IN THE MATTER of the Resource Management Act 1991

AND

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)

Index

1. Introduction

   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.

   1. Layout of this Evidence.

      This evidence will proceed in two defined segments;

      1. In the first segment there will be a broad description of the concepts, rational and processes that underpin successful sustainable management as proposed. These concepts are related to section 5 of the Resource Management Act 1991.
         
      2. The second segment will deal with the relevant matters to which the Buller District Council has reserved its discretion.

   2. Presentation of Evidence.

      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.

      1. The specialist team

         Presenting evidence on behalf of Timberlands West Coast is:

Evidence of Mr Kit Richards

General Manager Planning

On behalf of

Timberlands West Coast.

1. Introduction

   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.

2. Scope of Evidence

   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.

3. Evidence Part 1

1. Primary Legislation

   1. The Forests Amendment Act 1993

      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.

   2. The Resource Management Act

      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.

2. How Sustainable Management of Beech Forests Works
   

   1. Concepts

      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;

      • inappropriate yield regulation and excessive canopy opening,
      • pressure for unsustainable yields,
      • excessive damage to regeneration, existing young trees, and
      • Damage to soils.
      These negative features have generally lead to a situation where a variety of options for silvicultural intervention have evolved to compensate and allow the forest to be steered in directions that achieved faster and more concentrated growth for economic objectives. While these techniques are effective in providing sustainable yields, the effects of the harvesting and silviculture normally lead to situation where the cumulative summation of natural mortality, harvest removals and harvest related mortality was greater than the average level of mortality in natural forest. As a result a new growth / mortality equilibrium was established in managed forests that was reflected in younger, structurally simpler lower density forests. ______________ In New Zealand and elsewhere, the holistic demands for environmental sustainability, (now embodied in the RMA) requires a significantly different approach to indigenous forest timber production.

      1. Ecologically Oriented Management Process

         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 adaptation of a yield regulation system tailored to the natural patterns and dynamics of the forest,
         • acceptance of the natural species composition to retain full options for the future,
         • an approach where sustainability is not dependent upon regeneration enhancement or growth enhancement practices,
         • Redirection of funds released from active silviculture to harvesting systems operating in harmony with ecosystem patterns (in this case aerial harvesting) and adding biodiversity value through predator control.
         Such an approach recognises that forests are not static clusters of trees. They are populations of trees, continuously subject to unstable cycles of growth and death and fluctuations in disturbance patterns and scale. Disturbance is natural!. Any increase or decrease in disturbance frequency of intensity will alter ecological systems, sometimes in ways that threaten biodiversity. This forest management system is intended to work with and accept the natural processes and changes. At a global level its major effect will be to superimpose a more regular pattern of disturbance along side a natural range of regular and irregular patterns of disturbance of both greater and lesser magnitude. The system is described in greater detail on section 4.2.3. The Role of Adaptive Management
         
         One of the most conceptually difficult matters for the public at large to understand is the management of long timeframe projects. In the absence of perfect information many argue that management should not proceed until all information is available.
         
         The reality is that full information is known about nothing humans do and in New Zealand today there are many everyday activities undertaken which are known to be completely unsustainable. In the case of this application, while every complexity and interaction of an ecosystem will never be known, the key drivers as they are understood have been recognised and incorporated within the planning framework. Equally, and especially in the New Zealand context, there are many unknowns and risks from a purely preservation approach as our ecosystems seek new equilibrium in the face of an array of pests, weeds and predators never originally present in the land. Change, some of it negative, is still guaranteed under a preservation regime and needs to be considered in the context of this application. This framework is a precautionary risk management process where operational procedures are designed around best practices, results monitored or targeted research undertaken, processes audited then adjustments fed back into the management actions. In addition the low-intervention system adopted for this project provides considerable flexibility to adjust and a high level of reversibility. ___________________

   2. The Management Process

      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.

      1. Ecological Research & Knowledge of Natural Processes:

         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.

      2. Forest Inventory:

         To properly plan an ecologically based system, a comprehensive inventory of the forest is undertaken.

         Surveys conducted aimed to:

         • Establish the nature and distribution of wildlife (Birds, Bats, Lizards) and potential threats and important locations.
         • Qualitatively define the nature of vegetation associations, their descriptive trends and location and establish any untoward variation not well represented in the estate.
         • Establish, the quantum, composition, structure and status (including dying trees) of the standing forest as well as growth rates and merchantability ratios.

      3. Shortûterm forecasting models.

         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 provide guidance to management as to the expected level of natural turnover (growth and death) prevalent in the forest at the present time,
           
         • The level of yield and its composition (sizes and species of trees) that could be harvested within the objectives sought by management.
           
         • Forecast the effects of the harvest on the forest structure and composition over the short-term.
           
         • Provide trees markers and field managers with a tool for providing a "guiding shopping list" of the numbers, species and sizes of trees that could be taken.
           
         • Provide a means of auditing and reconciling; forecast allowable harvests to be taken relative to those actually taken.
           
           Forests are dynamic populations of ecologically interacting trees. Over quite short periods of time and quite large scales, levels of natural mortality and growth alter significantly in response to disturbances and the structural status of the forest. It can therefore be seriously misleading to attempt long-term forest projections without the assistance of very sophisticated ecologically based models that at present are not yet available for New Zealand forests whether managed for conservation or production.
           
           For this reason, the tools developed were designed to give short-term projections only. The problems arising from undertaking a long-term activity using short-term projections could be overcome by using the model in iterative process whereby at the end of each projection period new inventory and actual measured growth, mortality and forest compositional data could be fed in. This would enable new projections to be made for the forthcoming period including adjustments to yield that might be required to ensure management objectives were met. By incorporating g the use of the model within prescribed review and measurement periods as part of a robust adaptive management strategy, safety margins are protected while more robust models are derived.
           
           
           Conceptually this is no different to driving a car or navigating a ship around the world whereby getting to the endpoint that may not even be visible is achieved by constant small corrections to available data along the way. The important point is to know what the objective is. In addition, the current application is not for long term harvesting. It is for a term of 35 years. The model is satisfactory for predicting the outcomes of this relatively short-term activity. While it is intended that productive management will continue beyond 35 years, that would require a further assessment and fresh consent applications. This provides a very robust opportunity for future generations to reassess their needs and priorities.
           

      4. Objectives of Management.

         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.
         
         

      5. Establishing Sustainable Yield

         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.

      6. Establishing the Felling Cycle.

         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.)
         

      7. Tree selection

         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 :-
         

         • Trees exhibiting signs of ill health, recently dead or in a condition likely to be a precursor to mortality are selected as "potential gap-makers".
           
         • Trees that may suffer physical damage from the wind throw of the gap-maker or are in close proximity diseased trees and may (are) suffer (ing) associated disease effects are selected in whatever condition they present to make up the group.
           
         • Site characteristics that might influence the success of regeneration, e.g. the dominant species composition, the structural characteristics of the forest on the immediate site are taken into account through the size of gap taken, trees retained, ground scarification required etc that all contribute to the goal of protecting forest structure.
           
         • Large trees above predefined diameter limits are retained because of their importance in harbouring holes important to birds and bats and provide abundant food.
           
         • Trees exhibiting the presence or evidence of hole nesting birds or host dependent mistletoe will be retained.
           
         • Markers and fellers will take careful consideration of the extent to which the direction of felled trees can be controlled to avoid unwanted damage to adjacent healthy growing trees in order to prevent increases in the total rates of mortality in the forest.
           
         • The density and distribution of gaps being made, which will be matched to similar natural conditions.
           
         The listing of criteria and guidelines used are provided in the supporting documentation of the "Overview Plan for the Sustainable Management of Beech".

      8. Field Practices

         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.

      9. Extraction.

         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.

      10. Services û Roads and Landings.

          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.

      11. Monitoring.

          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.

          • Timberlands must collect such long-term monitoring data (e.g. forest mortality) as is required to measure the status of the forest and develop appropriate management tools (e.g. growth models).
          • Timberlands is required as a minimum to "maintain" and "sustain" not "improve" and cannot be expected to perform what the Crown and wider society cannot and does not perform in respect to land management on other lands. This fact was recognised in the previous review of the beech plans by the Parliamentary Commissioner for the Environment.
          • Monitoring should focus on high-risk areas where changes may signal potential adverse effects. Not all things need to be monitored at all times and in particular if early testing reveals no grounds for concern (e.g. water quality/fisheries, pinhole borer) continuous monitoring is not anticipated.
          • It is not the role of Timberlands West Coast to undertake primary research to understand the intricate function of ecosystems. Timberlands responsibility is to be able to demonstrate that adverse outcomes do not eventuate. If they do appear to be eventuating, changed management or further research may be required.
          Monitoring systems proposed are designed to monitor changes to forest structure and composition, forest turnover, pest and predator densities, water quality and fisheries, soils quality, invertebrates, disease and pinhole, and landscape effects. Databases will also record incidents of mistletoe hosting, rare species sightings etc.
          
          Birds and bats will be monitored through a combination of monitoring key parameters (forest composition and predators /pests) and representative sites giving long-term trends.
          
          Research will be a continual process initially focussing on key areas where more refined knowledge is useful such as gap formation and dynamics in mixed beech rimu forests and refining criteria for predetermining mortality.

      12. Audit.

          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.

      13. Issues.

          • Yield Models;
            Aside from a Forest and Bird sponsored submission on growth modelling dealt with in detail in other evidence to be presented, there have been other attempts to portray Timberlands proposals through quasi-mathematical models. These attempts are based around the assumption that the tree removals represent clearfells with no advanced growth poles, trees and seedlings remaining in or around each gap. This is wrong. Simple multiplication of average gap areas, or numbers of trees removed, by felling cycles has lead to conclusions that the resource will be extinguished in about 150 years. These efforts are professionally inept and require little comment.
            
            In similarly simplistic terms it can be calculated that in the time taken for the original older trees to be felled the largest of the undersized trees (not felled) when harvesting first began will already have been about 150 years old. With a further 150 years they will subsequently have achieved an age of 300 years, about the age of most of the largest trees.
            
          • Forest Ecology;
            Some submissions have questioned TWCs apparent assumption that the forests are uniformly all aged when in fact they comprise a composite of multi-aged patches. They further question how regeneration will occur on smaller gaps.
            
            In the first instance, pooled data will produce all-aged stem distributions. However this does not prevent the tree marker selecting tree characteristics in accordance with the specific site characteristics. By constantly comparing trees selected against the allowable harvest distribution, the marker will overtime achieve the average.
            
            On the issue of regeneration; at present many of the gaps created will be small and may favour silver beech species. This is the trend at present in natural forest and management does not seek to alter this. It is recognised though that a proportion of gaps are larger and this proportion is replicated by management. More importantly a much higher frequency of larger gaps are created regularly by periodic larger scale disturbances and these will continue to occur from time to time irrespective of management. This pattern should serve to retain forest composition similar to that present today.
            
          • Audit;
            Some submitters have called for Council audits or reviews over times as short as 5 years. Timberlands does not believe this to be appropriate since the rate of change is too slow to allow measurable change. Audits as specified are done so to check operational procedures are in place not to try and review consent conditions. The earliest such matters as forest density, growth rate or mortality could begin to become apparent would be after the 10 year remeasurement. Much monitoring will also require numerous years to deliver any relevant result.

   3. Socio û Economic Matters.

      Although not an area over which the Buller Council has reserved discretion, there are some fundamental socio-economic issues that are worth brief coverage.

      1. The Importance of Economic Diversity.

         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.

      2. Value of Native Timber.

         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.
         

      3. The Cultural Value of Native Timber.

         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.

      4. Added Value.

         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.

      5. Conflicts with Tourism.

         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.

   4. Global Significance.

      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

3. The Resource management Act

   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.

   1. Soil & Water.

      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.
      

      1. Protection /Avoidance /Remediation / Mitigation

         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.

         1. Protection through the Management System.

            The primary method for achieving protection has been;
            

            • The adoption of a silvicultural system built around log removals at spatial and temporal scales (time and group spacing) and intensity (trees per group) aligned to natural disturbance patterns. By default these natural patterns are in process in these forests at all times and the removal of trees in similar fashion is not expected to alter the status quo. There are innumerable situations where natural gaps are larger and of significantly higher localised impact than those caused by the proposed harvest. Near closed canopies will avoid accelerated sediment loss, nutrient leaching and nutrient volatilisation.
              
            • The utilisation of helicopters for log extraction. Normal ground based harvesting creates soil disturbance, compaction, understorey damage and channelling along log haul lanes and in wheel / track ruts. The helicopter method completely removes these problems. There is no soil disturbance other than the feet of the harvest crew and understorey and mid-canopy vegetation is left largely intact. Experience in controlling impacts from conventional operations of an order of magnitude greater than that proposed here gives confidence to the lack of impact expected from these proposals.
              
            • The retention of coarse woody debris from all unmerchantable volume and crown material on the forest floor will mitigate against nutrient loss from the system and ensure important invertebrate decomposition processes are protected.
         2. Mitigation through Protocols.

            Any physical undertaking can generate adverse effects. In this proposal these are managed through the following operational protocols;
            

            • Harvesting is avoided on steep slopes in wet conditions where tree topple and subsequent slide down-slope can occur. This avoids downhill oriented soil disturbance or large areas of crushing. Safety considerations generally limit harvesting of such slopes in any case.
              
            • Tree harvesting is limited within streamside margins in accordance with predefined stream classification criteria. Any tree debris that accidentally reaches stream water bodies will be removed.
              
            • Similar criteria control the proximity of road construction close to streams and crossing points. In addition basic best practice guidelines and construction tolerance guidelines (e.g. max gradient, max batter height etc) are used to control the actual formation of the road.
              
            • The roads are wherever possible located on existing formations and located in valley bottoms. This configuration requires care to avoid adverse hydrological effects (e.g. when cutting across the path of small streams) in the affected valley but dramatically reduces risks of road failure and significant sediment yield or erosion. Due to aerial extraction, the total road density has been reduced to less than a twentieth of normal harvest systems and the total of new roading within the forest is only 13% of the final requirement.
              
            • To protect fish passage lowered culverts will be placed where appropriate on small side streams while open fords with temporary bridges will be used at time of harvest for small to medium sized streams.
              
         3. Protecting Organic and Nutrient Values.

            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.

         4. Issues.

            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.

         5. Monitoring.

            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.

   2. Protection of areas of significance and ecological values.

      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:

      • It is of the view that most areas of significance are already in the conservation estate.
      • In addition, Timberlands believes it has excluded other areas of significance from its proposal.
      • Timberlands does not accept the interpretations advanced by forest and bird, which is effectively that all indigenous forest is automatically significant or that such values as might contribute to significance cannot be protected under a production regime.
      • Timberlands does not believe that it is a requirements of the Buller District Plan for it to apply the criteria in the plan to identify areas of significance, that is a matter for the council. The council in undertaking that exercise needs to weigh all of the criteria. (meeting one criterion, e.g. size, will not usually be enough.) Until such areas are finalised in the plan, there will inevitably be room for debate as to which areas are significant. The criteria in this plan are of guidance but are certainly not determinative of that, no guidance is given as to how they should be weighted between themselves and indeed the appropriateness of the criteria is untested.
      • However, in my view this exercise of identification is not necessary for the current applications, because even if there are areas of significance remaining in the proposal they are adequately protected by the mitigation measures built into the scheme, (the Act does not require preservation).
      • These same measures have regard to the intrinsic value of the forests ecosystems and safeguard their life supporting capacity.
      The hierarchy is based upon four levels, namely;
      1. A comprehensive "designed" protective network established through the late 1970's and 80's. (The work of the scientific co-ordinating committee has already been described. Their work led to the designation of a suite of ecological reserves).
      2. Floristic compositional surveys were undertaken during inventory assessments to enable objective analysis of compositional associations within the forests.
      3. Elements of the management system were specifically designed to ensure the vegetation was protected.
      4. DoC was consulted in terms of specific knowledge of rare or threatened plants with distributions likely to occur within the areas subject to management.
      5. Species specific management protocols designed to protect or mitigate any adverse impacts.

      1. The West Coast Reserves Network.

         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.

         1. The Work of the Scientific Co-ordinating Committee.

            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.

         2. The Role of the Joint Campaign.

            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"

      2. Specific Surveys for flora, fauna and other attributes.

         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;

         • Floristic compositional surveys plus specific data from DoC databases.
         • Extensive bird and bat surveys of all major areas of this application.
         • Lizard surveys as above.
         • Other databases such as the NIWA fisheries database were also used.