Comments on: "Critique of biodiversity impacts; Timberlands
West Coast Ltd, sustainable logging proposals"
The Department of Conservation.

Comments by
Dr Henrik Moller
Ecosystems Consultants Ltd.,
P.O.Box 6161,

Publishing this information follows written permission to do so from Timberlands West Coast Limited.                   (Click on the red - or green)

Table of Contents.     Please use your browser's back button to return here and go to another page.
1. The introductory page (Page zero) of the critique (which defines acronyms)
2. Page one of the Critique and response.
3. Page two of the Critique and response.
4. Page three of the Critique and response.
5. Page four of the Critique and response.
6. Page five of the Critique and response.
7. Page six of the Critique and response. Click here to jump to the bottom. to read the rest below; the introductory comments


The DOC Critique of TWC's sustainable forest management plans has brought forward some useful additional points for detailed consideration. The most important of these are:

The case for predator suppression of bat populations is more circumstantial than that for birds. Accordingly the putative lack of limitation of bat populations by hole availability is less certain than the equivalent inference for hole-nesting birds.

Saplings removed for "improvement felling" are not expected to be the main source of future holes because foresters select for shape and holes are triggered by environmental damage later in their lives. Nevertheless, this should be checked by field measurements and modelling, and the use of "improvement felling should be reviewed if it threatened TWC's biodiversity goals.

DoC's Critique is strongly biased in it's weighing of risks. No reliance whatever should be placed on the DoC Critique's conclusion that tree extraction "will be detrimental to threatened species" (see pt 60 of my response), let alone that retention of tree > 110 cm is "likely to be inadequate" (see pt 37 below) because:

Many of the concerns raised can be formally checked by the detailed mathematical model now proposed by TWC and Ecosystems Consultants (plans for this model have been spurred by the DoC Critique). The model will identify critical variables to measure as grouped-tree management regimes are applied. Changes imposed on the system will be slight, gradual and reversible, so an adaptive management approach using rigorous design criteria can test the putative risks highlighted by the DoC Critique while allowing a safe start to timber removal.

The Critique:
Timberlands West Coast Ltd. (TWC) have requested this second opinion on the critique offered by Colin O'Donnell (Science and Research Unit, Department of Conservation, Christchurch) on their sustainable forestry plans (hereafter called the "DoC Critique"). The DoC Critique was prepared by Mr Colin O'Donnell on three TWC plans: i.e. (1) "Beech Sustainable Management: Overview plan for sustainable beech management."; (2) Maruia sustainable management prescriptions"; and (3) Maruia working circle operations plan". The DoC Critique constitutes Appendix 4 of Mike Slater's (Conservator, West Coast) letter of 15 June 1998 (sic) to Tony Newton of the Indigenous Forestry Unit, of the Ministry of Agriculture and Forestry in Christchurch.

Colin O'Donnell very kindly responded in detail to an earlier draft of this response to the DoC Critique. His response was rapid and thorough despite it arriving while on extended holiday. His response to my draft comments is not an endorsement of the statements I make below: Clearly Mr O'Donnell and I still disagree on some matters, but his valuable response has alleviated my concerns in other areas.

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