<body bgcolor="#ffffff" text="#000000" link="#0000ff" vlink="#800080" alink="#ff0000"> <TABLE width="85%" border="1" cellspacing="0" cellpadding="4"> <TR> <!-- Row 1 Column 1 --> <TD > <img src="spacer3.gif" width="351" height="5" alt="white space"> <DIV align="center"><B>Responses to specific points raised by Colin O'Donnell</B> &nbsp; &nbsp; &nbsp; &nbsp;&nbsp; Page 6.</DIV> <HR WIDTH="95%"ALIGN=center> <center>by <I>Dr Henrik Moller</I></center> <HR WIDTH="95%"ALIGN=center> My comments have referred to numbered locations marked on Appendix 4 (attached - see rhs column), continuing at Section 3 (see previous pages in this series) before returning to the Summary & Recommendations (Section 1), now, at the end. <P> <B><I> Summary & Recommendations</I></B><P> <font color=#ff0000><B>54. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; This is accepted by TWC in its plans. The dispute is whether or not the proposed protocols are likely to increase risk for these species.<P> <font color=#ffffff>.<P>.<P> </font><font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>55. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; There is no dispute that food and nest/roost sites are also needed alongside predation control to safeguard the endangered species. The dispute is on whether the proposed logging will reduce hole or food availability in any way that increases the risks to the birds and bats.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>56. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; The DoC Critique has continually emphasised these warnings without adequately or repeatedly acknowledging that the new style of logging is so different from past practices that impacts are likely to be very much reduced (potentially even eliminated).<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>57. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; These are now proposed.<P> <font color=#ffffff>.<P>.<P> </font><font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>58. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; Mitigation procedures proposed by TWC by continual predator control and funding of research on forest processes and biodiversity management have not been acknowledged in the DoC Critique. A legitimate criticism (Colin O'Donnell, <I> in litt.</I> 5 October 1998) in my view is that these plans ( which I know about and have seen go in to the Okarito and Saltwater Plans) are not well specified in the management plans now going to public viewing. DoC and public assurance would grow if the planning was more explicit about just how much control effort will happen and where. In these ways the proceeds of sustainable timber production can be diverted back to create net conservation benefit for TWC forests and greatly assist DoC's national effort. Some bird (and bat?) recruits may flow onto nearby DoC estate where shortage on funds precludes their own "mainland island" restoration project.<P> <font color=#ffffff>.<P>.<P> </font><font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>58a. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; It is impossible to independently assess the validity of this statement (i.e. the "the only significant populations known ... outside eastern Fiordland") until data from the national bat survey efforts promulgated in recent years have been completed.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>59. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; No effects have been proven nor demonstrated to even be likely. A need for further research is indicated before the validity of the DoC Critique's conclusions can be formally assessed.<P> <font color=#ff0000><B>60. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; At the outset the DoC Critique is quite explicit that the approach taken here is indicative of the approach they recommend, and not a reliable indication or exact prediction. This caveat was lost sight of as the Critique progresses and is not evident in this summary statement. My rejoinders to the DoC Critique has outlined numerous unstated assumptions and several omissions, all of which increase perceived risks to bats and birds. Most critical of all is an unchallenged and as yet scientifically indefensible assumption that nest holes limit current population abundance, and that grouped tree removals will reduce cavity abundance in ways that will reduce population density. The second most important omission has been a lack of acknowledgement of tree growth and recruitment (projections in the DOC Critique are for static scenarios), and for no forest compensatory changes in growth and demography. In a myriad of smaller ways the risk assessment has only stressed one side of processes or unstated assumptions of additive effects. The critical need is for a model to predict the number of holes remaining after several rotation cycles, and research to predict whether the new levels of hole availability would significantly cap resurgence of numbers of hole users following predator control .<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>61. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; But no evidence for New Zealand, and sound ecological reasons for predicting that predation has lowered density to well below the carrying capacity where tree cavity limitation affects populations. Evidence from broadly similar habitats in the Eglinton Valley by the DoC team shows evidence that holes are not limiting, and repeated lines of evidence that predation is depressing population abundance. Anecdotal evidence from around Nelson in honeydew forests also demonstrates that holes do not limit kaka numbers.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>62. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; The basis for this calculation is flawed. Formal modelling of hole formation and depletion by grouped tree extraction, and of species hole requirements are needed to make it rigorous.<P> <font color=#ffffff>.<P>.<P> </font><font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>63. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; The basis for this calculation is flawed. Formal modelling of hole formation and depletion by grouped tree extraction, and of species hole requirements are needed to make it rigorous.<P> <font color=#ffffff>.<P>.<P> </font><font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>64. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; This calculation ignores the potential for compensatory changes in growth rate and survival caused by live tree removals. It is not known whether the cavity formation in large trees is a size of age <I> per se</I>, (sic) or size <I> per se,</I> or some combination of the two. Measures of rate of tree cavity formation in the managed forest system are needed to evaluate this potential compensatory effect.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>65. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; No evidence of nest site limitation is available for any New Zealand bird, or for bats. Several of the species mentioned in this regard by the DoC Critique are not obligate cavity nesters, so their numbers may be little effected (sic) even if hole availability was a regulatory factor.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>66. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; The DoC Critique only presented projections for removals above 80 cm DBH. The calculations presented were flawed in that they took no account of hole formation as trees grow into the larger sizes (sic) classes. Modeling is needed of scenarios where all 100 cm DBH trees are left <I> in situ</I> (all proposed protocols by TWC's plans), and measured rates of cavity formation are all included to see if they are a sufficient safeguard for biodiversity values in their forests. Only modelling, professional monitoring and an adaptive management approach will be able to rigorously answer the crucial ecological questions involved .<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>67. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; Modelling should allow calculations of these economic and ecological risk scenarios. Different maximum DBH extraction regimes could be one variable altered in an adaptive management framework .<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>68. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; These are likely to be very minimal effects. A rigorous calculation by TWC could remove all doubt.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>69. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; Modelling can predict whether such effects are likely to significantly alter cavity availability. This is the most significant of all the DoC Critique concerns (Colin O'Donnell, <I> in litt.</I> 5 October 1998. If an appreciable decline in the number of suitable holes is predicted, potential curtailment of the long-term recovery of bats and birds (following successful predator control) is possible. Holes are formed following environmental damage during its life cycle (usually branch breakage following heavy snow or wind, but sometimes from bruising as a nearby tree falls). Fungi then gain entry and rot enlarges the cavity. This process is most unlikely to be influenced by the shape of the tree in the forester's sense, which is the criteria (sic) used for "improvement felling" (Ian James, pers. comm. 7 October 1998). I think that it is most unlikely to suppress population abundance below that existing now, or that persisting if the forests in question were to be preserved as part of the DoC estate. Nevertheless if the proposed mathematical simulation of hole availability causes concern, TWC might need to consider reviewing its "improvement felling" strategy in order to safe-guard its biodiversity goals.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>70. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; This research is planned by TWC.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>71. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; Such research is now planned .<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>72. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; Some climbing may be done, but other measures may be taken from felled trees. Colin O'Donnell ( in litt, 5 October 1998) warns that cavities can shatter, or be filled in, or deformed when a tree is felled. Entrance dimensions can still be measured sometimes.<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>72. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; Studies of foraging preferences are a valuable first step but can not determine whether food limits the population in any way; let alone predict logging impacts .<P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>74. </B></font> &nbsp; &nbsp; &nbsp; &nbsp; This alarmist statement is very speculative.<P> <font color=#ffffff>.<P>.<P> </font> </TD> <!-- Row 1 Column 2 --> <TD > <img src="spacer3.gif" width="351" height="5" alt="white space"> Page 6 of the DoC Critique written by Colin O'Donnell. <HR WIDTH="95%"ALIGN=center> <DIV align="center"><h3>Summary & Recommendations</h3></DIV> <HR WIDTH="95%"ALIGN=center> <U><B>1.1 Principles: Impacts of logging on New Zealand wildlife</B></U><P> 1.1.1. &nbsp; Many of the forests in the North Westland beech area can easily be termed as significant habitats for indigenous fauna under the criteria of the RMA. The forests support significant populations of 24 indigenous forest birds including six nationally threatened and two regionally theatened species, two threatened bats and several threatened fish species. <P> <font color=#ff0000><B>(See comment 54)</B> Birds such as the kaka, and long-tailed bats, have been declining steadily throughout the country, and all habitats where they occur should be considered key sites for their recovery. Therefore, ensuring the sustainability of these populations should be paramount when setting harvesting limits for sustainable forest management.</font><P> 1.1.2 &nbsp; The BSM largely refers to the impacts on foraging habitats for birds.<P> <font color=#ff0000><B>(See comment 55)</B> However, ensuring the sustainability of roosting and breeding sites is just as important. Maintenance of foraging habitat would be meaningless without protection of a viable number of preferred nesting, roosting or breeding sites - and <I>vice versa</I>. <P> 1.1.3 &nbsp; A major premise of the mitigation programme being proposed by TWCL assumes that predators are the most important threat to wildlife communities. While habitat preservation without predator control would not sustain populations of threatened species, <I> neither would predator control sustain wildlife populations without protection of critical roosting, breeding and foraging habitats.</I> Management of threatened wildlife populations required an integrated management programme which incorporates control of pests and predators and maintenance of critical habitat.</font><P> 1.1.4 &nbsp; "Avifauna remains one of the greatest unknowns in terms of the effects of any management" (BSM, p. 169). TWCL are using a new harvesting technique for North Westland forests, <P> <font color=#ff0000><B>(See comment 56)</B> so obviously there are no data on its impact on wildlife. Therefore, at this stage we can only use predictive approaches to assessing potential impacts. However, the fact that a wide variety of historical harvesting techniques have all led to significant declines in numbers of threatened species serves as a warning of potential impacts. </font><P> <font color=#ff0000><B>(See comment 57)</B> 1.1.5 &nbsp; We need to go some way towards predicting impacts at this stage (see below) but if the logging is to go ahead then a rigorous research-by-management approach needs to be adopted and specific logging prescriptions need to be changed as necessary if adverse impacts are detected. Studies of wildlife foraging, breeding and roosting preferences in red beech forest will improve predictions.</font><P> <font color=#ff0000><B>(See comment 58)</B> 1.1.6 The MSMP, the document which should be specifically outlining mitigation procedures to reduce these effects, chooses not to acknowledge the New Zealand research or demonstrate how the impacts would be dealt with in New Zealand, but rather uses overseas studies. The assertion that logging increases diversity is misleading. Logging decreases the diversity of endemic, specialised and threatened species, while increasing diversity of edge-dwelling and introduced species.</font><P> <B><U>1.2 Mitigation of impacts of harvesting on threatened bat species</U></B><P> 1.2.1 Forests in North Westland support the <P> <font color=#ff0000><B>(See comment 58a)</B> only significant populations </font><P> of the threatened South Island long-tailed bat known outside of the eastern Fiordland/Aspiring area.<P> 1.2.2 While the BSM and MSMP reports note the presence of bats in TWCL forests they fail to address how harvesting regimes will <P> <font color=#ff0000><B>(See comment 59)</B> mitigate effects on bat populations. </font><P> It is not appropriate to assume that measures proposed for forest birds will also assist bat populations<P> 1.2.3 Specific surveys for short-tailed bats should be undertaken by TWCL using automatic bat detector units and mistnetting.<P> <font color=#ff0000><B>(See comment 60)</B>1.2.4 Research from the Eglinton Valley in Fiordland suggests that the harvesting regimes proposed would be detrimental to these threatened species. </font><P> Sampling of trees available to long-tailed bats indicated that suitable trees were rare in the forest and were concentrated in lowland forests on river terraces and outwash fans on the valley floor. They selected trees &gt; 80 cm DBH.<P> <I><U>1.3 Beech tree harvesting rates and mitigating effects on wildlife</U></I><P> 1.3.1 The most effective way to predict whether the harvest rates proposed (sic) is to compare those rates with the specific requirements of wildlife (in terms of sizes and ages of trees required for breeding and foraging) and then determine if sufficient trees remain through the harvesting cycle to allow for maintenance of critical wildlife populations in perpetuity.<P> 1.3.2 This submission demonstrates (i) how the specific effects of the logging regimes proposed might be predicted; and (ii) that proposed harvesting rates in the Maruia working circle may remove significant amounts of wildlife habitat, particularly for threatened species (long-tailed bat, kaka, yellow-crowned parakeet).<P> 1.3.3 One of the main predicted impacts of the harvesting regimes proposed would be the reduction in the number of older cavity-bearing trees. While the importance of cavities is disputed by TWCL <P> <font color=#ff0000><B>(See comment 61)</B> there is a huge literature available on how limitation of cavity availability can influence the viability of wildlife populations. </font><P> <font color=#ff0000><B>(See comment 62)</B>1.3.4 We predict that a minimum of 14 cavity-bearing trees/ha are required for threatened species </font><P> (long-tailed bat, kaka and yellow-crowned parakeet) for breeding and roosting (i.e. 83.5% of the 17 trees &gt;80 cm DBH/ha present in the Maruia Working Circle). Thus there is a high probability that any trees &gt; 80 cm DBH selected for harvesting would be trees required by these threatened species. Overall, the rate of felling these trees at 0.105 trees/ha/yr indicates a high minimum probability of removing 9.3% of preferred breeding trees/ha per 15 year rotation.<P> <font color=#ff0000><B>(See comment 63)</B> Over 120 years (allowing for 15 years resting between each cycle), a minimum of 37% of preferred trees would be removed. </font><P> This is unlikely to be sustainable for wildlife in the long term given that <P> <font color=#ff0000><B>(See comment 64)</B> trees take a minimum of 300 - 450 years to reach a size whereby that are used for breeding </font><P> by threatened species and because silvicultural practices will slowly reduce the number of cavity bearing trees in the forest.<P> <font color=#ff0000><B>(See comment 65)</B>1.3.5 No research has been undertaken to determine the nesting requirements of <I>other </I> indigenous species in the Maruia working circle (particularly 6 indigenous cavity-nesting species). This information is needed to assess whether the harvest prescriptions would impact on these species. Specifically, <I> these species may add to the cumulative number of cavity bearing trees per ha required for breeding wildlife</I> in addition to the 14 trees/ha required by threatened species). <P> 1.3.6 The above calculations do not provide any estimates for other cavity-using pest species in the Maruia forest ( e.g. rats, wasps, starlings) which may out-compete indigenous species seeking cavities for breeding. <I> These species may add to the cumulative number of cavity bearing trees per ha required for breeding wildlife.</I></font><P> <font color=#ff0000><B>(See comment 66)</B>1.3.7 The protection of all podocarps, rata, and beech &gt;110 cm DBH is a good first step towards mitigating the effects of harvesting on threatened species. <P> 1.3.8 In addition, no standing dead trees should be felled because they provide important wildlife habitat.</font><P> <font color=#ff0000><B>(See comment 67)</B>1.3.9 Setting the maximum harvesting limit of beech at 80 cm DBH rather than 110 cm) would mean that the majority (ca. 80% of cavity breeding and roosting sites for threatened species would be retained. This would reduce the harvest by a maximum of 10% - but would probably have a lesser impact on wood volumes recovered because a high proportion of wood from trees &gt;80 cm DBH will be "defective".</font><P> <font color=#ff0000><B>(See comment 68)</B>1.3.10 The harvesting rates per ha prescribed in the plans may be higher than the 1.009 trees/ha/yr because additional trees will be felled for roads, landings, firewood and health and safety. it is unclear from the documents what the real harvesting rate will be, but they may be greater than the level prescribed. </font><P> <font color=#ff0000><B>(See comment 69)</B> 1.3.11 "improvement felling" of immature "defective" stems (set a 2.36/ha/yr) will limit the potential pool of trees which will develop cavities (e.g. for nesting and roosting) in the future. It is not known what the long term impact will be, but if 19% of young, "deformed" red beech are felled per rotation, this would have a significant impact on the occurrence of cavity bearing trees in future generations.</font><P> <font color=#ff0000><B>(See comment 70)</B>1.3.12 The MSMP acknowledges that research on recruitment of new trees in these beech systems is required. Without this research, no-one will be able to assess if the annual rate of felling (especially in the larger tree size classes) will in fact mimic natural processes and be sustainable.</font><P> <font color=#ff0000><B>(See comment 71)</B>1.3.13 Surveys of the frequency of availability of cavity-bearing trees within the TWCL working circles would provide more precise prediction of the effects of harvesting on threatened species.</font><P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>(See comment 72)</B>1.3.14 Climbing trees before felling would provide the only accurate means of assessing presence of cavities.</font><P> <font color=#ff0000><B>(See comment 73)</B>1.3.15 A study of the foraging preferences of birds within the area would improve predictions as to whether the management regimes proposed would leave sufficient foraging habitat for populations to remain viable.</font><P> <font color=#ffffff>.<P>.<P> </font> <font color=#ff0000><B>(See comment 74)</B>1.3.15 (sic) Unless long-tailed bat roosting areas in the managed forests are identified prior to harvesting, then patchwork felling (tree group selection) would increase the probability of <U> devastating</U> bat populations. Long-tailed bats roost in relatively small patches of forest, usually in clusters of trees.</font><P> </TD> </TR> </TABLE>