Sustainable Management of Beech Forests:

Consequences for Biodiversity and New Zealand Conservation Management

Submission of Evidence


Dr Henrik Moller

Ecosystems Consultants Ltd.,

P.O. Box 6161,


03 û 4776885

03 û 4776895 (Fax)


Web site:

Presented in Support of Resource Consent Application RC99/75

Executive Summary

This TWC proposal is innovative and ecologically sensitive. It embodies a complete paradigm shift from earlier exploitative and ecologically unsustainable forestry practices. Economic return has been moderated so that a very small fraction of the annual production of the forest is taken. Tree removals are on small spatial scales, the size of natural forest gaps. Species and size classes of small groups of trees are selected for removal in direct proportion to their availability in the forest. This means that the size structure and species composition of the forest are not greatly altered, and forester's will "track" where the forest system goes rather than "pushing" it into an altered state that might yield increased timber production but also might increase risks to biodiversity. The proposal is in line with international contemporary shifts to 'Natural Forestry' and 'Ecosystem Management' approaches.

The Proposal has correctly identified the old large beech trees as an important habitat feature for birds and bats and taken several steps to ensure that this critical resource is not reduced to any great degree. Old trees and dead standing trees are sites of abundant food and hollows for nesting and roosting. They will be left and sufficient intermediate sized trees will be retained to grow through to replace natural losses in these old large trees. Rigorous monitoring of forest structure and the population abundance trends of 'focal species' will be used to guide an adaptive management approach to optimal tree removal regimes for protection of biodiversity.

Historically habitat degradation through unsustainable forestry, agriculture and urbanisation undoubtedly caused the demise and reduction of many of New Zealand's endemic species. But today it is the effect of introduced competitors, predators and browsers that are the main cause for concern in limiting native species. There is ample evidence that most of the endemic fauna and threatened species existing in TWC forests are depressed far below the 'carrying capacity' set by habitat availability because of predation by introduced mammals and wasps.

This has two main ecological consequences: (i) declines in New Zealand's biodiversity values are inevitable unless we act with force and soon to control introduced pests; and (ii) even reasonably major reduction in habitat quality will not exacerbate current pressures on biodiversity. So even if ecologists have somehow got their predictions very wrong, there is little prospect of irreversible consequences for threatened biota from this proposal. Nevertheless the proposal takes a precautionary approach to ensure that nothing is done that might significantly reduce habitat quality for valued indigenous biota. It is important to retain near natural habitats not only to minimise immediate risks, but also so as not to impair ultimate levels of restored biodiversity if effective predator and browser control is put in place in the long term.

The plan for active intervention to add conservation value to forests through browser and predator control mirrors the recent efforts of DoC to create 'mainland islands'. This is part of a general shift to a more active interventionist role for conservation managers û they are assuming a type of natural gardener's role of constantly weeding out introduced pest species. Wasps, rats, stoats and possums are the most important pests to control in beech forests to trigger restoration of ecologically representative communities on New Zealand's mainland. The proposer will divert 5 û 10% of the profits from sustainable timber extraction into this restoration effort. The result is a net conservation gain û a true win:win between biodiversity and economic interests. Only six such mainland island restoration sites are currently mounted by DoC throughout New Zealand and TWC proposes to trial 2 to 3 intermediate sized ones on their estate alone. I consider the scale of proposed restoration effort to be impressive despite uncertainty about actual methods to be used.

As well as adding conservation values to its own forests, TWC have funded extensive wildlife surveys in their preparation of these plans. New Zealand conservation management is critically short of survey information and ongoing monitoring of biodiversity in the way now proposed in the plan. This added information is a welcome adjunct to DoC's own challenge of managing "blind" due to lack of monitoring and a shortage of research capacity. TWC-funded predator control research is already providing benefits to other conservation endeavours. Secondary poisoning techniques developed from this plan are now being widely adopted by DoC and Conservation NGOs to manage reserves. More research is planned on predator controls, ecology and populations of threatened species, forest community structure and processes. All the understanding and experience gained in pursuit of their research for ecological sustainability can be exported to give a lasting benefit to conservation throughout New Zealand. Profits from sustainable forestry will help other under-funded conservation institutions such as DoC to best direct their scant resources elsewhere. This is one of the ways that New Zealand conservation will benefit from a mixture of preservation and conservation through sustainable use approaches typified by this proposal. Halting this proposal will therefore have several hidden costs for biodiversity by diversion of DoC's meagre funds from other conservation work to cover efforts proposed by the applicant.

The proposal has built in audits, controls, monitoring and mitigation processes to safeguard against deterioration of biodiversity within TWC forests. These assure public transparency. But more importantly, they set bounds on the degree of environmental damage that could occur if unexpected outcomes arise from inadequate knowledge of ecosystem processes.

Unknowns exist in all ecological management programs, but especially in totally new styled initiatives like the forestry proposed here. However the newness of this proposal relates to its very minimal timber extraction regimes and the 'Natural Forestry' and 'Ecosystem Management' philosophy. Common sense and existing reliable ecological knowledge about overall ecological processes leads me to expect that risks to biota from these unknowns will be minimal and containable. Mathematical modelling is underway, and more is proposed, to take best professional practice to estimating critical assumptions and set bounds on uncertainty in predictions. A formal adaptive management approach to managing these risks is proposed in the same way that is used to fine tune conservation management on nature reserves by DoC. This proposal is an important role model because New Zealand lacks formal applications of adaptive management models in the way proposed.

Placement of the first trials of "Natural Forestry" in New Zealand in north Westland is ideal for ecological risk minimisation and capturing benefits for biodiversity. TWC land is surrounded by a large matrix of inter-connected nature reserves. This buffers the TWC forests from ecological damage should unexpected effects emerge from the new harvesting philosophy. Equally if the expected benefits of increased abundance of threatened and common species occurs on TWC land, the new recruits and elevated population levels could spill over into the surrounding DoC reserve land. For a conservation biologist this innovative forestry initiative could not be better sited in New Zealand.

No known critically endangered species exist on TWC land, but 'Category B' and 'C' (DoC's second and third priority) threatened species are present and overall biodiversity in the forests is of high value. This signals the need for care and risk minimisation. I consider that such steps have been taken so that very little prospect of endangerment in the intermediate term remains. Rigoros monitoring and adaptive management will ensure that the slight risks will be further minimised in the longer term. Prior reservation as part of the West Coast Accord and creation of new reserves by TWC have added safety to biodiversity outside the areas proposed for harvest.

Great spotted kiwi, kaka, western weka and long-tailed bats are the species of highest priority for risk assessment and management. There is sound ecological evidence that all are threatened by introduced predators (except in the case of bats where evidence is more tenuous). I consider it very unlikely that these species will be harmed if the proposal goes ahead; indeed I consider it more likely that conservation will be denied benefit if this proposal is halted.

Direct risks to biodiversity from logging are minimal and extra precautions to protect kiwi and weka from possum harvesters and dogs are proposed. Felling of old trees containing roosting bats will replace natural tree fall because natural mortality will be subsumed by careful tree selection. Danger to torpid bats is therefore likely to be the same whether or not the proposal goes ahead.

This proposal also leads the way for sound environmental management in New Zealand by exemplifying approaches that have captured large gains for biodiversity overseas. Particularly pleasing features of general importance to conservation include:

  1. encouragement of open audit and public scrutiny on production land;
  2. the trend towards co-management, in which local corporations or community groups have real decision making power and responsibilities for conservation action;
  3. instead of leaving active conservation management to DoC, foresters will act as environmental stewards of their land;
  4. fostering examples of 'conservation through sustainable management' alongside a preservation approach to conserve biodiversity;
  5. attention to conservation of biodiversity outside nature reserves;
  6. adoption of an 'Ecosystem Management' rather than simply an economic sustainability approach to nurturing biodiversity;
  7. demonstrating commitment to sustained active management to restore biodiversity on the New Zealand mainland rather than just relying on biodiversity on off-shore islands;
  8. using financial profit as an opportunity to enhance biodiversity rather than threatening it. This proposal could act as a role model for other natural resource managers;
  9. building trust and mutual support between responsible resource users and conservationists;
  10. by honouring the West Coast Accord, the proposal will encourage negotiation and compromise and avoid public vilification of opponents in resource use conflicts;

The underlying ethos and creditability of the RMA are at risk if this proposal is rejected. The risks of not proceeding with this proposal go far wider than the lost benefits for biodiversity that would otherwise accrue to West Coast beech forests from the proposal.

Any unwanted environmental effects are very likely to be slight and will be rapidly reversible. The scheme is much more likely to realise immediate and tangible benefits for biodiversity.

  1. Introduction: the structure of this submission

My submission first identifies general ecological processes in West Coast beech forest ecosystems affecting biodiversity, habitat and threatened terrestrial fauna (Section 2) that might conceivably be affected by the proposal. It focuses on key ecological resources and processes that must be maintained if the proposed forestry is to be truly ecologically sustainable.

Section 3 then re-examines each of these key potential effects on particular threatened species identified as being present in the TWC estate and of high conservation value. Kaka, kiwi, western weka and bats are dealt with in some detail because they are particularly important in this regard to determine whether they are likely to be put at risk. Yellow-crowned parakeets , riflemen, bellbirds, tui and/or robins are singled out as potentially important focal species to monitor. A synthesis of the detailed survey data presented separately by Rhys Buckingham (Wildlife Surveys) is also presented in Section 3 and linked to the key question of whether timber extraction will threaten the wellbeing of the bird and bat communities present.

Section 4 considers the effectiveness of proposed ecological community restoration efforts through predator and browser controls.

As in all new endeavours, there are unknowns. I comment upon monitoring to minimising risks from these unknowns as demanded by the 'Environmental Precautionary Principle' The importance of these monitoring protocols and their rationale is evaluated in Section 5. This section is supported by Appendix 3 that considers some of the steps needed to finalise some of the monitoring protocols before they can be considered sufficiently scientifically reliable and cost effective.

General principles of conservation management approaches are considered in section 6, before conclusions and a synthesis are presented in Section 7.

My evaluation of the merits of this proposal comes from the standpoint of 22 years of professional experience and expertise as an applied population ecologist and wildlife manager. The detail of this experience is outlined in Appendix 1.

  1. Effects on ecosystem function, habitats and
threatened terrestrial fauna

  1. An Ecosystem Management Approach is proposed
There are several dominant themes that must be addressed to manage natural resources along 'Ecosystem Management' lines. These do not guarantee that your ecosystem will be healthy, as introduced animals impact on indigenous species no matter what your management method is. However, forest managers recognise general principles that are more likely to result in genuinely ecologically sustainable outcomes. Ideally Ecosystem Management will recognise that:
  • This proposal is geared towards Ecosystem Management. It meets many of the criteria set out by Grumbine as indicators of ecosystem management practices. This can be seen in the proposal through The broad thrust towards Ecosystem Management principles makes it much more likely that this proposal will be ecologically sustainable.

    2.2 Past levels: what is natural and what can we expect if we do nothing?

    There are no long-term monitoring programmes in place to quantify recent trends in wildlife abundance in TWC forests, and few elsewhere in New Zealand. The perception that species are sliding further towards the "extinction vortex" comes from shrinking distributions and anecdotal reports that wildlife abundance was much higher at the end of last century. Several species have already gone from all or most of the TWC beech forests (e.g., kakapo, South Island kokako, South Island brown kiwi, Little Spotted kiwi, South Island bush wren, yellowhead, South Island saddleback, South Island piopio, short-tailed bats, and an unknown number of invertebrate and plant species). Others persist over wider areas but may be in decline. Habitat removal and/or severe modification undoubtedly contributed to historical declines, especially in distribution (rather than abundance).

    However the factors causing initial declines are not necessarily the main threats now. Unfortunately there are signs of ongoing declines for some species even where habitats remain unchanged. A recent (1995) repeat of bird counts done in the 1970s in beech forests at Mt Misery (Nelson Lakes National Park) has detected declines in the abundance of 10 bird species (and increase in one). No habitat modifications have occurred in Nelson Lakes National Park in these intervening years û this is a sober warning of what might happen if preservation of land alone is considered to be a sufficient conservation response.

    Unless we intervene soon there is no reason to expect a halt to further degradation of biodiversity in TWC forests.

    2.3 Predation by introduced mammals and wasps: the immediate threat

    Predation is the most urgent problem confronting wildlife conservation in New Zealand. The Department of Conservation considers predation to be a critical threat to 18 of 30 vertebrate species, such as our national symbol the kiwi, that are of highest priority for conservation. New Zealand's attempt to protect these species are part of our national and international obligations to protecting biodiversity. In the past, conservation managers considered predator control in situ too unreliable, difficult and expensive, so the safest and most effective response was to shift threatened species to offshore islands where the predators did not occur. Now that most of the critically threatened species are secure on offshore islands there has been a shift of emphasis towards restoration of mainland ecological communities. This proposal continues this trend. Ongoing declines of several species suggests that predation will continue to restructure New Zealand's mainland forest communities unless the effective predator control occurs. It is only recently that relatively safe and effective methods of predator control have become available for conservation managers that might allow sustained pest control for restoration of mainland ecological communities. Rats and stoats are the critical predator species in South Island beech forests, especially after beech seeding has triggered population irruptions.

    2.4 Securing habitat quality: a basic first step but not sufficient in itself

    In the past habitat removal or severe modification has undoubtedly caused declines and endangerment of several species. Past unsustainable forestry practices have played their part in this regrettable situation, and strident public debate over clear felling and over-cutting of indigenous forests triggered the genesis of a popular conservation movement in New Zealand.

    Evidence has been cited that past forestry practices have threatened bird numbers by removing habitat. The past history of logging impacts provides a general precautionary tale. However, use of evidence concerning past methods for predicting impacts of the new approaches embodied in this proposal is unbalanced risk assessment. Work by O'Donnell & Dilks (1987) and O'Donnell (1991) is the most relevant of the published record to predict impacts of logging, but there are problems using it in this way to predict outcomes for this proposal, because:

    1. the proposal is not to remove the largest live trees or standing dead spars;
    2. the paper was based on data from a different forest;
    3. it tests the model by using data from forests heavily modified by historical methods not proposed here;
    4. Dr E.B. Spurr's data, used for the test of the model, compared forests logged recently c.f. long ago. This assumes bird abundance was the same everywhere before logging and that logging was the only important ecological change between areas;
    5. the predictions of the model worked for yellow-crowned parakeets and yellowhead, but not for kaka (we should have little confidence in any model until its predictions are upheld for a replicated series of species or place, or until a plausible post-hoc hypothesis is tested for why the model should apply to one species and not another);
    6. the model assumes that the preferences indicated by the bird studies demonstrates need, and so retrieves the over-riding assumption that habitat variables limit the populations. All animals will show preference of some sort or another for particular foods or places, but this does not mean that such preferences have any tangible impact on their numbers.

    The general public and some conservation NGO leaders have apparently failed to realise that habitat modification is no longer the critical ongoing threat to biodiversity in New Zealand, and certainly of little relevance for the current proposal.

    Since there has been no broad scale active conservation management intervention in the TWC and surrounding DoC forests, there is no reason to hope that the major declines registered over the past century are not ongoing. These inferences, albeit poorly quantified, emphasise the risk of doing nothing ù declines seem inevitable unless there is active management intervention to control predators. Nevertheless it is important for long-term minimal risk for biodiversity to not do anything to deteriorate habitat quality in ways that will reduce eventual "carrying capacity" once predator and competitor control has restored numbers.

    2.5 The importance of large old trees

    The fundamental approach of TWC's proposed timber extraction is to leave the forest structure minimally altered relative to natural variations. Indeed the careful monitoring and matching of timber removals to what is there is designed to "track" natural changes. Nevertheless ecological knowledge emphasises that retaining the visible presence of the forest may not be enough. Critical habitat features, like tree holes and hollows are thought to be potentially important for hole-nesting birds and bats.

    Monitoring of tree size and abundance is a critical safety check for biodiversity as forest use unfolds (see Section 5 and Appendix 3). Nevertheless there are already several inferences that holes do not critically limit current abundance of birds or bats. If predation or competition from introduced mammals and wasps suppress the population or is causing an ongoing decline, the population will be below the forest "carrying capacity" set by habitat variables such as food and nest/roost hole availability. There is ample evidence of the pervasive impacts of predation, and these predatory impacts have been operating for well over a century. In such circumstances we would expect the current populations to be very much below carrying capacity set by habitat variables. For example, in the only detailed study of its kind, yellowhead were found to have nine times more holes than they needed. During the first four years of this study, yellowhead density was about at carrying capacity, yet it was still not limited by nest site availability, nor through competition for nesting sites with yellow-crowned parakeet. Similarly it was also suggested that it was unlikely that nest sites were limiting yellow-crowned parakeet density. A recent review found no evidence of nest hole competition in New Zealand forests.

    Kaka numbers are also considered to be lowered far below the carrying capacity set by tree hole availability. A Landcare research team found virtually no re-use of the same holes for nesting in their 8 year research programme of kaka at Nelson Lakes National Park.

    Larger trees have more holes because of their size and therefore birds can use these larger trees more. It is unlikely that the quality of the holes in larger trees is different. Therefore, holes in all tree sizes are equally likely to be useable. This is important for predicting harvesting impacts.

    The critical question is whether the harvesting proposed will lower the carrying capacity below that which the current populations occur in the face of persistent predation. I think this is very unlikely indeed. Strict testing of trends in overall tree cavity abundance will occur as forestry proceeds provides a check that I am right. In the meantime every inference and available piece of evidence suggests that hole-nesting bird abundance is not currently limited by hole availability, and that there is no threat to this critical habitat element from the proposal.

    2.6 The importance of food supplies for birds

    Mistletoe, miro and rata are important food supplies for kereru and honeyeater birds like tui, bellbird and silvereyes. These species will not be used or changed in abundance by the proposed scheme. The especial effort to leave trees with mistletoe is potentially important since it is being progressively eliminated by possum browsing.

    The single greatest predictor of bird abundance in the beech forests involved in this scheme is the availability of the honeydew scale insect and this "keystone" or "critical" species is not expected to be affected by the low intensity timber extraction regime proposed. This gives me confidence that large scale and long-term changes will not occur from this proposal.

    Epiphytes are important for food and shelter and floristic diversity. Extensive epiphyte gardens predominate on the larger older trees. These will be protected by the tree selection protocols that are central to the proposal.

    The whole importance of food limitation for forest bird populations is unproven, and even more difficult to evaluate than the hypothesis that tree hole availability limits the population. Evidence for the mechanisms for the effects of past logging methods on bird numbers is almost completely lacking. Without this knowledge of mechanisms it is much harder to guess at the likely impact of small group tree removals when the bigger/older trees are left in place. However, the same general argument about the likely impacts of predation apply to the food limitation hypothesis i.e. when severe predation occurs, especially of adults as in the kaka case, food is most unlikely to be a limiting factor.

    The monitoring and adaptive management approach acts as an overall safeguard for these risks. Similarly, the same large trees left in situ by the group-tree selection protocols to safeguard availability of cavities will also help ameliorate potential food impacts because the largest trees are also the favoured feeding trees for many species of bird.

    2.7 Fragmentation and roading

    On average ca 3 - 4 gaps will be created per hectare of forest in each harvesting event (every 15 years). Most passerines have territories in the order of a hectare, and bats in the order of 10s of square km, so localised effects are unlikely to be significant. This style of forestry is fundamentally different in that it does not trigger fragmentation of the habitat. The size and intensity of tree removal events is similar to natural levels of gap formation in the forest and artificial gaps replace natural gaps by the tree selection and subsummation of natural mortality process. Canopy cover therefore remains intact. Fragmentation is therefore maintained at broadly natural levels.

    Fragmentation is a potential threat by disrupting dispersal between patches of suitable habitat. It also causes an increase in edge habitat compared to cores, and such edges are considered potential sites of intense predation and invasion by weeds. This "ecotone" idea has been promulgated from overseas work. DoC's Eglinton predator research team could find no evidence that stoats concentrated their activity near to roads in 1990/91 and 1992/93, and in 1991/92 traps along roads actually caught significantly fewer stoats. The only direct test of this "habitat edge" hypothesis in New Zealand so far failed to find any change in probability of predation of yellow-eyed penguin chicks on edges c.f. middle of forest breeding areas. It may be that New Zealand biota are so vulnerable to predation that any slight concentration of predators on habitat edges is irrelevant (since nestlings in centres are also nearly always eliminated even if there was less predator use of such areas).

    Roads may also benefit biodiversity by allowing cost effective predator controls and are also favoured feeding sites for long-tailed bats because they create habitat edges.

    Roads also present potential threats to forest communities, through the dispersal of invasive species via road and road traffic. Male stoats are thought to use the roadside habitat more often than females but there has been little research into the effects of roading on New Zealand's ecology.

    In any event, the proposed application reduces requirements for roads by about 10-fold, traffic is infrequent and the roads are narrow. They most certainly do not represent barriers to dispersal in the way large motorways do overseas.

    2.8 Recovery forests: a long-term habitat restoration initiativeThe primary way that this proposal will confer benefits on biodiversity will be through predator control. However some small areas of 'recovery forest' will be restored by silviculture methods directed to recreating more natural forest structures. There is ample evidence that bird abundance is reduced in such areas. Active intervention by foresters will speed the restoration for the long-term benefit of regional biodiversity.

    3. Risks and potential benefits to endangered species

    3.1 Overview

    TWC forests have some areas of high species richness and abundance. In no case is there unequivocal evidence that the nationally threatened biota present in the TWC forests are at critically low abundance (i.e. below the "Minimum Viable Population") in ways that threaten long-term local persistence. Thus we do not know if low abundance itself is a threat. Nevertheless the "Environmental Precautionary Principle" applied in this proposal aims to set a proximate goal to not do anything that lowers threatened wildlife abundance below its current level, or below its current trajectory of ongoing decline. I also consider that nothing in the proposal will greatly reduce the prospects of population recovery later, assuming that effective and widespread predator controls can be achieved and the adaptive management process is adhered to.

    The standard DoC criteria for threatened species work lists the following classifications for species on TWC land:

    Category A: (Highest priority): No species on TWC land

    Category B: (Second priority) Great Spotted kiwi


    South Island kaka


    Blue Duck

    New Zealand falcon

    Long-tailed bat

    Western weka

    Category C: (third priority) Yellow-crowned parakeet

    I concur with R. Buckingham that the proposed harvesting is most unlikely to harm these threatened species in TWC forests. The TWC estate has a high species diversity and bird abundance in some areas. It is important to note that the best areas of habitat in the region were taken into DoC reserves at the time of the West Coast Accord. This creation of reserves to exclude sites of especial importance for wildlife from harvesting was continued by TWC when preparing these plans. What remains in areas zoned for harvesting therefore has broadly much lower biodiversity value than the region as a whole. In this way a precautionary approach has already been taken to minimise risks to biodiversity from harvesting.

    3.2 Kaka

    The threatened status of kaka is well researched, and their low abundance and infrequent success in breeding in the South Island are major causes for concern. Historically and on a very large spatial scale, habitat removal undoubtedly caused declines in the distribution of kaka. However clearfelling or over-cutting is not proposed in this proposal, so it would be a non sequitor to link these historical patterns to predictions of what might happen now. A Landcare Research team led by Dr Peter Wilson has tested the hypothesis that reduction of honeydew by introduced social wasps reduces kaka breeding rate and/or success through competition. A supplementary feeding experiment, now finished, discounted the competition hypothesis. Instead predation of chicks and sitting adult females at nests by stoats is now considered to be the key threat to South Island kaka. Reduction in numbers by predators means that this species is most unlikely to be limited by food or hole availability. Therefore this proposal will not depress kaka numbers. In fact it may enhance them enough through predator control efforts.

    3.3 Other hole-nesting birds

    As for other New Zealand hole nesting bird species, yellow-crowned parakeets (a category C threatened species) are vulnerable to introduced predators. However, yellow-crowned parakeets are relatively more susceptible to stoat predation than most other endemic hole nesting birds. Yellow-crowned parakeets nest later than most other hole nesting forest birds and their breeding season extends into the time when stoats are reaching their highest numbers. Yellow-crowned parakeets nest in holes with only one entrance. The incubating adult is always a female. Therefore nest predators often "trap" and kill the incubating adult female as well as eggs and chicks. This causes a sex-biased death rate due to predation, with fewer females available to re-nest after nest predation. Additionally both the incubating female and older nestlings are highly conspicuous to predators due to their noisy vocalisation during feeding. Loss of adults to predators is usually a catastrophic threat for any New Zealand bird because they tend to be naturally long-lived and slow reproducers.

    Rifleman are thought to have declined in TWC forests. I consider the evidence for this decline to be statistically weak, as is also stressed by R. Buckingham. Rifleman use very small holes which are super-abundant. Any putative declines are most likely to be driven by predation or competition for insect foods with vespulid wasps, but this is speculation.

    1. Kiwi
    Great spotted Kiwi are present on some parts of the TWC estate. Like all kiwi species on the mainland they are considered threatened, though Dr J. A. McLennan, who studied the great spotted kiwi for several years, considers them to be the most secure of all the mainland populations. A recent survey of the high altitude ('subalpine') Saxon (Heaphy area) population showed no declines in the population after 10 years since Dr McLennan's initial baseline study there. However there have been no repeated surveys of the lowland great spotted kiwi populations to gauge whether they are stable or declining. Dr McLennan suspects the latter to be more likely and as a rule of thumb suggests that kiwi are holding their own in areas above 4.5 m of annual rainfall (the high altitude and/or rainfall seems to represent a refugia, probably from predator populations). Earlier more widespread distribution within the lower altitude dry beech forest has now disappeared. Dr McLennan cites the low ratio of juvenile to adult kiwi recovered by trained research dogs as evidence of predation. Accordingly we can infer that kiwi on TWC land are limited mainly by predators. Predation is listed in DoC's Kiwi Recovery Plan as the primary threat to be mitigated. The great spotted kiwi studied by Dr McLennan bred every year so there was no evidence of habitat quality limitations. In the absence of other information and the expected impacts of predators, it is safe to assume the same lack of habitat limits occur for great spotted kiwi on TWC land.

    Dogs are an occasional threat to kiwi and relatively easy to manage. Proposed policies will ban dogs from all kiwi areas.

    There is anecdotal evidence that cyanide paste used by possum harvesters occasionally kills kiwi. Small residues of brodifacoum have been found in North Island brown kiwi, but there is no evidence of direct poisoning by brodifacoum. Kiwi survival has now been monitored through several aerial 1080 poison drops without registering kiwi mortality. Gin trapping by possum hunters kills some adults . Survivors are often missing claws and around 7% of the Great spotted kiwi adults caught by Dr McLennan carried this sign, even though the intensity of possum hunting had declined a decade before his study.

    The proposal already plans to ban dogs from kiwi areas but I suggest that the above risks will be further avoided or mitigated by one or more of the following additional strategies:

    1. ban possum harvest from kiwi areas;
    2. insist that victor traps are used instead of gin traps;
    3. insist that traps and poison pastes are set up "ramps" at least above 35 cm and for preference above 70 cm, to eliminate kiwi (and Weka) by-catch;
    4. restrict harvesting during the kiwi breeding season (late winter to early summer) in kiwi areas.

    Great spotted kiwi are shyer than the other kiwi species. They roost above ground, commonly in raised root butresses. They are prone to bolt when disturbed and so are very likely to flee from the vicinity of harvesting gangs and so are not in danger of being killed. Direct impact of logging operations will probably be limited to occasional disturbance of nesting and potential loss of the current year's egg or chick. This is most unlikely to impact on the population's viability since the adults are long-lived.

    1. Other bird species
    Kereru gains its threatened status mainly from declines in abundance in the top half of the North Island. There is no suggestion that they are regionally threatened in Westland. Kereru suffer intense predation on the mainland and reach much higher abundance on predator-free offshore islands. Accordingly, predation is likely to be holding numbers well below the habitat's carrying capacity. The proposal involved such slight habitat modification that the prospect of any impact on kereru is an extremely remote possibility. Kereru breeding success responds rapidly to predator control so prospects for increase populations from the proposed predator control programme are good. This could be particularly beneficial for wider biodiversity if their hypothesised critical role in seed dispersal is correct.

    Western Weka is likely to respond in a similar manner to kiwi in TWC forests. Predation has been a particular problem in attempts to restore North Island weka. The precautions taken to protect kiwi are likely to also protect weka.

    New Zealand falcon are naturally rare. Any scenario that predicts that the current proposal would in some way harm them would be entirely speculative. The ecological needs and population trends of this species are not well understood.

    Similarily kea are most unlikely to be affected in any way by the proposal.

    A localised population of blue ducks occurs in one part of the estate. Since they are closely associated with streams which are very unlikely to be altered, there seems little chance that the proposal will impact on them.

    1. Bats
    Recent work has highlighted the need for a change of emphasis to increasing concern for South Island long-tailed bats as well as short-tailed bats. Formerly it was the short-tailed bats that were considered most endangered and long-tail bats were considered relatively common. More research of both species is urgently needed to see if the findings in the Eglinton Valley are representative of ecological factors impacting on bats elsewhere. The relative importance of long-tailed bat populations on TWC land compared to surrounding DoC land, or populations elsewhere in South Island, has not been demonstrated nor measured.

    Threats to birds are potentially different from those for bats. Very important in this regard is the lack of detailed information one way or the other about the importance of predation on bat numbers. The sparseness and apparent elimination of long-tailed bats from much of the TWC estate, even where no habitat modification has occurred, certainly points to some non-habitat related threat. Predation by introduced mammals is the most likely explanation, but this is speculation. DoC's bat recovery programme lists predation by rats, stoats and feral cats as a threat to bats. If they are not vulnerable to predation their populations may be much closer to the carrying capacity set by food availability or roost hole availability than expected for the bird species. Competition for insect prey with prolifically abundant introduced social wasps is potentially very important in honeydew beech forest areas.

    Bats go into torpor for some months of the year and so can not fly away if their roost tree was felled. O'Donnell records up to 123 bats roosting in one tree at a time. A high proportion of a local social group might then be killed if a key roost tree is felled in winter. However the proposal will not add to this risk because the harvesting replaces natural tree fall (mortality is subsumed because leaning and defoliated trees are selected). There is even some prospect that felling gangs will detect bats in the hollow trees just felled (their contracts stipulate that they must cut up such trees into short lengths to accelerate decomposition) and could be required to report them and where possible mount a "bat rescue" attempt.

    A population of long-tailed bats in the Eglinton Valley had at least 3 separate "cryptic" social groups that restricted their roosting to a much smaller area within a very large range. Replicate studies are needed to determine if this is a general pattern for short-tailed bat populations. Large areas of that range may have had no roosting by other social groups, or all might have been used. There is no certainty that the bats could (or could not) move or extend their areas to include new holes nearby. Most importantly, the proposal strives to maintain a large number of holes by various strategies. Had historical coupe clear-felling been proposed, then a risk of destroying or seriously disrupting the roosting area would exist, but this is not proposed. The current proposal represents a significant start towards assessing and potentially mitigating any putative impacts on bats. A formalised model of tree hole availability and the impacts of logging on it will objectively measure these risks long before any putative changes are imposed on the system. The model can also test various mitigation measures, especially ones involving tree selection criteria.

    Short-tailed bats roost hole requirements will probably be different from those of long-tailed bats. However, this evidence is very distinct from any expectation that such holes will be in limited supply, either before or after logging, or in the presence of both bats. There has not yet been an analysis of DoC's wider survey data for both bat species to test whether there are fewer or more bats in heavily cut over or coupe logged sites.

    Long-tailed bats in the Eglinton Valley shifted roosts regularly, often at almost daily intervals. This behaviour is markedly different from most other overseas bats studied, perhaps in part because tree cavity dwelling bats have received little study until the New Zealand effort. The crucial issue for our present risk analysis is whether or not they need to shift so often amongst such a large number of different holes or do they just prefer to do so. Does the continuous mixing reflect ecological or behavioural needs, or simply preference? It may just reflect a superabundance of holes available. It is not known for sure what effect reduction in number of holes in the roosting zone might have on the bats and whether there the overall area of the roosting zone will simply expand. It was clear from the Eglinton Valley studies that vast areas with abundant tree holes existed within the large foraging range of the social groups.

    Twenty-two percent of bat roosts in the Eglinton Valley were in standing dead trees. These were favoured roosting sites. TWC do not propose to remove the largest live trees or standing dead trees or spars. These standing dead trees will be left in situ, therefore the number of holes present in large standing dead trees should not be greatly affected at TWC sites (eg Maruia).

    The ultimate safeguard for bat impacts rests on rigorous population monitoring and the adaptive management framework in this proposal. This only allows retrospective assessment of impacts but sensible and extensive measures have been planned by TWC to ensure ongoing abundance of roost sites. I urge that consideration be given to long-term repeated surveys of bat abundance in the sustainable use areas.

    3.7 Other fauna

    Many of New Zealand's native freshwater fish species would be unaffected by the proposed felling regimes. There is a possibility that TWC forests are home to several endangered and/or threatened fish species including endangered kokopu species, the brown mudfish and the lamprey. Threats from starvation by the loss of terrestrial food resources caused by tree removal are unlikely. Many of New Zealand native fish are opportunistic feeders and if the abundance of one prey item declines alternative food species will be used. Loss of shade cover caused by tree removal is not important for many New Zealand species, while, riparian margins of 20 m would provide sufficient shading for those species such as Galaxias postvectis, G. fasciatus and G. argenteus common in forested streams. The proposal adequately addresses the major concerns of sediment inputs. This proposal could also provide opportunities for habitat enhancement such as placement of slash within streams to provide cover and the placement of appropriate culverts to ensure introduced species are kept restricted in their range while climbing native species (e.g. eels) have passage upstream. Generally, while there is need for a more comprehensive survey of waterways covered, the proposal presents a low risk to indigenous freshwater species and recreational fishing.

    Within the Inangahua Working Circle, five species of lizard are known or presumed to occur. The gecko species (Naultinus tuberculatus, Hoplodactylus aff granulatus, H. maculatus) are not regarded as seriously threatened or at risk and are widespread in distribution. Presently there are no known populations of skinks in the Inangahua Working Circle and only scattered records of skink species (Oligosoma infrapunctatum, O. nigriplantare polychroma, O. aff nigriplantare 'Grey Valley" and O. sp. 'Denniston') have been recorded in North Westland. The harvesting regime proposed by TWC should not result in any changes to forest structure or composition that would significantly affect lizard habitat, therefore direct ecological impacts are expected to be negligible. However, lizard populations could conceivably be affected by indirect ecological interactions if harvesting resulting in changes to ecosystem health and stability. Whitaker (1999) and Buckingham (evidence for this consent hearing) are concerned that increased competition and predation pressure from introduced species (such as wasps and mammalian predators) could be triggered by habitat changes from harvesting. I can not see how this could occur if harvesters are simply subsuming natural gap formation. The size of gaps and frequency of gap formation should not be greatly different from natural sizes and rates. The canopy would remain intact. It therefore seems most unlikely that changes in predator/prey interactions would occur. Whitaker (1999) considers that mitigative measures are not required for lizards with the proposed harvesting regime but environmental monitoring is necessary to detect changes to the lizard fauna.

    4. Restoration through predator control

    4.1 Technological advances create opportunity for restoration

    Various methods of direct and indirect poisoning have killed large proportions of tagged predator populations in New Zealand forests, so a growing suite of effective control strategies are becoming available to conservation managers. However, large proportions of native passerines are sometimes poisoned when poison baits are applied and exposed on the ground and few other species have been adequately monitored or long-term studies assessing the overall population impact completed. Risks of poisoning native wildlife can be reduced. Risks of poisoning robins were almost entirely eliminated when poison was contained in bait stations, and sustained large-scale control of predators (by deploying poison either aerial or in bait, along with trapping) has resulted in the successful recovery of threatened populations such as kokako. Extensive research is required before rigorous assessment of the costs and benefits to the native wildlife communities and optimise methods of the predator control strategies can be found. Nevertheless, a positive outcome is very likely.

    This proposal will add conservation value to forests by controlling introduced pests as a matter of routine forest stewardship. TWC research has striven to identify a cost-effective method that can be derived by staff on routine visits to forests for their other forestry duties. The proposed method of placing control stations (containing poisons) along the roads improves the cost-effectiveness of control programmes while still remaining very effective at killing predators. It will provide safe and cheap protection of native wildlife over extensive areas of the TWC forestry estate. Research into non-target impacts of these poisoning operations is first being completed before extension and routine application of the method is considered sufficiently safe. Until the risks are measured it is difficult to prescribe detailed methods or the scale of control interventions that will be possible.

    The secondary poisoning approach researched by TWC generated several subsequent investigations by University and DoC teams in the last few years. This is an example of the way research funded by a proposal like this can bring lasting benefits to other conservation endeavours throughout New Zealand. If this proposal is approved, more such research and practical benefits are likely to accrue for conservation throughout New Zealand. The Foundation for Research, Science and Technology is attempting to foster business investment of this sort through the new Foresight programme and NERF. The TWC effort proposed here is therefore in line with New Zealand government science policy.

    TWC now seek the opportunity to capture the benefits from their research to enhance bird (and potentially bat) numbers in their on forests. In my opinion the prospects for success are high. Valuable restoration of both common and threatened species is likely.

    4.2 Goal of enhancing biodiversity

    New Zealand society wants to maintain representative ecological communities on the mainland, partly to further protect biodiversity but also so people can all freely interact with and enjoy the species that make New Zealand forests part of our national identity. From this proposals a forestry concern is dedicated to helping perfect and include techniques for pest and predator control aimed at maintaining or even improving our indigenous forest communities. This is a key reason for my overall support for the proposal and my overall conclusion that it should be approved.

    The techniques to be applied are derived from several commissioned research projects to find the most effective methods to kill predators, minimise risks to non-target species and design optimum intervention strategies. The overall strategy and planning is outlined in their restoration strategy which involves the following general approaches:

    · trials of "multi-predator" control methods using secondary poisoning methods,

    · an initial phase (2-3 years) of research to measure efficacy of killing target predators and risks to non target species. Research is now swinging to the latter emphasis.

    · experimental management trials on 2-3 intermediate sized areas once risks to non-targets are considered minimal,

    · pulsing of poisons to maintain efficacy and minimise poison deployment,

    · research projects started to learn how key parts of the ecological systems responds to the proposed management,

    · joint funding with government science providers,

    · the restoration project should be overseen by a steering committee made up of all stakeholders (Foresters, DoC, Conservation NGOs, research agencies etc),

    · initial independent audit by conservation scientists after 3 years; and the restoration project be trial for 8 years at least before its overall success is evaluated.

    The overall Forest Community Restoration Project aims:

    This long-term goal is realisable by triggering the increase in abundance of extant species and extending the distribution of species now persisting within small areas of the TWC estate through control of introduced mammals, and eventually re-introduction of species previously present which now only exist on the offshore islands or in refuges on the mainland. Conservation of biodiversity includes retention of original ecological processes within the community and ecosystem, not just conservation of the species themselves. Increased abundance of some species may be essential to reinstate natural processes with long-term consequences. For example, enhancement of kereru numbers may trigger increased seed dispersal and reduction of wasps (Vespula spp.) may restore litter invertebrates to re-instate former rates of forest litter breakdown; and elimination of browsing pressure could reinstate former rates and directions of plant succession.

    4.3 Practicalities: the enormous magnitude of the challenge to be natural gardeners in perpetuity

    Restoration must proceed by expensive and intermittent intervention to kill the introduced predators, browsers and competitors. The key to success is to reframe the traditional role of the conservation manager as solely a passive protectionist in favour of a role as a gardener of near natural systems who constantly weeds out the alien species so that native species can flourish. This will demand innovation to develop new techniques and long-term commitment to constantly intervene because introduced pests are common, widespread and difficult to control over large areas of forest. They breed quickly and disperse widely, so numbers quickly resurge following localised control operations. The current proposal is an excellent example of the necessary change in philosophy that is expected to capture new gains for conservation of biodiversity.

    4.4 Scale of TWC Proposed Restoration Efforts

    TWC plans to devote between 5 and 10% of annual revenue derived from sustainable management of beech forests on research, pest control and monitoring strategies of pest and predator species. Possum numbers are to be maintained at medium to low levels throughout its forests. In TWC managed areas identified as "Integrated Management Landscapes" by the Department of Conservation, TWC will work co-operatively with the Department to achieve mutually agreed targets for pest control. Population monitoring of possums, wasps and predators to follow the success of control operations will be undertaken in eastern Paparoas and Station Creek in the Maruia Valley using annual trap-catch surveys, spotlight counts and tracking tunnels. Some possum control strategies are known to control rats, mice and stoats and these strategies will be used until other multi-predator control systems are developed. TWC intends investing in predator control research, specifically secondary poisoning. Predator usage of undisturbed, natural and harvest gaps will also be monitored in a one-off study.

    Preliminary plans are to mount at least two and maybe three "mainland island" restoration areas as a first step before extending it further across the TWC estate. Considering that DoC nationally is currently only mounting 6 such initiatives the proposed scale of intervention by TWC is admirable.

    The proposed new predator control in sustainably beech use areas will parallel that mounted by TWC at Okarito and Saltwater forests where sustainable forestry principles have been applied for the last decade. As yet, there is no formal report of the action and outcome but I. James reports that possum control has been undertaken since 1993 at Okarito. TWC has concentrated their effort in the southern 50% of the Okarito forest. In 1996, DoC did an aerial 1080 control operation in the northern 50% of the forest. TWC possum control operations until 1999 used 1080 jam "Feratox" and cyanide. This year "Feratox" has been placed in bait stations with the disposal of possum carcases. "Talon" (300g) has been placed in bait stations in spring and early summer. Spotlight counts have occurred before and after possum control operations. Rat and mice interference has been observed at approximately 50% of "Talon" bait stations. Stoats have been controlled by secondary poisoning of their prey (rodents and possums). Stoat numbers have been monitored by DoC using tracking tunnels in the winter of 1999. Monitoring of stoat numbers is to be repeated by TWC this coming winter. Bird numbers are no different or higher on the TWC land now as compared to nearby DoC land where no logging has occurred but predators have been controlled. This track record contributes to my confidence that real and practical commitment to predator and browser control will ensue if this proposal is approved.

    In my opinion the main priorities to maximise conservation benefits are to:

    I consider the above to be a worthwhile and practical approach that nicely complements efforts of DoC outside Westland. This maximises learning and benefits for conservation everywhere while adding tangible conservation value to the TWC estate.

    5. Monitoring

    5.1 Monitoring and adaptive management: a key for added safety for biodiversity

    Sound wildlife management demands well designed monitoring. Provided sound monitoring is coupled with learning and adjustment of subsequent management, all of wildlife management can be viewed as scientific experimentation. I view the commitment outlined in the proposal to sound monitoring to be exemplary.

    Monitoring birds imposes difficulty due to high cost to achieve reliable data. Instead a recommended programme to establish the risks to fauna will be a focus on the monitoring of what are recognised as key drivers to their maintenance, large old trees and pest numbers.

    The former is covered in terms of the monitoring target being set in relation to maintaining a similar forest structure and density, while the latter will be instigated as part of pest management strategies and will demonstrate the effectiveness and long term trends in relation to key pests.

    Direct bird monitoring will apply only in terms of establishing trends in representative areas on the basis that if a trend prevails in representative areas in a forest then subject to the same management elsewhere a similar trend should prevail. Therefore all trends must be assessed relative to nearby representative areas that are not being logged (most probably on DoC land).

    I suggest that initially two sorts of areas should be compared using a Before: After/Control: Impact ('BACI') design:

    1. Harvested areas with predator control, and
    2. Unharvested areas with predator control, but,
    where five years pre-treatment monitoring and five years post-treatment is done on (i).

    If after 10 years:

    1. Indigenous fauna in (i) is lowered or increased less rapidly after harvesting commences there are grounds for concern that some unexpected impacts on habitats have occurred from harvesting. If this arises by year 10 an intensified scale of monitoring should be mounted; or
    2. If change in indigenous fauna is the same or elevated in (i) after harvesting compared to area (ii) there is either no effect of harvest or a "net conservation benefit" is accruing in some way. Ongoing low intensity monitoring is then all that would be required.

    Adverse trends, if they eventuate, would need further investigation. However the primary expectation, based around the well-established rapid and positive response that arises for birds from effective pest control, is that there will be increased fauna abundance rather than a


    As animal abundance varies greatly in space, there is a statistical challenge to get adequate replication for the experimental approach. The "BACI" approach may give increased statistical power by having the before and after comparison on the same areas. A staircase replication could add confidence if the expected extension of predator controls into wider and wider areas eventuates.

    Critical habitat features, like tree holes and hollows are thought to be potentially important for hole-nesting birds and bats. For this reason TWC have commissioned a mathematical modelling exercise to identify the most important parameters to measure to allow confident prediction of the density of tree holes retained in the forest.

    A tree-cavity model under construction for TWC can most rigorously calculate the risk of tree felling killing torpid bats. This model will incorporate the bats' selectivity, the tree size selections used, and the months of the year in which felling is proposed.

    5.2 Use of indicator or focal species to measure harvesting impacts

    Given the great diversity of species, monitoring of all the biological components of managed ecosystems is impossible. There is no easy method to decide how management can consider the full complement of species that occur in forest systems. Based solely on pragmatic considerations, management of biological systems may be simplified and made more cost-effective by considering only a small group of indicator species as surrogates for the complete system. The concept of an indicator species, is one of a species that is associated highly with a specific habitat type and can be monitored to determine the possible reaction of the species to changes in this habitat type. Moreover, if this species is associated positively with a number of other species, then one may assume that habitat needs of the other species are also being met. Usually more than one indicator species must be selected because a single species can only serve as an ecological indicator for a narrow range of conditions within a habitat type.

    Use of indicator species to guide forest management in the United States and New Zealand has been controversial. The reasons and potential pitfalls of the approach are outlined in Appendix 3 of this submission of evidence. The general consensus has become that no species is likely to be a wholly satisfactory indicator of the viability of other species because of important differences in dynamics of individual species. However, this does not say that some species do not provide an integrated indication of the status of some portion of the forest system. The United States Forest Service has proposed changing to a 'focal species' concept which would allow a variety of approaches to selecting species to monitor and assess for viability. The key characteristic of a focal species is that its status and time trend provide insights to the integrity of the larger ecological system.

    I have included the extensive discussion of the concepts in Appendix 3 to illustrate the complexities involved. I believe it would be unwise to impose a rigid monitoring protocol on the consent before more focused research on ecologically important parameters has been completed. About two years would be needed to do pilot studies, measure statistical variance in counting methods and design the most cost-effective yet scientifically defensible monitoring method.

    5.3 Useful focal species for TWC to monitor

    Yellow-crowned parakeets would probably be useful as indicators of the well-being of hole nesting birds; bellbirds or tui for honeyeaters and impacts on fruit, nectar and insect foods; and robins for ground insect feeders. Rifleman are potentially useful too, partly because they may be declining and also because they are relatively easy to monitor compared to yellow-crowned parakeets. Yellow-crowned parakeets fluctuate with beech seeding (it triggers prolific breeding) so it is possible that riflemen are a more stable (and therefore more tractable) species to monitor for tree hole availability.

    Yellow-crowned parakeets are also potentially good "indicator' species for forest health in relation to predator impacts and logging practices. These birds are essentially a beech forest species that use large diameter trees both for feeding and for nest and roost sites. As hole nesters, yellow-crowned parakeets could be susceptible to severe reduction of suitable nest/roost cavities should unexpected reductions occur because of beech forests logging practices. Yellow-crowned parakeets were formerly common throughout South Island forests, today though they remain widespread and in some cases locally common. Some ecologists suggest that they are rare or absent in heavily logged forests but severe modification is not planned by this proposal. Also this rarity or absence does not always seem to be the case, with yellow-crowned parakeets still present in relatively high numbers in several modified beech forests, including those owned by TWC.

    The relatively high abundance of yellow-crowned parakeets in beech forest would make indexing of their abundance much more logistically feasible than for the rarer and more endangered species like kaka. The continuing threats facing yellow-crowned parakeets and other endemic species in New Zealand forests such as tree hole loss and introduced predators makes them ideal as an "indicator" of the health of the forest wildlife community as well as for other hole nesting species.

    6. Wider conservation management implications

    In this section I review some of these wider implications of the current proposal and relate them to current international trends in conservation and natural resource use.

    6.1 Audit and public scrutiny: the key to public confidence in the outcome

    A continual plea of conservationists is that that our plants and animals belong to us all. Private land ownership is seen as potentially threatening to biodiversity because it is portrayed as a warrant for landowners to do what they like out of sight on their own land. International evidence is mounting that the reverse may be true in some circumstances û that private ownership and control can become all the more an incentive to looking after the plants and animals in private care provided that property rights are well defined and economic interests are secure. Two issues are embodied here: scrutiny and problem ownership. This proposal sets regular, independent and open audits in place so that the general public can learn what is going on. The managers have acquired ISO/14001 Environmental management certification and seek other forms of independent ecological audit. The system of tagging timber extracted and the stump from which it was cut along with GPS mapping gives the ultimate safeguard that independent auditors can check whether protocols are being followed.

    These are valuable principles that should be encouraged for conservation of biodiversity by all natural resource users.

    All these factors provide the tools to give public confidence and Council capacity to ensure appropriate outcomes.

    6.2 Co-management: giving DoC a hand

    The World Wide Fund for Nature (WWF) and International Union for Conservation of Nature (IUCN) have been working hard since the mid 1980s to encourage collaborative management throughout the world. These international Conservation NGOs realised that top-down imposition of preservation on local communities was often not as effective as a mass of local, smaller scale, "bottom-up" approaches to nature conservation. New Zealand lags the world in fostering effective "strong co-management", partly because of well-meaning but unreasonable and short-sighted opposition from preservation-oriented Conservation NGOs. The view continues to be promulgated that the only way to safeguard conservation is by publicly owned reservation administered by a central "top-down" agency like DoC. This takes away the incentive from other enterprises, or individuals to act in an environmentally responsible way. Co-management takes time and planning to establish, but in the end is a lasting, sustainable and effective method of looking after biodiversity. It is also a cheap method for taxpayers to achieve both conservation and economic aspirations.

    In this application TWC is proposing to use some of the profits from a sustainable forest use to invest back into active conservation management, monitoring and research. It is a form of co-management that will marry biodiversity enhancement expenditure and risk management with profit earning. The co-management principle is embodied in the 'New Zealand Biodiversity Strategy' that is currently being formulated. That strategy tries to engender responsibility for conservation well beyond what DoC can achieve and this sets the tone for conservation in New Zealand in the 21st century.

    6.3 Conservation outside nature reserves: the crucial next challenge

    A related issue to co-management is the urgent need to foster active management of conservation outside nature reserves. Part of the myth of asserting that conservation must proceed only

    by preservation is a damaging idea that somehow conservation is a process that occurs only

    within lines on a map surrounding a nature reserve. Ecological processes and forces flow over these artificial lines drawn by people. It can lead some resource users to believe that if we have a reserve somewhere else we can do what we like outside those reserves. The proposal is an excellent example of the total reversal of this principle. It sets out to do nothing that diminishes biodiversity outside the extensive existing matrix of nature reserves around the area proposed for use. This acts as a model for other prospective resource users and is something that New Zealand must foster. Several of New Zealand's threatened plants occur only outside existing nature reserves.

    6.4 Foresters as gamekeepers: adding conservation value to the foresters' estate by active management

    The proposed control of introduced predators to restore populations of native wildlife (in the same way pioneered by the Department of Conservation) is part of a paradigm shift in New Zealand's conservation management as a whole towards a more active interventionist approach from a previously more passive preservation approach. Part of what Dr David Norton called the "myth of reserves" is that all you need to do to safeguard conservation is to create the reserve. Effective widespread conservation on DoC land is effectively precluded by inadequate financial and people resources. Predator control is expensive and must be maintained in perpetuity, rather like a gardener continually weeds out the unwanted species to allow others to flourish. Commitment to definite plans is difficult before the exact methods and cost-effectiveness of predator controls has been measured, and before the scale of the beech forest use and revenue are assured. Commitment to expending a percentage of revenue to predator control is therefore a logical and practical solution to the uncertainty.

    6.5 Thinking holistically: using an Ecosystem Management approach

    The Ecosystem Management approach evident in this proposal is new for New Zealand but at the cutting edge of quests for ecologically sustainable resource use overseas. New Zealand biodiversity will benefit from the sme general approach in other forestry proposals and agricultural land use practices.

    6.6 Commercial enterprise: an opportunity rather than a threat for conservation

    It has been obvious from the public debate of the TWC beech proposal that there is mistrust amongst preservationists that big business concerns could deliver conservation safeguards or gains. Investment in an industry relying on extraction of natural resources was considered a threat to environmental protection by preservationists because they suppose there will always be a commercial benefit from rapid over-exploitation of the resource and then transferral of the investment and profits to a new extractive industry elsewhere. TWC's mandate as a State Owned Enterprise will not allow this transferral of investment to other extractive industries. Apart from the areas set aside for additional nature reserves and scenic reserves, the available area is to be fully used by TWC for sustainable logging. There is no other resource for this enterprise to transfer its attentions to if it over-exploits the forest. This offers a large incentive for the company to maintain its rate of extraction within the ecological limits set by the productivity of the ecosystem to allow forestry in perpetuity. In this case the economic gain from forestry is in part directed back to enhance biodiversity values: a true win:win for conservation and economic interests.

    A recent review identifies many ways in which economic models and approaches can enhance conservation outcomes in New Zealand. New Zealand can do better for its plants and animals in future by fostering models of business profits being directed to enhance rather than damage biodiversity. I believe this proposal will act in this way and hasten healing of a damaging division between business and conservation interests.

    6.7 Sustainability: the ethos of the RMA and key challenge for the 21st century

    IUCN and WWF have recognised that sustainable development is the fundamental challenge facing biodiversity in the 21st century. Preservation is an important, sometimes critical element of protection of biodiversity. New Zealand is the envy of the world in its extensive network of nature reserves, and no region within New Zealand is more provided by reserves than the West Coast. But this proposal can demonstrate that biodiversity can be protected, indeed enhanced, within the context of 'conservation through sustainable use'. Rather than seeing conservation and use as alternatives demanding compromise, we need to learn and expect that each can co-exist and benefit from the other. Diversion of profits for active management to create net conservation gain, research and monitoring are obvious examples of benefits for conservation from this proposal. Retention of biodiversity for normal nutrient cycling, maintenance of intact forest cover to reduce erosion and wind-throw are examples of many ways that the long-term sustainability of low extraction forestry will be safeguarded by caring for biodiversity. The RMA's definition of "protection" of significant natural values does not demand preservation.

    I therefore consider that this proposal is an overdue example that should force New Zealand society to understand that preservation and conservation are two separate things. Both need the other for maximum protection of biodiversity.

    6.8 Active Management, Reversibility and the Environmental Precautionary Principle

    This proposal marks a paradigm shift for forestry and conservation alike. All new initiatives must be a step into the unknown. If we never step into the unknown we will never innovate and find better ways to conserve biodiversity. There are ecological unknowns and potential risks from the proposed timber extraction, just as there are ecological risks to biodiversity from vesting the land in DoC to manage as a nature reserve. The same adaptive management approach proposed by TWC to circumvent uncertainty has been used by DoC to learn how best to restore North Island kokako populations. Adaptive management is gaining momentum overseas to be the main tool to learn how to manage natural systems in forestry, fisheries, agriculture and conservation. Its power could be evaluated for other New Zealand natural resource users if this proposal is given consent.

    There are risks of non-use of natural resources and rejection of this proposal, but these are often not considered in conservation debates. The Environmental Precautionary Principle urges that unknowns are assumed to fall in the direction which best protects biodiversity. In this case uncertainty exists either way, so the principle can be followed only by using best professional practice to minimise risks and mitigate unwanted effects. The use of adaptive management and stringent monitoring are the keys to learning how the system will respond to management and to check best professional guesses about outcomes.

    Best professional practice demands minimisation of risks by restricting the spatial and temporal scale of perturbations. This philosophy is embodied completely in the group-tree selection that underpins this proposal.

    The other fundamental approach of conservation managers when faced with uncertainty about what to do is to ensure reversibility of actions. Of potential serious concern is the repeated demonstration by community ecologists that communities do not necessarily return to the same state after they have been perturbed. In this proposal this risk is minimised by the fact that the proposed timber extraction is to be at very low intensity that mimics the small natural perturbations in both spatial and temporal scales. Species ratios are not altered. Size and age distributions will hardly be changed. Little extra roading is needed and what is there will be in stable valley bottoms. Roads cover minimal areas and will eventually overgrow. By not "pushing" the system but "going where it goes naturally" the reversibility of the actions proposed is ensured and reversion from small changes should be rapid in ecological terms.

    Major ecological disturbances (earthquakes, cyclones, floods) are natural events. Even though they are infrequent events in human terms they can be relatively frequent within the 'generation time' of a forest. Accordingly they can place a fundamental "stamp" on the structure of the forest that will be evident for centuries. Management proposed by TWC tracks these major natural forest restructuring events by ensuring its modifications are at a comparatively micro-scale.

    Reversibility is thereby embedded in the philosophy of the management approach being taken in this proposal. This reduces long-term risks for biodiversity.

    1. Conclusion: the TWC proposal will enhance rather
    than threaten biodiversity

    In consideration of the risks and management of risks in this proposal I believe that it exemplifies many of the key approaches already being fostered overseas to ensure conservation of biodiversity. This judgement stems from:

  • I therefore conclude that biodiversity has a lot to gain from approval of this proposal. I consider it visionary from a conservation biologist and conservation managers perspective.

    A political decision to halt this proposal, however well intentioned by preservationists, will set New Zealand conservation back by several decades.

    This proposal deserves the RMA Commissioners' support.

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    Appendix 1: Curriculum vitae and my standing

    to evaluate this proposal

    I obtained a BSc (1975) and MSc (First Class Honours; 1977) from the University of Auckland, and a PhD from the University of Aberdeen, Scotland (1983). I have both a botanical and zoological training (double majors) and in the past 10 years have taught wildlife and conservation management at the University of Otago. I can therefore evaluate both science and management, especially in South Island beech forests where I have researched for over 10 years.

    The wider context of my commentary stems from over 23 years of experience in the application of ecological science for conservation, pest control and sustainable harvest. I was awarded the New Zealand Ecological Society Award in 1990, its inaugural year. This is the Society's top award for scientific excellence and is granted "in recognition of outstanding achievements in the study and application of ecological science". Other awards received by me include the Prince & Princess of Wales Science Award, 1994 (granted by the Royal Society of New Zealand), a Waitangi Fellowship (1995), a British Council Travel Award (1995), a Stapledon Memorial Trust Travel Fellowship (1995), and a British Council Higher Education Link Fellowship (1997 û 1999). I have published 85 peer reviewed scientific papers or book chapters, and a further 92 popular articles and reports.

    I am particularly experienced in ecological processes and the impacts of introduced mammals and wasps on birds and weeds in beech forests like those under consideration in this application. I have supervised student research on bats and mathematical modelling of Okarito brown kiwi population viability and robin trends with and without predator control.

    My evaluation of this submission is from the standpoint of a professional conservation scientist and harvest management scientist. I served (1991-1994) on the Scientific Advisory Committee for World Wide Fund for Nature (WWF-NZ) and currently is a member of the International Union for Conservation of Nature's (IUCN's) Australasian "expert panel" on Sustainable Use, and another expert panel on "Co-management". These expert panels are made up of an international coalition of conservationists, scientists and managers.

    I am the Minister of Conservation's appointee on the New Zealand Game Bird Habitat Trust Board, a group of managers dedicated to habitat creation and enhancement to support sustainable harvest.

    I work 80% of the time for the University of Otago, and 20% of the time for Ecosystems Consultants Ltd.

    Appendix 2: Common and scientific names used for plants and animals in this submission

    Bellbird (Anthornis melanura)

    Great Spotted kiwi (Apteryx haastii),

    Kaka (Nestor meridionalis)

    Kakapo (Strigops habroptilus)

    Kereru (Hemiphaga novaeseelandiae)

    Little Spotted kiwi (Apteryx owenii)

    New Zealand falcon (Falco novaeseelandiae)

    Rifleman (Acanthisitta chloris)

    Silvereyes (Zosterops lateralis)

    South Island brown kiwi (Apteryx australis)

    South Island bush wren (Xenicus longipes longipes)

    South Island kaka (Nestor meridionalis)

    South Island kokako, (Callaeas cinerea cinerea)

    South Island piopio (Turnagra capensis capensis)

    South Island saddleback (Philesturnus carunculatus carunculatus)

    Tui (Prosthemadera novaeseelandiae)

    Yellowhead (Mohoua ochrocephala),

    Short-tailed bat (Mystacina tuberculata)

    Long-tailed bat (Chalinolobus tuberculatus)

    Wasps (Vespula vulgaris, Vespula germanica)

    Beech (Nothofagus)

    Miro (Podacarpus ferrugineus)

    Mistletoe (Elytranthe)

    Rata (Metrosideros umbellata )

    Appendix 3: Proposed use of focal species to measure harvesting impacts on habitat quality

    Experience with using indicator or focal species to monitor harvesting impacts on biodiversity in USA is instructive for the current proposal. It is important to consider carefully and do preliminary research before the best species and methods are selected for monitoring. It is realistic to assume that at least two years of research will be needed to design the optimal monitoring method and check that yellow-crowned parakeets, riflemen, bellbird and or robins

    are indeed the most useful and reliable candidate to chose as a focal species. For this reason it would be unreasonable to impose a tight prescription of how the monitoring must be done as an immediate condition on this resource consent. A requirement to investigate and finalise a practical and scientifically defendable protocol by 2 û 3 years is possible.

    Focal rather than Indicator species

    In the United States the Forest Service is required to maintain viable population levels of native wildlife populations on public land and to prepare forest plans that include periodic evaluation and monitoring of management objectives (U.S. Laws, National Forest Management Act 1976). This includes the identification of indicator species. Indicator species can include: 1) threatened or endangered species, 2) species commonly hunted, fished, or trapped (of social or economic value), 3) species with specific habitat needs, or 4) species believed to indicated effects of management activities on the collective species of a biological community or on water quality. Species in the third and fourth categories serve as an "early warning system" of habitat changes because they are among the first species to respond to changes in habitat or because they respond to the smallest changes in habitat. We expect yellow-crowned parakeets or riflemen to act in this way in TWC forests.

    Choice of focal species

    The procedures, justification and assumptions used in selecting indicator species must be documented in the forest management plan. The forest plan must identify habitat components required by management indicators; determine goals and objectives for management of indicator populations; and specify standards, guidelines, and prescriptions needed to meet management objectives. Monitoring must also be conducted to determine whether guidelines and management prescriptions for indicator species are being met and are effective in achieving the desired results. The implicit assumption in the use of indicator species is that they provide a reliable assessment of habitat quality, and that if the habitat is maintained for the indicator, conditions will be suitable for other species. In the present proposal we seek practical species to monitor a key habitat variable (tree hole availability) that is difficult to measure directly.

    Conceptually, we would expect species with narrower habitat ranges to be more sensitive to habitat changes and therefore to make better indicator species. However, these species would then be less likely to be representative of other species in the community. This emphasises the need to have clearly defined objectives for the conditions and/or health of the community you wish the indicator species to represent. The use of indicator species must be justified by research that demonstrate that the indicator species exhibits a measurable response to habitat change and that it is representative of other species in the community. The degree of change that represents cause for concern must also be decided upon.

    To improve the effectiveness and credibility of indicator species assessment criteria need to be clearly stated and indicator species chosen by explicitly defined criteria. The biology of the indicator species must be known in detail and sources of subjectivity when selecting, monitoring, and interpreting indicator species identified. Methods of data collection, statistical analysis, interpretations and recommendations should be submitted for peer review and research and monitoring should allow for the natural variability in population attributes. In addition, selection criteria should not be confounded, the number of indicator species used should be manageable, species should be common enough to allow adequate sampling, and indicators from one region should not necessarily be considered appropriate for another region..


    Monitoring is usually designed with two broadly different objectives.

    (i) Management indicators: Plant and animal species, communities, or special habitats selected for emphasis in planning and which are monitored during forest plan implementation in order to assess the effects of management activities on their populations and populations of other species with similar habitat needs which they represent. Management indicators representing the overall objectives for fish, wildlife and plants may include species, groups of species with similar habitat relationships, or habitats that are of high concern. Selection of management indicators must consider all sensitive species in the plan, those species in demand for recreational, commercial, or subsistence use.

    (ii) Ecological Indicators: Plant or animal species, communities, or special habitats with narrow range of ecological tolerance. Such indicators are selected for emphasis and monitored during forest plan implementation because their presence and relative abundance serve as a barometer of ecological conditions within a management unit. Ecological indicators must be selected only if scientific evidence exists confirming that measurable changes in these species of groups would indicate trends in the abundance of other species or conditions of biological communities they are selected to represent.

    The term "focal" includes several existing categories of species used to assess ecological integrity:

    1) Indicator species: species selected because their status is believed to (1) be indicative of the status of a larger functional group of species, (2) be reflective of the status of a key habitat type; or (3) act as an early warning of an anticipated stress to ecological integrity. The presence of fish in a river is an indicator of water quality.

    2) Keystone species: species whose effects on one or more critical ecological processes or on biological diversity are much greater than would be predicted from their abundance or biomass (e.g., the red-cockaded woodpecker creates cavities in living trees that provide shelter for 23 other species). The honeydew scale insect is one potential Keystone species in TWC forests and abundance of introduced predators another.

    3) Ecological engineers: species who, by altering the habitat to their own needs, modify the availability of energy (food, water, or sunlight) and affect the fates and opportunities of other species (e.g., the beaver in USA systems. There is no obvious ecological equivalent in West Coast beech forests).

    4) Umbrella species: species who, because of their large area requirements or use of multiple habitats encompass the habitat requirements of many other species (e.g., deer).

    5) Link species: species that play critical roles in the transfer of matter and energy across trophic levels or provide a critical link for energy transfer in complex food webs. For example, prairie dogs in USA grassland ecosystems efficiently convert primary plant productivity into animal biomass. Prairie dog biomass, in turn, supports a diverse predator community. Litter invertebrates are potential equivalents in West Coast beech forests. Introduced wasps prey heavily on these species.

    6) Species of concern: species that may not satisfy the requirement of providing information to the larger ecosystem but because of public interest will also be monitored and assessed for viability. Such species include some threatened and endangered species, game species, sensitive species, and those that are vulnerable because they are rare. Kaka, parakeets, western weka and kereru are prime potential candidates in West Coast beech forests.

    An emphasis on focal species, including their functional importance or their role in the conservation of other species, combines aspects of single species and ecosystem management. It also leads to considering species directly, in recognition that focusing only on composition, structure, and processes may miss some components of biological diversity.

    Potential problems with the focal species approach

    Examples of indictor species used in the United States include northern goshawks, American marten, elk, pileated woodpeckers and groups of cavity nesters. The concept of indicator species in the United States helped to establish management guidelines for these and other indicator species but monitoring programs were seldom implemented. It was often considered more effective to monitor the particular habitats of concern than to monitor the indicator species (USDA 1999). However, even then, the Forest Service has been criticised for not succeeding in the correct development, implementation, and monitoring of comparatively simple prescriptions that include provisions for large trees and snags. Other problems have included inadequate description of associated habitat characteristics, selection of species that are too rare to be monitored or for which special monitoring techniques are necessary to assess their presence and trends, the absence of precise definitions or monitoring procedures, confounded criteria used to select species, discordance with ecological literature and a narrow focus only one aspect of a species life history when determining habitat associations.

    Woodpeckers are often used as indicator species in North American forests because it is assumed that since they are primary cavity nesters, maintaining woodpecker populations at viable levels, will also maintain secondary cavity-nesting populations at viable levels. Methodology for sampling snags and large trees on a landscape have been developed to enable compliance and effectiveness monitoring for wildlife in relation to the habitat standards and guidelines on national Forests. Snag retention programs on National forests have been hampered by problems with safety, funds, and inconsistent standards and guidelines. Consequently, condition, density, and size of snags on national forests often fail to meet the snag and woodpecker guidelines outlined in forest plans.

    The need for a wider planning context for monitoring: do not rely just on focal species

    In the Northwest Forest Plan selection of prospective indicators for the status of species or ecosystems is based on the development of conceptual models relating resource change to reliable, early warning signals of change. Changes in population status of species are monitored through significant changes in habitat at several spatial scales. This, of course, assumes habitat to be a reliable surrogate for direct population measures.

    Three types of monitoring are used by the National Forest Service: implementation, effectiveness, and validation. Implementation, or compliance, monitoring determines whether a National Forest complies with the objectives, standards and guidelines outlined in their forest plans. For example, were a minimum of 2.2 snags per ha. left in a stand after harvest? Effectiveness monitoring refers to periodically collecting the necessary data to determine whether management actions are producing the desired effect. For example, are woodpeckers present at 40 percent of their potential maximum population level when 2.2 snags per ha. are left? Validation monitoring collects information to support, or refute, the assumptions of the guidelines and objectives stated in the Forest Plan for a particular species. For example, does woodpecker abundance respond in a positive, linear fashion to increasing snag densities? All these wider planning context and monitoring are in place in the TWC proposal, so the simple reliance on indicator or focal species is not a risk in the manner happening overseas.

    Research needed to mount a focal species approach to guide TWC adaptive management

    Available knowledge of species' ecologies and their functional roles in ecological systems is so limited that it is not always possible, a priori, to unambiguously identify focal species. Therefore, the selection of focal species, based on existing information and the criteria for inclusion, should be treated as a hypothesis rather than a fact. Given this uncertainty, the assumption that a specific species serves a focal role must be validated by monitoring and research. It will be important to mount an intensive research project on the yellow-crowned parakeets and other potential species themselves if they are to be used as a focal species to monitor logging impacts in TWC forests. One would need to radio-track them to determine which areas they roam over so that ecologically sensible and statistically independent populations are identified as independent monitoring units.

    Development of reliable monitoring methods is fundamentally important to the success of the approach. Yellow-crowned parakeets although relatively abundant and conspicuous to predators nevertheless are hard to count within the forest ecosystem. During the breeding season females spend most of their time within their nest hole and are therefore can be absent from bird counts. At other times males and female spend much of their time in the upper canopy and not easily seen. It can also be difficult to estimate numbers from calls alone as yellow-crowned parakeets will group together. The normal methods of counting birds such as the 5-minute bird counts and line transect counting are affected by changes in yellow-crowned parakeet consciousness . Therefore detecting temporal changes in density requires a system that will equalise these highs and lows of conspicuousness. One possibility is to count birds only when they are not breeding. This method would allow you to count the most conspicuous birds during the least conspicuous time and statistical variances would potentially be reduced. Underestimates of yellow-crowned parakeet abundance could occur as birds will be hidden within the upper canopy and distinguishing between one bird's call and a group of birds calling from the same location will be difficult. A relative population index is therefore required rather than an absolute counting method.

    Using both a five minute bird count, where yellow-crowned parakeets are "called" down using taped yellow-crowned parakeet calls in conjunction with a transect line count would remove bias caused by inconspicuousness and group numbers. It is known that both male and female yellow-crowned parakeets will respond to these calls and it is unlikely that they will habituate to the "artificial" calls if there is no negative reinforcing stimulus, such as netting and/or banding . Taped call counts could be taken in areas that were audibly isolated from each other, therefore, reducing the risk of calling in the same birds. Transect line counts allow the counter to cover large parts of the forest and with yellow-crowned parakeets and kaka the ability to count them as you walk, if necessary. These methods could be used successfully during the breeding season, but before and/or after females move into their nest sites. If used pre-breeding season these counts will give an estimate of the adult population, which can be compared with different years. Post-breeding counting will also give an estimate of the number of juveniles fledged as well as the surviving adult population.

    Selection of the monitoring method and protocol details to monitor abundance will depend on: