the Proposed Plan must also be complied with for the activity to be a restricted discretionary activity. The only rules that potentially may not be complied with are those relating to temporary signs, and access points to strategic routes.
- Timberlands has stated that it will make site specific resource consent applications for any sign that does not comply with the performance standards in the Buller District Plan before the sign requires erection or construction. I consider that this is a very minor issue, and can be appropriately dealt with by condition of consent.
- Transit and the Buller District Council have signed a memorandum of agreement to amend the transport rules. This would result in all accesses which generate more than 60 vehicle equivalents per day a full discretionary activity. When the Environment Court releases a record of determination on this consent order, it will not change the status of the application from Limited to Full Discretionary as s88A of the Act requires that the activity status of the application be carried through to the conclusion of the application process including all appeals.
- With respect to the access issue, I have been involved in discussions with Transit New Zealand to attempt to prepare adequate conditions that would maintain the safety and efficiency of the State Highway system but allow the activity to occur. There are two separate access issues to be addressed:
- Private accesses to the State Highways
- Remote accesses using local roads but affecting the local road/ State Highway intersections
- In preparing the original resource consent application and AEE for Timberlands, we did not examine every access point on the ground that would be used over the 35 year consent period. Instead we sought that accesses that did not comply with standards for access to strategic routes (proposed rule 7.4 of the Plan as amended by Council decisions) be not included in the application. At the time of lodgement of the application it was unknown which access points complied and which access points did not comply.
- However, since notification, Transit's network maintenance consultant has indeed examined every proposed access and formed an opinion as to the suitability of each individual access. In further discussion with Transit, I am of the opinion that the safety and efficiency of the State Highway will be maintained, and Transit's concerns satisfied as long as a condition is imposed that requires prior to logging activities taking place:
- For private accesses to the State Highways û localised widening being carried out in accordance with Diagram D of the Transit New Zealand access standards (included in the Buller District Plan by way of consent order) minimum sight distances and spacing between accesses in accordance with Transit's standards; and,
- For local road/ State highway intersections, formation/ sealing to Transit's standards.
Objectives and Policies
- Therefore, it is my opinion that the application can be granted consent subject to the above two conditions being imposed. In the specific situation where an access does not comply with the above standards, Timberlands can either construct the access to meet Rule 7.4 or the relevant Transit intersection standard, or apply, in consultation with Transit New Zealand, for a change to the consent under section 127 of the Act. The change to the consent would allow a lower minimum standard to be used due to traffic generation and usage factors, and existing site conditions. In most situations, the application could be processed non-notified in consultation with Transit, due to Transit being the only party affected by the change.
- I have also examined the objectives and policies of both the Transitional and Proposed Plans contained in the Buller District Plan and can conclude that the proposed activity is not contrary to those provisions. I draw the Committee's attention to the specific reference to the Timberlands forestry activities in section 22.214.171.124 which states that: "Extensive parts of the Rural Character Area are Crown land, managed under an agreement with Timberlands West Coast Limited for sustained yield indigenous forestry purposes. This agreement is based on the West Coast Forest Accord (1986)." In my opinion, it can therefore be shown that the Proposed Plan specifically envisaged the sustainable beech management activity to occur in the Rural Character Area.
TASMAN DISTRICT PLANS
TRANSITIONAL TASMAN DISTRICT PLAN
- In conclusion, the proposed activity complies with the above matters of discretion, (analysed later in the AEE section of my evidence) and the two district wide rules, and any adverse effects can be avoided, remedied, or mitigated by the imposition of appropriate consent conditions.
Status of the Activity
- Parts of the Maruia Working Circle falls within the former Waimea County and are subject to the Waimea County Section of the Transitional Tasman District Plan. All forests are zoned Rural C.
- Timberlands has already obtained a certificate of compliance for the logging of these forests under the Transitional Plan provisions. This certificate of compliance is based upon the total area of clearance in each of the sites that will not exceed 5 ha in total in any 5 year period.
PROPOSED TASMAN DISTRICT PLAN
- The Transitional District Plan and Proposed District Plan allow clearance of up to five hectares of indigenous forest per site in five years. In the Transitional District Plan this is a permitted activity, while the same activity is a controlled activity in the Proposed District Plan. Accordingly, applications for the four separate forests of the Maruia circle have been sought. However, there is an argument that the non-contiguous area of the four forests in combination will need to be assessed in terms of the rules. Therefore consent has been sought for the activity in the full working circle, based on full discretionary activity status in the Transitional District Plan and restricted discretionary activity in the Proposed District Plan.
Status of the Activity
- The Timberlands forests are all located within the Rural 2 zone. Under the relevant rules, the activity can be evaluated as a controlled activity, provided that less than five hectares in total is cleared in any one year.
- There are some considerable interpretational issues associated with the rules for indigenous forestry. These issues have been discussed in section 5.3.2 of the Assessment of Environmental Effects. In essence, they relate to the definition and interpretation of the area of clearance permitted under the relevant rules. Due to the status of the District Plan, the Transitional Plan rules must be taken into account. Under those provisions, clearance over five hectares is a discretionary activity.
- While the rules in the Proposed Plan permit the activity as a restricted discretionary activity and those matters are set out in the Plan, the Transitional Plan provisions ensure that the activity must be evaluated as a full discretionary activity within the Tasman District.
- There are also other rules in the Proposed Plan relating to the frontage to unformed legal roads; land disturbance; and earthworks. As the application is classified as a full discretionary under the Plan, these matters are necessarily taken into account in the assessment of the effects of the activity.
OTHER RELEVANT RESOURCE MANAGEMENT DOCUMENTS
WEST COAST REGIONAL COUNCIL
- In conclusion, I have evaluated the effects of the activity against the provisions of the Tasman District plan and conclude that the activity can be granted consent subject to appropriate conditions of consent being imposed. This includes an evaluation of the objectives and policies of the plans of both areas.
BULLER WATER CONSERVATION ORDER
- The West Coast Regional Council controls land disturbance and earthworks through rules in the Transitional Regional Plan and Proposed Soil Conservation and Erosion Control Plan (Part 1). TWCL have obtained land use consents for works associated with its roading/ landing site network and helicopter harvesting activities. In addition, land use consents pursuant to s13 RMA (works in, on, under and over the beds of rivers) are currently being obtained from the Regional Council to allow stream crossings.
- Many rivers and streams in the general application area are subject to protection under the Buller Water Conservation Order. However, road crossings of waterways (i.e. fords, culverts etc.) if required, are not controlled by the conservation order (subject to obtaining necessary resource consents) as none of the areas where crossings will be required have a natural state classification.
- The applications can be classified as being restricted discretionary activities under the provisions of the Buller District Plan and full discretionary under the provisions of the Tasman District Plan (because of the Transitional Plan provisions). The following sections of the Act are relevant in evaluating the applications.
- Section 105(1b) states that a consent authority may grant or refuse the consent, and (if granted) may impose conditions under section 108: provided that, where the consent authority has restricted the exercise of its discretion, consent may only be refused or conditions may only be imposed in respect of those matters specified in the plan or proposed plan to which the consent authority has restricted the exercise of its discretion.
"(a) Any actual and potential effects on the environment of allowing the activity; and
(c) Any relevant à regional policy statement, and proposed regional policy statement; and
- Furthermore, the Council must also have regard to the matters to be considered in section 104 of the Resource Management Act. It is noted that the Council is not bound by the matters of Section 104 and does not mean that the matters in Section 104 must necessarily be followed. With respect to this case, the following subsections are relevant:
(f) Any relevant regional plan or proposed regional plan, where the application is made in accordance with a district plan; and
(g) Any relevant water conservation order or draft water conservation order; and
(i) Any other matters the consent authority considers relevant and reasonably necessary to determine the application."
PART II OF THE ACT
- Any relevant objectives, policies, rules, or other provisions of a plan or proposed plan; and
- Section 5 of the Act sets out its purpose that is to promote the sustainable management of natural and physical resources. "Sustainable management" is defined in s5 and means:
- "managing the use, development and protection of natural and physical resources in a way, or at a rate, which enables people and communities to provide for their social, economic, and cultural wellbeing and for their health and safety while:
- sustaining the potential of natural and physical resources (excluding minerals) to meet the reasonably foreseeable needs of future generations; and
- safeguarding the life-supporting capacity or air, water, soil and ecosystems; and
MATTERS OF NATIONAL IMPORTANCE:
- avoiding, remedying or mitigating any adverse effects on the environment."
- The following matters are matters of national importance that should be considered as relevant to this application.
(e) The relationship of Maori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, and other taonga.
- The protection of outstanding natural features and landscapes from inappropriate subdivision, use, and development:
- The protection of areas of significant indigenous vegetation and significant habitats of indigenous fauna:
- Section 7 sets out certain matters to which the Council must have regard in achieving the Act's purpose. This includes:
ASSESSMENT OF ENVIRONMENTAL EFFECTS
- the efficient use of natural and physical resources;
- the maintenance and enhancement of amenity values;
- Intrinsic values of ecosystems;
- the maintenance and enhancement of the quality of the environment:
- Any finite characteristics of natural and physical resources.
Effects on Water Bodies, Wetlands and Riparian Margins
- I consider that this application is an ecologically complex application that has required a considerable input into the evaluation of environmental effects. The application contained an extensive Assessment of Environmental Effects with reference to further even more detailed material relating to the proposal and its effects. Most of the potential or perceived adverse effects have been already dealt with in greater detail in the evidence of other witnesses. In my evidence that follows, I have sought to summarise the potential effects and the mitigation proposed. Sections 48 to 57 relate directly to the matters of discretion that are set out in the Buller District Plan. I then discuss wider matters that should also be taken into account in evaluating the applications as full discretionary activities under the Tasman District Plan.
Effects on Habitats of Any Threatened and Protected Species
- Timberlands has identified stream side protection zones where timber extraction and roading activities will be strictly regulated. Design criteria for river crossings are also included to ensure fish passage is maintained and physical disturbance of waterways minimised. The method of timber extraction will minimise sediment mobilisation, while road construction and storm water control will be undertaken in a manner that protects waterways and any wetland areas.
Effects on Archaeological, Cultural or Historic Sites within the Extraction Area
- The low intensity of harvest, retention of large trees providing nesting habitat for birds and bats, protection of riparian margins and waterways, and reservation from production of areas with particular identified habitat values of special significance will ensure there are no significant adverse effects on the habitats of threatened or protected species. It is important to emphasise that the areas to be managed are areas that are the result of an already extensive "sieving" process that over the last ten years has involved the Forests Accord and additional areas protected as part of the Timberlands proposal itself. This process has ensured that habitats of significance have already been removed from the management regime.
Protection of areas of Outstanding Natural Features and Landscapes
- Known sites have been identified and mapped, while protocols have been put in place to ensure archaeological, cultural and historic sites which are inadvertently discovered during operations are adequately protected. Timberlands also agrees to the imposition of the proposed consent conditions set out in the Councils' Planning report (conditions 4 û 6) relating to archaeological, cultural or historic sites. I note that further discussions have been held with Ngai Tahu subsequent to the lodgement of their submission, and agreement has been reached as to the imposition of an accidental discovery protocol for historic sites. I understand that such a protocol will satisfy the concerns of Ngai Tahu (condition 7).
- Identifiable areas of outstanding landscape and natural significance discovered through ground or aerial survey have been accorded protected status where appropriate. More importantly, I consider that landscapes in general have been protected through the low-impact nature of the proposed operation. Again I emphasise the "sieving" process that has occurred in the selection of these forests for management, and the range of other reserves and national parks within the regions that already contain significant and outstanding landscapes.
Protection of areas of Significant Indigenous Vegetation and Significant Habitats of Indigenous Fauna
- On my site inspection of a recently sustainably logged area as part of the trials, I was unable to ascertain a "logged" area from an unlogged area either from the helicopter or on the ground until I was directly adjacent to the logged area. In almost all situations, the public will be viewing the forests from an oblique angle. Such an angle will prevent any view of the "logged" areas. This is in marked contrast to the adverse landscape effects of clear felled areas.
Effects on Ecological Functioning and the Life Supporting Capacity of Air, Water and Soil and Ecosystems
- The areas of West Coast indigenous forests with the most significant vegetation and habitat value have already been identified and included in the conservation estate through the West Coast Forest Accord process, and other reserve processes. Timberlands has gone further to identify and reserve from production additional areas within its estate. These measures, in association with the low intensity operations proposed, will ensure protection of areas of significance, and will ensure that any effects on other areas are avoided or adequately mitigated to the extent that adverse effects will be minimal.
Effects on the Intrinsic Value of Ecosystems
- The proposed low intensity nature of operations, harvesting of trees over a range of diameter classes (i.e. not just the large trees), deliberate retention of a proportion of felled trees and woody material on-site to retain sufficient nutrients from decomposition, and other management measures, will protect the ecological functioning of the forest ecosystem and the life supporting capacity of air, water and soil. In addition, proposed management of even-aged "recovery" forests which have been subject to previous natural disturbance or logging are likely to show improved ecological functioning as stands are returned to a more mixed age structure. I also note that the earlier proposal for "improvement felling" was deleted from the application before you.
Effects on Recreational Values
- As well as protecting identified areas of special value and reserving these from production, the management system by its very design and low intensity will protect the intrinsic value of ecosystems.
The Location, Extent and Methods Employed in Harvesting Operations
- To a large extent the areas of highest recreational value are in the conservation estate and are not affected by this proposal. Recreational values within the Timberlands estate will be protected by reserving from production areas of particular identified value. Those areas not reserved from production will be subject to minimum disturbance due to the low intensity of helicopter extraction, large time period between extraction events in the same area (10 û 15 years) and relatively short periods when extraction operations are conducted in each area. There will be positive benefits for recreation with areas not undergoing operations being available for a wide range of recreational activities, some of which are not permitted in the conservation estate.
- The operational methods and management system to be employed have been designed to have minimum impact on the environment. This includes the use of aerial helicopter extraction, directional felling techniques, tree selection by suitably qualified professionals, and canopy gap size and distribution modelled on natural occurrences.
- In evaluating these applications, the consent authority is required to consider the matters set out in Part II of the RMA, in addition to those matters that I have addressed above. While these matters are not part of the matters that the Buller District Council has restricted its discretion to, they must still be considered in evaluating the application. It is my opinion that the financial profit of the activity should not be under scrutiny as part of the evaluation of these applications, as has been suggested by some submitters. This matter will be addressed in the medium term by the profitability and therefore feasibility of the activity. That is, the market will decide whether or not the activity is efficient. If it is not efficient, then the activity will simply cease. Given the passive nature of the management system, discontinuation of the operation would not have any significant adverse effects other than perhaps more impact from predation due to removal of funding commitment to their control. However, the direct (and indirect) economic impact of the activity on the wider community should be considered.
- Unlike past proposals for utilisation of the beech resource, the current proposal represents a more efficient use of the (natural) resource, with more value extracted from harvested trees and retained locally with dramatically reduced cost to the environment. Previous proposals such as chipping would have seen little downstream economic benefit derived locally with chipped beech product being exported without any added value processing on the West Coast.
- Sustainable beech management will target a niche market with a high value solid wood product (e.g. veneer, feature flooring and panelling, and furniture) being part or fully manufactured locally prior to export overseas and to other areas within New Zealand. This will enable a higher economic value to be derived domestically from the harvested beech, in perpetuity.
- It is likely that downstream economic effects will occur as a result of this activity both on the West Coast and further afield in areas such as Canterbury. The ultimate nature, scale and location of processing will be determined through commercial interaction of local processors, investors, and those with market access and the resource manager.
Direct and Downstream benefits
- Today on the West Coast and in Tasman District a resource exists that is capable of sustainably producing a range of quality wood products. This provides an opportunity for giving rise to further social and economic activity in a region where economic (and social) diversity and sustainability is limited by historical, geographical and, to some extent, external political influences.
- In employment terms high value recovery required of fine woods operations are much more labour intensive, with an efficient operation employing in the order of two or more times the labour for a given level of pine production. The main anticipated product lines will be furniture, feature and composite flooring and solid and composite joinery.
- Tourism is a significant contributor to the West Coast economy. While there is very little direct use of the sustainable management estate for tourism, its naturalness contributes indirectly to the tourism experience. Visual impacts of harvesting and roading from state highways has the greatest potential for adverse impacts on tourism. However, I have already concluded above that there will be no adverse effects on landscape values from the most sensitive areas (i.e. state highways). Tourists would need to visit a specific site to have any knowledge of the sustainable management activity. In most cases, this is very unlikely to occur.
PART II MATTERS
- Commercial tourism ventures will be possible within the sustainable management estate. Improvement and extension of the forest road network will also improve the opportunity for use of the sustainable management estate for tourism through improved vehicle access. Though the types of tourism that benefit from management of the estate may be different to those that theoretically might benefit from an unmanaged estate, the differences will complement the overall diversity of the tourism experience and will certainly compliment the vast unmanaged resource opportunity in the public conservation estate. In this way, the proposed activity will have positive effects on tourism within the Buller and Tasman localities.
- I have already addressed many of the relevant matters set out in sections 5, 6, and 7 of the Act in my evidence above, and the specific details have also been addressed in the evidence of other witnesses to this application. In particular, this especially relates to those relevant matters in sections 6 and 7 of the Act, some of which have been used as restricted matters of Council discretion in the Proposed Buller District Plan.
- However, I consider that the central issue of these applications is one of the sustainable management of the forest estate for logging purposes, and the application of Section 5 to evaluating the applications. The West Coast, just as any other area, needs to be able to rely on a range of industries to support its economic base. In the past, conservation in New Zealand has meant the "locking up" of large tracts of land û especially on the West Coast of the South Island. Tourism has been proposed as the cure of the economic issues for the Coast. And tourism has shown remarkable growth on the West Coast. However, this sustainable beech scheme will not have a negative effect on the tourism industry but will provide further diversification and long term sustainability of the timber industry on the Coast. This is a key issue for the West Coast. The economic sustainability of the West Coast requires that the economy is diversified, not focused singly on the tourism industry. This application is part of that diversification. Furthermore, it is at a rate that will assist in providing for the very long-term social and economic protection of "people and communities" on the West Coast.
- I was strenuously opposed to earlier beech schemes that sought to chip large areas of beech forest and export these chips overseas. I would still be opposed to such a scheme today. This application does not represent such a scenario. The difference is emphasised in the small scale nature of this proposal, and the extremely low level of adverse effects that will result from this activity. In my opinion, to state that the effects will be "minor" would be to overstate the effects. In preparing the AEE, I have not been able to identify any adverse effects that have not been able to be mitigated. Traditional logging methods have resulted in larger effects on the environment because of clear felling, and extraction by forest roads. This approach has resulted in significant ecological effects. This application proposes low level rates of felling using helicopter extraction, with the imposition of strict monitoring standards.
- An important part of the application is the monitoring and the feedback mechanisms that will translate into further "fine tuning" of the activity over the thirty five year period.
- Furthermore, a very significant outcome of the activity will be the control of introduced pests to a much greater degree than would otherwise occur in these forest areas. In most cases, I do not consider that the pest control is required specifically as mitigation of the effects of the activity. It is however, part of responsible forest management and forms part of the overall management scenario for the estate.
- I also must emphasise the "sieving" nature of the forests that have been selected for sustainable management. In particular, the 1986 Forests Accord placed these areas aside specifically for sustainable indigenous beech management as part of a wider settlement involving major conservation groups, labour organisations, district councils, and sawmillers. Areas of natural significance were again excluded from management areas and placed in reserves. Timberlands has undertaken an additional "sieving" process, and further excluded areas of natural, ecological, and landscape significance from the management proposals. It could now be argued that the areas remaining as part of the forest estate are not outstanding or significant in the regional context. These areas have already been placed in national park, or reserve, and what remains have been specifically identified as being able to be sustainably managed for low level production.
- Based on the evidence of the other witnesses for the Timberlands application, I consider that the ecological effects of the activity have been fully addressed and where required, mitigated. I consider that the subsections (a-c) of Section 5(2) of the Act relating to sustainability for future generations, life-supporting capacity of the soil, and the effects on the environment have all been addressed. In effect, the issues become the compliance with the first part of section 5(2), and one of the whether we should use, at all, a resource such as this in this way. This is a philosophical question and is in my mind a central issue to the parties to these applications. It could even be argued that this philosophical question forms part of the "cultural" wellbeing of people and their communities. But it does not alter the fact of the lack of long term effects from the activity.
- Opposition to this application is based on the perception that the effects from the activity are major and that the forests should be left untouched and "preserved" for future generations. In the regional context of the West Coast, this cannot be seen as a sustainable management approach as it does not provide for the social, cultural, and economic wellbeing of the West Coast people and its communities. It is difficult to see that preservation of these areas will somehow lead to an increase in tourism. There is already significant areas on the West Coast (78% of total land area) set aside for such use. On the other hand, this proposal embodies all the aspects of sustainable management set out in section 5 of the Act. It proposes to both use and protect a natural resource at a rate that will have both a direct and a downstream benefit for the West Coast and for New Zealand.
NEGLIGIBLE ADVERSE EFFECTS
- The precautionary approach has been discussed in the Councils' report. In this application, the proposal is only to extract up to a maximum of 50% of the increase of the forest's average annual growth. This 50% figure is itself low and permits considerable latitude should the feedback mechanisms indicate that too much timber is being taken or that the effects are more than minor. But it is also part of the overall on-going audit process that is proposed that will ensure that the activity is sustainable over the 35 year period, and indeed over the longer term. I consider that the low extraction rate figure, the lack of environmental effects, the self imposed maximum consent term of 35 years, and the feedback mechanisms proposed will ensure that future generations continue to have this resource in accordance with Section 5 of the Act.
OBJECTIVES AND POLICIES
- Drawing on the evidence of other witnesses to this application, I can conclude that the activity avoids, remedies, or mitigates any adverse effects of the activity on the environment. In my opinion, it therefore complies with the rules of the Buller and Tasman District Plans.
- I have assessed the activity against the objectives and policies of the Transitional and Proposed Plans of both Districts. I can conclude that the activity was envisaged as part of the preparation of these Plans and complies with their objectives and policies.
CONDITIONS OF CONSENT
- I consider that the proposed activity embodies the philosophy of sustainable management as set out in Section 5 of the Resource Management Act.
- I consider that the conditions of consent recommended in the Councils' planning report are acceptable with the following changes and additions:
- It is not practicable to comply with proposed condition 27 that requires bunding of all hazardous substances. This would include a single five litre container of chain saw fuel, or agricultural weed spray, that is required in day to day operations. The condition needs to be modified to include larger quantities of hazardous substances but maintain the flexibility for day to day operations.
Peter L Glasson
07 December 1999
- An additional condition should be added relating to the standard of accesses to State Highways, and remote access to roads that intersect State Highways. I have set out the suggested mechanism for such a condition in my evidence above.