IN THE MATTER of the Resource Management Act 1991
IN THE MATTER of the hearing of applications by Timberlands West Coast Limited to Buller and Tasman District Councils for land use consents for sustainable beech forest management (including harvesting and associated activities)
EVIDENCE OF C.R.Richards
ON BEHALF OF THE APPLICANT
(Sustainable beech forest management)
This submission covers the evidence to presented by the applicant (Timberlands West Coast Ltd) in support of its application to sustainably manage beech forests for timber production purposes described in the resource consent application RC 99/75 the lands of which are described in volumes 1and 2 of the application and "Assessment of Effects".
The forest areas relevant to this application are beech and mixed beech podocarp (rimu) forests that were set aside for "the commercial production of native timber species in perpetuity", a contractual undertaking between the Crown, and other parties.
Timberlands as agent for the Crown, has through a "Deed of Appointment" signed with the Crown, the exclusive contractual rights to manage the relevant forests to meet the objective of sustainable management described above.
This evidence will proceed in two defined segments;
Timberlands West Coast has used the expertise of a significant range of scientists and others to generate the management systems for which the consent to operate is sought. Their reports and conclusions are referred to in the management plans supporting this application.
In the presentation of evidence for the purposes of this consent hearing and in the interests of brevity and focus, this scientific information will be summarised by a small specialist group who will focus on the key issues that will benefit from greater explanation (not all will present their information in person). However there is no need to repeat the material already available in the Assessment of Environmental Effects.
Timberlands General Manager Planning will handle much of the presentation. Specialist assistance will be used for particular subjects.
Presenting evidence on behalf of Timberlands West Coast is:
Specialist Field of Evidence
Mr Phillip Miln
Mr Peter Glasson
General commercial and conservation forest management.
Indigenous silviculture, management and modelling.
Dr J Vanclay
Forest growth modelling, mixed species tropical & temperate forest silviculture & management, international perspectives.
Dr R Allen
Beech forest ecology & dynamics. Forest types.
Dr P Clinton Forest Research
Mr D Franklin
Forest Ecology past protection surveys.
Mr R Buckingham
Fauna surveys and distributions.
Dr Richard Allibone
Dr Henrick Moller
Fauna ecology and risks.
Mr Allan Rachkam
Mr B Watson
Recreation and amenity values.
Evidence of Mr Kit Richards
General Manager Planning
On behalf of
Timberlands West Coast.
I am a professionally trained Forester with 16 years practising experience in both exotic plantation management, indigenous forest management (including non-commercial environmental aspects). I am Qualified with a New Zealand Certificate in Forestry and a Bachelor of Forestry Science (Hons class 11). My academic and practical experience has covered economic, forest management and ecological disciplines.
I was one of the negotiators of the West Coast Accord representing the Forest Grower. I have been responsible for the co-ordination and development of successful sustainable management systems currently in operation in rimu forests in south Westland and in the research and development that has led to this application for the management of beech forests. I have authored much of the documentation represented by this application.
My role in Timberlands has been to manage the strategic direction and development of the Company after having been on the initial establishment staff during its formation in 1990.
My evidence will provide a framework overview of the elements of the management system into which will dovetail the more explicit and detailed expert evidence required for key issues. The evidence will broadly cover the nature of the proposed management then deal sequentially with the means by which protection, avoidance, remediation, and mitigation as required under the Act are achieved.
Evidence Part 1
The beech management proposals will shortly be required by law to meet the requirements of the Forests Amendment Act 1993.
The Buller District Plan requires that for the purposes of an "restricted discretionary consent application" under it's forestry rules, an activity must be certified in writing by the Director General of Forestry to be compatible with the requirements of the Forests Act as amended.
Timberlands is in receipt of such a certification.
The beech management proposals must meet the requirements of the Resource Management Act 1991.
The management system has been specifically designed around holistic approach to sustainability as written in section 5 of the Act and around the specific requirements of Section 6. Appropriate regard has also been had to sections 7 and 8.
Traditional forestry even that classed as sustainable in production terms, has while meeting societies economic goals, often failed to meet the demands required of if for longûterm ecological sustainability, especially the protection of biodiversity.
In the past, the overriding pressures of harvest economics and the use of heavy log extraction machinery has pressured undesirable harvesting intensities that in turn tended to lead to;
The approach taken by Timberlands West Coast has been to adopt a management process adapted to flow with the prevailing ecological processes in the forest rather than to control them to achieve higher productivity or other socio-economic goals. Critical features of the system are;
The following section serves to briefly outline the operation of the management process. This is described in more detail in Sections 3 & 4 of the "Assessment of Effects" and in the supporting management planning documents. The process is outlined in terms of all the key steps taken to construct a viable management system.
The first critical step to create a management system is an understanding of the ecology of these forests. In this respect, information on forest replacement strategies, gap formation, processes, scale and intensity, determinants of species composition, causes of mortality and damage and functionality of forest structure e.g. the role of rotting or hollow trees for birds, must be understood. Most of this detail is described in the supporting "Overview Plan For The Sustainable Management Of Beech", Sections 2 through to 4.4.
In this respect, a long New Zealand background of research into the beeches plus the utilisation of the most recent research into gap formation and replacement strategies in Maruia forest has provided a very good basis for designing an ecologically based management system. Ongoing research into rimu replacement strategies in mixed beech/rimu forests has also provided and will in future provide further insights into the dependency of this species upon occasional large scale catastrophe for successful periodic regeneration.
Similarly there has been much research in New Zealand on the effects of intensive harvesting systems on certain avifauna and on their preferences for foraging and nesting.
Numerous, scientific reviews have also been commissioned covering matters of, soil and water risks, invertebrates, pinhole borers etc. The full listing of reports and scientific material utilised is listed in the bibliography of the "Overview Plan for the Sustainable Management of Beech" and has provided the ecological framework for the management system.
To properly plan an ecologically based system, a comprehensive inventory of the forest is undertaken.
Surveys conducted aimed to:
With the above information it was then possible to start planning for management. In order to provide management with a tool to assist with the management of yield, a forecasting model was developed based on the information available.
The background and details to the model and its assumptions and use are covered in detail by Mr I.L. James. In summary however, this forecasting tool was designed;
To manage the forest and data available to achieve an end result, objectives must be defined. The objectives are described in more detail in section 1.5 of the "Assessment of Effects" in terms of the broad ecological, economic and social matters. These are refined in forestry terms in Section 6.2.2 of the document.
In lay terms, the primary management objectives sought to be able to economically produce a timber product from forests in a way that also took account of the recognised ecological values of these forests as habitat and already functioning ecosystems. Achieving this objective was seen to be best met by maintaining a forest structural and species composition very close to that currently existing. This could be undertaken by regulating the yield in terms of intensity, scale and spatial and temporal separation, setting low levels of harvest and using low impact methods of harvest. The potential for biodiversity enhancement also exists as a function of active pest and predator control.
Harvest yield is established through the process of utilising information from forest inventory and modelling it through the forecasting tool to achieve the desired management objectives over consecutive fifteen-year periods. The detail of the process is covered in the evidence of I.L.James.
The yield was set conservatively in the knowledge that under an extensive, low intensity system such as that proposed, recovery of all the available yield would be very difficult. This is because a significant proportion of the theoretically available yield would in practice occur as individual trees that would not be found or whose mortality could not be predicted. For these reasons the sustainable yield that could be uplifted was set at 50% of the theoretical sustainable yield. This is considered to be a very conservative approach.
The end result of this process was to establish a sustainable yield of about 46,000 trees arising from 48,000 productive hectares. This yield includes all non-productive commercial trees and logs and equates to less than one tree per hectare per year on average. The commercial yield that arises from the sustainable yield will be about 65,000m3 of merchantable logs.
The felling cycle is the length of time allowed to pass between harvesting events on a given area.
The shorter the felling cycle the lower the levels of harvest each operational event but the more frequent the return and the larger the area affected by each operational cycle. The scale is larger but the intensity is less. Longer felling cycles involve the reverse until the felling cycle equates to the growth period for a species and the management system resembles plantation clearfelling.
The felling cycle selected for the beech "Old-Growth" forest results from information on ecological processes, inventory and modelling. In simple terms, data showed that there were currently on average about eight dying trees per hectare. A proportion of these (about 60%) initiate mortality gaps in the existing forest that eventually involve a number of surrounding trees healthy and dying trees. Gap size frequency distributions for some forests were available from research and dead tree frequencies could be indicated from permanent sampling plots.
From this process it was possible to establish a means of harvesting the permissible yield that would have a scale and intensity of gap formation, similar to that which commonly existed under current natural processes. The return period also took into consideration the need to have harvest events well spread out to avoid any risk of elevating natural pinhole borer populations.
The end result of this process is that at full production in any one year, yield will be removed from around one fifteenth of a productive forest area. Removals will be in small groups of trees (up to about 10), from small gaps in the forest of up to 0.05ha except when clearing naturally induced windthrows. Within the current fifteenth of the area, there will be around four such harvested gaps per hectare, with no further returns to the same fifteenth of the forest area for 15years. If the full yield is not uplifted in any year from any particular fifteenth area of the forest returns may be made until the balance of the yield has been taken. Such uplifts however are inclusive of the total sustainable yield in any one year, not additional to it. Returns may also be made to salvage windthrow as this always takes precedence over live yield were it is located.
Occasionally research may indicate a shorter cutting cycle is better for ecological reasons. It is envisaged that such a shortening be permitted provided that he intensity of harvest is adjusted to preserve the 50% of increment sustainable yield threshold. (Noting that the greater the frequency (shorter the period) of the cutting cycle, the lower the intensity of harvest per cycle.)
Tree selection in the field is one of the most important components of the management process.
A range of criteria is used by a professional forester to make the choices as to what should and should not be felled.
The criteria are driven at the broad level by the results of the model used to provide forecasts for a given association of forests. This provides the markers who select and mark the trees for felling ahead of the felling operation, with a guide as to the number and species by size of trees that may be taken to meet yield targets. In the field that marker incorporates this guide into a range of other decision factors and guiding principles to ensure impacts are mitigated and sustainability assured. These factors include :-
Following marking, felling crews operate in the forest preparing the marked trees. Every tree is tagged with a unique number that has been entered onto a tree register by the marker for audit purposes. Fellers have no discretion on felling other than for purposes of safety. Trees are felled to create the least possible damage to existing trees and advance growth poles and saplings. Generally, felling can be achieved with less associated damage than that due to the natural non-selective fall of trees. Where damage is incurred, the damaged tree is assessed according to severity criteria. Trees assessed as likely to die from the damage just received are also felled and included within the yield with compensatory reductions elsewhere.
After felling, the trees are cut to merchantable sections to comprise a payload for the helicopter, and the audit tags transferred to the stump for long-term record. Records are kept of all logs removed, their species, and quality, all trees felled in total, the gap number, its GPS reference and size and its compartment. Non- commercial wood is retained on site to provide elevated nutrient and moisture rich seedling regeneration sites, habitat for invertebrates and return of nutrient / carbon to soils. To prevent risk of elevating pinhole beetle populations, non-commercial wood is cut into small pieces in accordance with criteria related to piece size to promote drying and treated along with stumps with small quantities of urea. Forest floor leaf litter is also placed on stumps to accelerate invasion of stumps with fungi that compete with the yeast's critical to successful pinhole breeding.
The workers also record regeneration levels and where considered inhibited by undergrowth will scrape clear small 1m square soil patches to ensure seedbeds are present. Any small waterways are cleared of debris deposited by felling.
In preparing any given compartment for extraction, a felling crew will operate for approximately one month before the lifting operation. The only chemicals utilised on site are the fuel and oil for chainsaws and urea for placement on stumps.
After preparation of logs in the field, all commercial material is removed from the site by Helicopter. The machine will operate up to two kilometres from a log landing point where the logs are gathered. The total yield from any given compartment will be lifted in between one and two operating days.
Logs are lifted using a grapple to minimise all human safety risk while logs are removed carefully and vertically from the gaps to prevent any further significant damage to the remaining forest. All logs brought in are reconciled against the markers and fellers registers by matching tags. There is no soil disturbance during the process of harvesting.
During the log lifting operation, truck-based fuel tankers are present at prepared landings for the duration of the operation. Noise levels from the operation have been assessed as within the permitted rural daytime levels to a range very close to the helicopter. This fact will mean that neighbouring property will not be significantly adversely affected and such affects as occur will be very widely dispersed in space and time and occur only for short periods of time.
Log removal from log-landings will be normally by standard road-based log trucks. Log transport will normally occur continuously during daylight hours for a period of 7-10 days after the aerial lifting ceases.
This type of operation can be contrasted with the norm for the past whereby heavy machinery would be present in any given area for long periods and truck activity would be continuous though obviously at lesser intensity.
The only infrastructural requirements to service the project are roads. Because most forest areas have a history of past harvesting over 87% of the required total road network is already in existence, though some will need upgrading. Of the new roads required, more than 23% represents the access required to reach forest boundaries rather than new internal access. Most main highway or county road access will be gained from existing forest access points. Overall the required road density is at least around one twentieth or less than that required by conventional harvesting techniques.
At maximum production the extent of additional heavy traffic will amount to just 9-10 trucks per day dispersed on the highway system.
Extra internal forest roading will be constructed in general conformity to the routes displayed on the associated maps (volume 2) and the controls listed in Section 4.5 of the "Assessment of Effects". These controls are specifically designed to address risk areas associated with sediment yield and erosion into rivers. Other protocols address issues of stream crossings that could prevent fish passage, and weed colonisation of road edges
From time to time, specific road consent applications may be required where the framework of guidelines cannot be met due to specific local conditions or requirements. E.g. a road may pass close to steep slopes for a short distance and require a specific consent to provide for steeper batters or grades over that particular distance.
The monitoring systems proposed are described in more detail in both the supporting "Overview Plan for the Sustainable Management of Beech" Section 6.4 and "Assessment of Effects" Section 9. Essentially however the systems are built around the following philosophies.
Monitoring systems are of little use unless they provide a basis for feedback to management. The implementation of an extensive adaptive management program such as this utilises a framework of audits to formalise the feedback loop and also to provide wider public transparency over the management of these public lands.
The proposal allows for a number of levels of audit. These processes are all builtûin components of the ISO14001 Environmental Management program for which Timberlands is an accredited party. Audits range from six-monthly field checks conducted by the Ministry of Forestry and surveillance audits for the ISO program to more complete five-year audits specified in the Beech planning documents (Section 1.4). The five-yearly audits provide for a more comprehensive review and represent the earliest period over which any useful data can be expected to begin to show what is (or is not) working and allow for the time for any subsequent management adjustments to work through before the next review.
The ISO results are available to the public, while the Forest Act audits are provided to the shareholding ministers. Both forms of reporting could be utilised by Council to provide the basis for monitoring elements of the program in lieu of additional and duplicated monitoring regimes.
The Councils also have enforcement and review powers available.
Timberlands have also indicated in the "Assessment of Effects" how the monitoring system could be further improved subject to the approval of the Crown.
Although not an area over which the Buller Council has reserved discretion, there are some fundamental socio-economic issues that are worth brief coverage.
Like any ecosystem, economies are also stronger if they are diverse. The West Coast economy is a rural based economy of which tourism, farming, mining and forestry are the top four. Agriculture is increasingly undiversified relying on dairying as the prime mainstay, tourism despite increasing numbers and value is nevertheless based around a limited number of themes. This concentration is evidenced by the steady rundown of assets across the conservation estate with effort and investment concentrated in the areas where visitor numbers are sufficient. There is no evidence that the low intensity operation proposed by Timberlands West Coast will in any way reduce tourism or tourist opportunities. Nor does it follow that leaving the forest untouched will contribute to any significant tourism growth.
Mining is clearly faced with commodity trading difficulties while radiata plantation forestry faces increasing challenge to remain competitive as the available resource doubles and marketing efforts fail to break radiata wood from its low-grade image.
Indigenous forest provide one opportunity to increase diversity in the sector providing a high value niche product produced "organically" in a de-intensified, non-plantation system requiring minimum fertiliser and pesticide use. The species are adapted to the climate and poor soils of the region and the markets follow different cycles to the international commodity wood markets. This industry could provide for a 140% increase in jobs over the base provided by the radiata industry, in markets that are separate from the basic international softwood commodity cycles, and in products that are relatively unique. Furthermore, an indigenous timber industry has the capacity to underpin further high value product manufacture that wont eventuate with radiata on its own.
The value of native timbers is more that 4 times the average value of plantation radiata in log form and the gap increases with processing. Most importantly in terms of returns averaged out per hectare, indigenous forest products processes to the basic dried and sawn / machined stage is worth more than six times the value of Tourism on a similar basis.
Despite continued recent publicity over native logging, there is no decline in either the demand for or price of rimu. Repeated benchmarking surveys have shown that on average around 85% of respondents want rimu, they want it above all other major competitors from overseas and they want future generations to have access to the timber. An increasing majority wants to be sure it comes form a sustainable source. The primary driver of this demand, despite high price is the cultural association with rimu as a highly valued decorative timber.
In terms of Maori values, totara and other species have significant cultural values. It is almost impossible to gain access to small quantities required by Tangata Whenua from time to time other than through the West Coast Crown estate. It is significant that apart from matters of detail, there is no opposition to the proposal from Maori interests.
Processing of high value timbers is inevitably relatively labour intensive. Existing efficient operations employ nearly 100 people per 30,000m3. This gives a ratio of 300m3per person employed to the semi-processed stage and compares with a ratio of about 560m3 per person for radiata.
In economic terms, the indigenous industry has very high multipliers through the furniture industry. Current figures suggest that the furniture industry dependent on indigenous timbers generates over $70 M in exports per year and employs partly or in full, several thousand people. These down-stream benefits that in part may ultimately accrue to the West Coast if the industry develops, have not been relied upon in the projections for 200additional jobs and $30M per year used as the direct socio-economic benefits to the West Coast. It should be noted also that Timberlands West Coast does not envisage log exports as a viable basis for the beech industry and no such proposals have been considered.
It has been often claimed that tourism will be adversely affected by this proposal. Timberlands permit and concession data establishes, as has the Recreational and Tourism Plan, that there is little significant recreation and even less so tourism in these forests. Many of the areas are relatively inaccessible and or offer few qualities better than that available and managed for the purpose in the Conservation estate. The important role these forests provide is the impression of an integrated, large-scale relatively unspoiled natural landscape. This function will not be altered by the proposals in this application.
Conversely, the harvesting operations of Timberlands West Coast have in their own right attracted hundreds of visitors to the Coast each year, (many of them international). Improved access to the forests may well enhance recreational and tourism opportunities albeit for a slightly different spectrum of the recreating public who are not as well catered for in the Conservation estate.
Ultimately, the economic efficiency of the native timber industry means that the total value of the tourism industry to the West Coast could be generated from just 24% of the land area under sustainable timber production compared with 79% under conservation management if simplistic averages were to apply as they are often used by critics.
In reality, given the low impacts there are overall unlikely to be detractions from the overall tourism options and income on the west coast and an overall enhancement of the total economic benefits.
While the Buller Council has not reserved its discretion on this matter, there has been much criticism that the nature of this proposal represents a breach of New Zealand's global responsibilities and treaties.
Most commentators are clearly poorly informed about the nature of these obligations.
For instance Agenda 21 arising from the Rio Conference contains chapters highly relevant to the Current situation.
Chapter 10 Managing Land Sustainably includes amongst other thingsààà..
"Governments should take into account environmental, social, population and economic issues, then develop laws, regulation and economic incentives to encourage sustainable use and management of land resources".
Policies developed should among other thingsà."take into account the land resource base, population changes and the interests of local people"à. "Use techniques such as landscape ecological planning that focus on an ecosystem or a watershed, and encourage sustainable livelihoods".
Chapter 5 Referring to the Convention on Biological Diversity requires of signatory nations that among other thingsàà..They " develop national strategies, plans or programmes for the conservation and sustainable use of biological diversity"
These proposals do not contravene any of the requirements of these agreements and in fact are in complete alignment with the thrust of these statements.
The New Zealand biodiversity strategy has also often been quoted as a justification for these proposals not proceeding. The strategy correctly identifies that habitat loss has in New Zealand's past been a major cause of the problem leading to the decline in many species. However, habitat loss per se does not explain the West Coast situation. If only habitat was the issue bird and bat populations would be dramatically higher and not under threat. The underlying problem remains pests and predators.
New Zealand's overall poor biodiversity record is a function of both pests and habitat loss. But habitat loss has been extreme in much of the rest of New Zealand. Attempting to preserve 2% of the nations indigenous forest will not significantly assist New Zealand's international performance base in the light of the other 98%, much of which is conservation land but nevertheless still suffering the effects of pests and underfunded management. Certainly preserving 100% of the West Coasts Ecosystems will do nothing to preserve or restore the lost ecosystems of other regions.
Evidence Pt 2
The purpose of the Resource Management Act and some of its key principles are relevant to this application. They are listed below and all relate in essence to testing the capacity of the proposed management regime to maintain ecosystem function to a level similar to that already in place.
In general terms, the ecosystems of the forests subject to this application are functioning in such a way as to be self-perpetuating into the very long term. These systems are not however static and are to the best of current knowledge in a state of dis-equilibrium. The influence of 100years of pest and predator invasion is revealed today in the continued decline of numerous known and unknown native species of both plants and animals. Without active management intervention to protect these species, some will decline to local or regional extinction within a generation. The presence of wasps in particular is a relatively recent invasion the adverse effects of which are only really beginning to be understood.
None of this means the forests will disappear, it does mean however that they will be in a state of change as the ecological structure moves toward a new equilibrium. It means that today's forests will not be the same as tomorrows, whether or not they are managed for timber. The potential long-term impacts of the possible current shift in climate trends and predicted major realignments along the alpine fault within the next 60 years all predicates a process of ongoing change in these forests.
In meeting the intent of the RMA, the aim of management is therefore not to prevent change but rather to ensure that (given other influences), all the key elements currently comprising the ecosystem are still there in the medium term at levels not too dissimilar to the present.
THE RELEVANT SECTIONS OF THE RMA
Section 5 : enabling communities to provide for their economic well being.
Section 5a: Sustaining the potential of natural resources to meet the needs of future generations
Section 5b: Safeguarding the life supporting capacityà.and ecosystems.
Section 5c:Avoiding, remedying, mitigating.
Section 6b: Protection of outstanding natural features and landscapes.
Section 6c: Protection of areas of significant vegetation and significant habitats.
Section 7c: Maintenanceà..Amenity values.
Section 7d: Intrinsic values of ecosystems.
Protection of soil and water is often a significant concern in relation to Timber management operations. In the preparation of this proposal a number of reports were commissioned. The assessments made were;
Soil & Water impacts (Landcare New Zealand Ltd)
Land stability (Dr C.O'loughlin)
Fisheries /riparian (Dr P Ryan)
These assessments considered that generally impacts on soil and water values and land stability would be extremely low. Fisheries too were unlikely to be adversely affected because of the exceptionally low intensity of the proposed style of management, provided basic riparian management protocols were followed and care taken with roading.
The safeguarding and protection of soil, water, and their ecosystems has been achieved through a number of mechanisms described briefly below. Mitigation is achieved through basic road construction protocols and riparian management.
The primary method for achieving protection has been;
Any physical undertaking can generate adverse effects. In this proposal these are managed through the following operational protocols;
Most agricultural and forestry activity depends on the application of nutrients to maintain productivity in the face of intensive crop removals. This normally leads to leaching of nutrient into streams and potentially the depletion of soil nutrient reserves. Through the very low rates of harvest, spatial and temporal separation of operations, retention of canopy cover and avoidance of all soil disturbances, nutrient leaching should be minimally altered. No fertilisers are used other than a few grams of Urea per hectare for pinhole control reasons. The undisturbed soil organic layers will hold any runoff.
In further measures to protect against nutrient drain, all non-merchantable material, especially the nutrient rich crown, is retained on site as coarse woody debris. This retains nutrients, promotes regeneration on the decomposing woody material and retains habitat for invertebrates and other decomposers essential for nutrient recycling and retention. Much less material is extracted from the system simply because of the focus on removal of quality material only.
There has been some criticism of what have been deemed to be inadequate provision for the protection of aquatic habitat of important fish species. These have arisen from a general view that small (< 1m) streams can be more important for breeding than larger streams and will be severely impacted by harvesting. Best practices from overseas have been quoted as evidence that substantially larger riparian margins should be provided for. Concern has also arisen in respect of wetlands.
Timberlands West Coast is in full agreement that small streams may be important for breeding habitat. However, it is our view that such submitters have lost sight of the near-natural spatial and temporal scale and intensity of this specific type of operation. By definition what is proposed is little different to what nature is doing now. The results to date with invertebrate studies are for instance a good indicator of the close-to-natural outcomes.
Larger reserves overseas predicate large-scale ground-based clear or partial-felling regimes with large proportions of canopy cover removal ground disturbance and high intensities of roading. No such situations occur here. The diffuse nature and scale of harvesting is such that small streams will regularly be subject to as much exposure and disturbance from natural sources as from harvesting. Further, natural windthrows and slips can regularly be seen to block and divert such streams, something that is not a permitted consequence of harvesting.
For all the above reasons only roading is considered a potential general threat. Therefore only culverting across small streams warrants most attention.
Wetlands are non-productive in forestry terms and as such are not at risk from forestry except from roads as above. Protocols recognise the value of wetlands as does the District Plan and such areas above critical thresholds are protected.
Timberlands West Coast is confident that where specific localised added protective measures could be identified by DoC, such specific designed protection can be accommodated if requested.
There are reliable empirical studies and demonstrations showing that fisheries and water and soil quality are not adversely impacted from significantly harsher operations than proposed in this application.
As a lesser risk matter, basic monitoring of soil quality and water quality is proposed in accordance with simple standard procedures. A simple catchment set will be monitored for aquafauna at one site in the Grey Valley and further simple monitoring undertaken in the Maruia to accommodate different chemistry and aquafauna. Only if the results of this indicate any cause for concern will studies be increased or coverage expanded.
Section 6c of the RMA requires that provision be made for the protection of areas of significant indigenous vegetation and significant habitats of indigenous fauna. Likewise Section 7d requires that managers "à have particular regard to the intrinsic values of ecosystems" and section 5 requires that "the life supporting capacity of ecosystems be safeguarded"
Timberlands approach to these requirements can be summarised as follows:
Some 78% of the West Coast region is protected under Conservation mandate and in the area of this application there is a 9:1 ratio of protected lands to nominally productive forest. Within the Conservation estates 830,000ha some 70% is in high status reserves ranging from national parks to ecological reserves.
Around 50% of all land below 600m asl is protected in the conservation estate. An analysis of major vegetation / landform types throughout the West Coast has shown that of 95 such types over 25 Ecological Districts, only 9 types fall below a point where less that 10% of the original pre-European forest cover is protected. None of those types are the subject of this proposal and of the 9 under-protected types 5 occur in North Westland. The average percent protection of the original pre1840 vegetation coverage is 61%.
In particular the ecological reserves and wildlife corridors form a specialist network of linked reserves carefully chosen to provide high level protection to fully representative distributions of species and landforms. This reserves network is then embedded within a contiguous, buffering matrix of Conservation and Crown Production Land.
The work undertaken in defining these reserves was a precursor to the Protected Natural Areas Surveys and developed the robust methodology adapted for later use around the country and the end result is that if there is any where in New Zealand that it is most appropriate to undertake the proposed type of management it is the Coast because of the risk buffering provided by the DoC estate and conversely the benefit flow-on to the DoC estate if fauna are actually enhanced.
The work of the Scientific Co-ordinating Committee lead to the designation of Ecological reserves that today comprise 181,000ha in North Westland or twice the size of the total indigenous production estate in the same area. As already described each of these reserves was defined according to principles that would ensure representative vegetation sequences and landforms were protected over areas viable in the long term within the total landscape defined by each ecological district.
It is these reserves embedded in a much larger (4:1 ratio) of other Conservation lands that provide the fundamental protection for all significant vegetation associations, ecotones and environmental vegetation gradients. The features of these reserves and their purpose have generally been written up in a range of reports and papers held by the Conservation Department.
The North Westland Reserves Network was the result of the Scientific Co-ordinating Committee. That committee made a comprehensive range of recommendations to establish a reserve network based on known surveyed data, bird ecology and island biogeographic theory.
Evidence on the role and outcomes from that committee's work has been prepared by Scientist D Franklin.
In the mid 1980's, the work of the Scientific Co-ordinating Committee was being incorporated by the then Forest Service into public Forest Management Plans. In the course of that process and under pressure to meet commercial and contractual wood supply imperatives, many adjustments were made to reduce the size of some reserves.
As controversy over clearfelling increased, key environmental NGO's (Forest & Bird, Maruia Society (now Ecologic Foundation), Federated Mountain Clubs and ECO), all combined forces with the Ecology Division of DSIR to lobby for further reservations. The united group formed under the name of the "Joint Campaign on Native Forests" and successfully gained political support for the review process that led to the "West Coast Forests Accord."
Among the outcomes of that process was the gazetting of all reserves sought by the joint Campaign which in turn reflected in full the recommendations of the Scientific Co-ordinating Committee. These past initiatives have now provided a safe platform to innovate and allow "safe use and conservation through sustainable use"
The effect of the established reserves network and the subsequent Accord process was to provide for a highly representative protected coverage of landforms, forests and habitats with the lands of least ecological value allocated to production.
Nevertheless the size of the allocated lands meant that the possibility existed that there may be areas of exceptional habitat or floristic value in the Timberlands West Coast estate. Such areas may not be well represented within the protected area network or may be required to ensure added safety in meeting the requirements of sections 5 & 6 of the RMA.
Surveys were therefore initiated to cover the Timberlands West Coast estate. The surveys were as follows;
This function has been achieved as described below.
In accordance with the protective hierarchy previously described the following strategies apply.
The purpose of the West Coast Accord negotiation process was to ensure that only lands of relatively low or unexceptional conservation value remained available for productive purposes. Nevertheless on the scale of the lands concerned it was plausible that specific vegetation associations may exist that were not recognised by the Scientific Co-ordinating committee. To cover this eventuality further data was collected and analysed by Landcare Research.
The results of this work are covered by Rob Allen û Scientist, Landcare Research Ltd.
Protection (from harm) is different from preservation. Best ecological practice has also recognised that significance in term of vegetation is not solely a matter of "outstanding" or "different", rather it is a matter of "ecological context". In this sense the large areas of native production forest and their relationship with adjacent conservation lands and agricultural land means they are at least not insignificant in terms of their scale of ecological functioning. To this end the management practices subject to this application have been designed to protect the basic vegetation replacement and maintenance processes to those within the frequently occurring natural ranges. By doing this the overall intrinsic functioning of the forest based ecosystems should be protected.
The production approach which has been adopted and applied to provide protection to all areas of forest (not just those that are significant) has been scientifically described from similar work undertaken in mixed species temperate forests in South Africa. Management is based on:
Irrespective of the preceding protections, individual tree and plant species are recognised as playing an important role or are threatened or locally or regionally rare. In some cases the species may be diffusely located in many areas of a forest (e.g. mistletoes) while in other cases a species may be abundant in a confines area.
Timberlands sought information from DoC on such species and have introduced measures to protect them. I most cases the exact whereabouts of such species is not known thus the measures are based on operating protocols. Apart from the use of the helicopter, which almost entirely eliminates risk to shrubs and small plants from ground disturbance, other measures include;
Monitoring for vegetation will be undertaken at a range of levels to achieve different functions.
Details are described more fully in the "Assessment of Effects" Section 9 and in the "Overview Plan for the Sustainable Management of Beech" .
Key components of the proposed strategy are:
The integration of the need of threatened species, regard to their intrinsic values and the provision for their protection is documented in the "Assessment of Effects" Section 6.3. The rationale for how the need for protection has been derived is covered extensively in the supporting document the ""Overview Plan for the Sustainable Management of Beech" Sections 3 & 4.
A similar protective hierarchy to that described for flora applies here. Its stages are as follows;
The advent of the RMA nevertheless requires that all habitats of threatened species are provided for and some such species do occur on the Timberlands estate. For this reason a series of surveys were undertaken.
Mr Rhys Buckingham covers the results of this work and the recommendations that led to the protection of further areas of forests or other protective mechanisms.
The management system has been designed to provide for the protection of habitats of terrestrial fauna through a variety of adaptations.
The effects and mitigatory strategies will be further covered by Dr Henrik Moller and Dr Richard Allibone. However, in summary the elements of the management system that achieve this are.
A number of protocols have been introduced to provide for the protection of individual species. These range from;
Monitoring is proposed to assist in determining the sustainable management of fauna and is outlined further in the "Assessment of Effects" Section 9 and the ""Overview Plan for the Sustainable Management of Beech".
Birds comprise a huge difficulty due to costs in achieving reliable data. Instead the primary means 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 one or two representative areas in a forest then subject to the same management elsewhere a similar trend should prevail. Adverse trends if they eventuate would need further investigation, however the primary assumption is based around the well-established rapid and positive response that arises for birds from effective pest control.
Fisheries will be monitored on the basis of a before & after check on a paired catchment. If no detectable problems are found Timberlands West Coast would not propose to extend the monitoring. If however concerns do arise, further monitoring or research would be needed.
Invertebrates will be covered under research projects aiming to establish whether detectable differences occur between harvested and non-harvested sites. If no specific concerns are
raised then such monitoring will be discontinued.
A system of platypus monitoring has been introduced to check for any significant increases in Pinhole attack of trees adjacent to felling sites. This will be maintained for a number of years over a variety of sites until it is clear as to the degree to which pinhole respond adversely if at all.
Key issues raised in submissions are further covered in Dr Henrik Mollers evidence.
Evidence of Rob Allen, Scientist Landcare Research Ltd
Section 6(b) requires that outstanding natural features and landscapes be protected from inappropriate development. This requirement has been achieved in the following way.
The general conclusion from the surveys was that there were few areas of high recreational and tourism value in the production estate. Such areas were already under the jurisdiction of the Conservation estate.
Landscape values are particularly relevant to the values required for recreation and tourism at a localised scale. There were few of such areas that were of a value above the norm for the forests or associated amenities in the Timberlands area. Specific small areas were nevertheless identified for added buffering and protection along public use access ways and rivers such as the Waitahu and Rough rivers.
At the larger regionally and nationally significant scale;
The effects of this proposal are considered largely self-explanatory. However since aerial photography will be undertaken over the same areas from time to time for other reasons, this mechanism will provide a basis for monitoring the Landscape effects of the proposal.
Some critics of the application have stated that the proposal will lead to a "patchwork" quilt effect that will destroy the visual characteristics of the forests. Such claims arise from a failure to recognise that generally a similar scale and density of gaps is already present or being generated in any one hectare on average. The only difference is that in some of the natural gaps, dead spars will remain diffusing the impression of an opening. Also the gaps are not clearfells, and understorey vegetation and small trees remain largely intact.
In reality, aerial photographs prove the difficulty of determining natural from unnatural gaps, many of which will close up after 5 years.
Section 7 c of the RMA requires that particular regard must be given to the maintenance and enhancement of amenity values. Section 7 also outlines obligations in respect of cultural values. These obligations have been covered in some detail in Sections 8.6 & 8.7 of the "Assessment of Effects". They are also detailed in the supporting documentation in respect of landscapes and recreation..
I order to establish and manage these values a number of information sources were used.
In the first instance as before, there have been a number of reserves resulting from the West Coast Accord. Timberlands West Coast sought information from DoC, consulted with Fish & Game, the Tourism Board, the Communities close to the forests and Ngai-Tahu. In addition, Timberlands West Coast commissioned a recreation and Tourism assessment and management plan. The outcomes of this assessment are contained in the written brief of B Watson, the consultant but as already discussed, generally confirmed that the important areas for recreation and tourism opportunities were well protected in the Conservation estate while the management system would not generally create adverse landscape effects.
Following the Accord, some 44,000ha of land was in place as scenic reserves in addition to the 342,000ha of national parks in the general Nth Westland Region. These reserves were in particular aimed at protecting outstanding amenity values and recreational opportunities.
In addition following the fauna surveys, the tourism and recreation plan work and other aerial surveys, a number of other areas were reserved from production to maintain and protect the "naturalness" of certain areas. The rationales are detailed within the respective reports that are available as supporting information, while maps in the "Assessment of Effects" show the locations of these amenity reserves.
Avoidance & Mitigation
The management system itself is designed to mitigate against adverse amenity effects. This is achieved through;
A series of policies and procedures have been developed in the Recreational Management Plan to enhance the public's ability to utilise the forests. Essentially these policies clarify to the public the range of rules and the opportunities for the safe use of these forests areas.
One issue raised by recreationalists has been the assumption that vast proportions of the forest will be closed to the public for long periods thus breaching the general tenor of the "open access" policy. In reality while warning signs are erected to warn of felling operations on small parts of the forest at any one time, this does not normally require closure of roads or common access. The only time these would be closed is during aerial lifting, a matter of a few days a year in any particular area.
To provide further assistance to the public Timberlands would propose to build a section on its web site where public notices can be posted providing universal access to minimise inconvenience to the recreating public.
Timberlands has as part of its ISO14001 and Environmental Management Program. I that is spelt out the processes for dealing with Historic and Archaeological sites in accordance with the Historic Places Act.
The company also maintains a database of all known registered sites on this land and these automatically appear on operational maps through the GIS mapping system. Supervisors are trained to include historic site issues in any pre-operational site environmental risk assessments.
Timberlands have also consulted with Ngai-Tahu and local Iwi, Te Runaka O Katiwaewae & Te Runaka O Makawhio. The later have provide written confirmation that they have no issue to resolve while the former are currently working through a set of protocols for the discovery of artefacts or human remains that they wish to have included within the planning process. This is the only source of their objection to the application. Timberlands has no difficulty with the requests in respect of these issues as they have been conveyed verbally to us.
These issues are covered in the evidence of Mr P Glasson of Glasson Potts Group Ltd