140 Panorama Road
Christchurch 8008

14 January 2000

Hon. Sandra Lee,
Minister of Conservation,
Parliament Buildings,

Dear Ms Lee,

Labour's action in respect of Timberlands West Coast and sustainable beech production - conservation forestry.

I write this as a person with tertiary training and practiced expertise in forestry, as a New Zealand citizen who is concerned about current events.

In my opinion, Labour made a serious error in taking the steps it did to prevent the completion of the Resource Consent hearing being held under the provisions of the Resource Management Act (RMA), and is wrong in uncritically opposing the very carefully developed proposals of Timberlands West Coast Limited (TWC) in this regard.

My opinions are based on the following:-

1. Labour Party policy states that "Labour is committed to sustainable development in which economic, environmental and social considerations are not considered separately, but are melded into one".

Such sustainable development was the basis of the TWC proposal; to sustainably manage 100,000 hectares of the nation's 2.8 million hectares of beech forest for enhanced conservation of wildlife and plant values as well as careful timber production. The 100,000 hectares represents a mere 3.57% of New Zealand's beech forest.

Further, on the RMA, Labour Party policy states "Sustainable management of our unique natural and physical resources is vital to New Zealand's social, economic and environmental well-being. Labour strongly supports the Resource Management Act because it provides an integrated, participatory, and transparent approach to planning for sustainable management."

I agree that the RMA does these things. But Labour by its actions showed absolute lack of support of the RMA processes and the 'knee-jerk reaction' nature of the Labour's response with respect to Timberlands planning application seemed to show it did not care.

This response of Labour to the TWC management proposals is poor government, and a very disappointing first move. I thought that NZ was past that with Muldoon, Douglas and Prebble out of government, and Alan Gibbs out of forestry management..

2. The forest management computer simulation program (beechm.exe) created by Dr M. Efford of Landcare CRI, and upon which much reliance has been placed by opponents (including Mr Peter Hodgson) of the beech management proposals has significant flaws, resulting in misleading results when it is run to show what would happen if the beech forests were managed under the TWC proposed regime. The misleading nature is such that the management regime appears very damaging.

When the flaws in this program have been exposed by international and New Zealand experts in forest growth simulation (which Dr Efford is not), the exposure is often disbelieved or discounted. It seems to me that the detractors of TWC's proposals have simply not bothered to look into the matter.

3. It has been pointed out many times that to 'lock up' an indigenous forest, in the presence, as now, of introduced pests and predators - both animals and plants - does not provide the adequate protection that people applying the locks intend. To be safeguarded, indigenous forests need specific protection measures, and TWC proposed to apply such measures to those forests also providing a timber yield.

New Zealand is a signatory to the Montreal Process protocol, signed by many Pacific Rim and Oceanic countries.

Under this protocol, New Zealand is required to actively manage its indigenous forests to conserve biological diversity, maintain productive capacity, maintain forest ecosystems, conserve soil and water, maintain the contribution to the carbon cycle, maintain multiple socio-economic benefits and meet the needs of society, and maintain legal institutional and governmental frameworks for conservation and management. New Zealand is required to report on the action taken. It is somewhat ironic that the Department of Conservation (DOC) is prevented under the Conservation Act from actively managing the forest under its control to achieve several of these ends, and it is well known that it is severely under-funded for these and other tasks.

4. New Zealand is short in supply of tree species that can produce fine timbers with the qualities of our beech trees. Red and silver beech are well suited to interior joinery, panelling, and furniture, and are excellent for processes such as steam-bending, machining and turning. Our plantation conifers are inferior for these uses.

New Zealand uses significant volumes of high-quality indigenous timber from other countries, many of which do not or can not manage their indigenous forests sustainably.

It is significant that red and silver beech are two of the three indigenous tree species with most potential for responsible, economic forest management. The other is kauri.

It is hypocritical of New Zealand to turn its back on the innovative and example-setting process that TWC proposed to sustainably manage some of the beech forest for both conservation and timber production, and at the same time use the indigenous timbers from other countries that have been harvested in a non-renewable way. Further, through preventing NZ beech timber from entering this international product stream, the unsustainable forest felling in tropical countries will be hastened. It is very disappointing that Labour should commence its term of office in the new millennium with such a demonstration of hypocrisy.

5. In many of the public discussion papers and statements by opponents of the TWC sustainable management plan, the plan is referred to in terms solely of "beech logging proposals", "beech logging plan" and the like, giving prime emphasis to "logging". Those people using such terminology are doing so deliberately in order to conjure up mental images in the public, and I am sure also in the minds of many new members of Parliament who are simultaneously stressed and excited and without much time to carry out a considered examination of the facts, of vast tracts of wasted, flattened forest with exposed soil, and the like. This is misleading, and wrong.

In fact the proposals entail harvesting timber volume equalling merely one half of the natural mortality, using helicopters for log extraction, from minuscule canopy openings in such a way that forest regeneration is enhanced and forest structure and complexity retained. Further, the plans include provisions to monitor the forest reaction, (so that management can itself modify what it does), and provisions to protect the forest from a range of pests, and to enhance public use and enjoyment. There were commendable proposals to enhance the forests for indigenous wildlife. They were developed over a period of about 10 years by expert, honest and devoted scientists and foresters with the conservation of the forests as a prime objective. The RMA process was opening up these very matters for public scrutiny and expert comment.

In conclusion, may I recommend that you take some time to acquaint yourself with this matter, and recommend to your parliamentary colleagues that the TWC shareholding Ministers reverse the instruction they gave to the TWC Board, and that they have the RMA hearing re-started.

It is high time that some rational thinking was applied to this matter. Internationally, this new New Zealand government appears distinctly foolish because of the actions taken in this regard, but there is a little time to put things right. Labour should find some face-saving way to reverse the hot-headed actions taken in the first week or so after the election.

Yours sincerely,


Brian Swale