The Assessment of Environmental Effects for the Timberlands West Coast sustainable beech management proposals of 1998 - 1999, written by Kit Richards. Timberlands West Coast Limited (New Zealand) (TWC) applied to the Buller and Tasman District Councils for Resource Consent hearings under the Resource Management Act 1991, to carry out sustainable forest management in about 98,000 hectares of beech (Nothofagus) forest. TWC is a State Owned Enterprise, created following the dis-establishment of the NZ Forest Service by the 1984 - 1990 Labour Government. In 1999, a newly elected Labour government, acting on preservationist dogma, moved swiftly to stop the Resource Consent hearings. In consequence, the public of New Zealand, and the world, was enied the oppertunity to learn about the excellent and world-leading sustainable forest management developed and proposed by TWC. This document is published here to help make the information more publically accessible.

Assessment of Environmental Effects


APPLICATIONS FOR RESOURCE CONSENTS

UNDER SECTION 88 OF THE

RESOURCE MANAGEMENT ACT 1991


Page five of this document.


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6.3.4 Predator Control

In general terms, the greatest impact on indigenous fauna in the sustainable management estate is from predation and competition. Predators are already present in the sustainable management estate, and indeed in most of the conservation estate. Sustainable management of the beech forests provides the opportunity for predator control research and control measures. TWCL will commit funds to these activities, although they can not guarantee at this stage that the outcome will be a significant reduction in predators. However, it is not anticipated that sustainable management will significantly increase current predator levels within the overall sustainable management estate. Such pest populations already fluctuate dramatically according to heavy seeding years.

The control of pests in relation to the protection of vegetation has already been described. In relation to the protection of fauna values the strategy employed by TWCL will include over and above the contributions to generalised control programmes:
  • Regular systematic control operations in conjunction with annual operations areas and along road lines.
  • Co-operative management of priority "integrated landscape management" areas to jointly accepted targets.
  • The more general application of multi-predator control techniques if research defines safe and appropriate systems.
  • The commitment of between 5% and 10% of net revenue to pest control, ecological research and monitoring.

6.4 Waterbodies and Riparian Margins

6.4.1 Overview

Under traditional forest management regimes where sites have been clearfelled around streams, concerns have arisen over the impacts of harvesting on instream biota. In a review of the potential impacts upon fisheries of proposed beech forest management, commissioned by TWCL, Ryan (1997) identified potential contributors to negative impact upon fisheries habitat (outlined in the sections below).

6.4.2 Suspended and Deposited Solids

Released primarily from ground based hauling activities and badly controlled roading activities, suspended sediments could reduce photosynthetic activity in waterways and impede ‘visual feeding’ of fauna such as banded kokupu. Deposited sediments clogg gravels, reducing oxygen levels and periphyton productivity as well as dependants down the food chain.

Provision of riparian management zones and compliance with standards set out in the TWCL

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Environmental Compliance Manual was recommended and seen as reducing potential effects to an undetectable level.

6.4.3 Nutrient Loads

Nutrient loads could increase as a result of large amounts of organic material left to rot in concentrated areas e.g. following coupe harvesting (which is not proposed) or from the excessive use of urea as a pinhole borer mitigation strategy.

Ryan noted that, while the potential might exist for increased nutrient loads and while undesirable in relation to a natural system if it did occur under depressed light conditions, algal growth would not be significant and any flow on effects, if they occurred, could be positive in terms of fish numbers.

No adverse effects from increased nutrient loads are anticipated from this proposal.

6.4.4 Dissolved Oxygen

Breakdown of large quantities of woody material in waterways could reduce dissolved oxygen and lower fauna carrying capacity.

Ryan concluded that the nature and steep slope of streams in the forests in question would result in sufficient disturbance and turnover of water so that, provided water temperatures remained low, there would be no effect even if debris entered waterways.

Mitigation measures proposed are designed to minimise instances of woody debris entering waterways.

6.4.5 Organic Material

Algal films developing on woody material in rivers and streams was noted as an important source of food in the food chain of many of the fisheries.

Small amounts of woody debris entering forest streams were noted as likely to be beneficial.

6.4.6 Light and Temperature

Increased light levels leading to higher temperatures normally leads to adverse effects from reduced oxygen content in the water and increased algal growth.

The report concluded that with the provision of streamside (riparian) management areas there would be no detectable or significant change to normal levels.

Submissions to the government process on the management proposal raised issues in relation to a perceived inadequacy in the width of riparian management zones compared with overseas (USA/Canadian best practices). Also raised were the effects of harvesting upon terrestrial streamside invertebrates providing food to the aquatic chain and the failure to provide for

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riparian management of small ephemeral streams that may nevertheless provide breeding habitat for native fish species.

TWCL has reviewed its plans and remains confident in its plans as specified. It is correct that best practice in some countries provides 4-5 times larger riparian management areas. However, such catchments are being subjected to intensive harvesting using heavy ground based machinery. The resulting impacts are orders of magnitude greater than those anticipated for the beech.

In the situation of ephemeral streams and terrestrial invertebrates, the impacts are limited by the rules for vegetation protection that are designed to ensure a scale, intensity, and spatial and temporal distribution of gap formation in the forest canopy within the scale of normal regular events. This should protect invertebrate biodiversity. Natural gap formation often leads to the uprooting and/ or felling of trees from stream banks into the watercourse. The uproot will often loosen soil that will gain direct entry into the stream. Protection from such eventualities due to harvesting are specifically prescribed for.

6.5 Natural Features and Landscapes

Section 6(b) of the RMA requires that the protection of outstanding natural features and landscapes from inappropriate use and development be recognised and provided for. Furthermore, Sections 7(c) and (f) require that in managing the use, development and protection of natural and physical resources, the consent authority must have particular regard to the maintenance and enhancement of amenity values, and maintenance and enhancement of the quality of the environment. However, Buller District Council has reserved discretion only over the protection of outstanding landscapes and not over general landscape amenity. The Council has not identified any areas of outstanding landscapes or natural features in the Proposed Plan. TWCL has of its own volition excluded a number of significant landscape areas from the proposal. There are not other outstanding landscapes within the estate. Furthermore, as outlined below, the operations has virtually no effect on visual amenity and little effect on intrinsic (wilderness) values.

6.5.1 Visual Effects of Harvest Gaps

The West Coast is arguably one of the most picturesque parts of New Zealand. Landscapes within the proposed management area are typified by a close and intertwined integration of large areas of relatively unmodified natural areas and small farming and urban communities. The lineal nature of the West Coast means that visitors to the region can travel for long distances in close proximity to the natural environment without experiencing the impact of intensive urbanisation and agriculture.

These characteristics are of intrinsic value to the residing communities of the West Coast and an integral component of the tourism industry which, while not utilising the sustainable management estate directly, does benefit from the impression of unspoiled naturalness of the region.

These factors mean that it is important to design harvesting and roading systems to avoid or mitigate any type of visual impacts that could detract from the landscape impression.

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In the course of wildlife surveys (Buckingham et al, 1996, 1997, 1999) and as a result of a specially commissioned report (Watson, 1997), areas of particular landscape note were identified for protection. These are identified on maps in Appendix 6, Volume 2), and have been reserved from production. In general, however, it was noted that for most of the TWCL forests, the area visible from main highways was small and, if visible at all, generally part of the distant backdrop. The most sensitive areas were parts of the lower Maruia Valley from Highway 65 and the upper Grey Valley from Highway 7.

Aerial coupe and selection harvesting trials have shown that under both forms of management the impacts can be minimised. However, in the case of selection systems, it is clearly demonstrable that whether from a ground based or aerial oblique view or directly overhead, only the most trained eye, with the benefit of previous reference, could distinguish a harvested from an unharvested site.

To demonstrate the visual effects of aerial harvesting, photographs of harvesting gaps created during trials are included in Appendix 11. There are two aerial photographs included in the appendix showing the trial area before and after group tree selection trials. Trees in the trial were harvested at a similar density to that proposed for management in these applications. The trial area includes all of the land on the aerial photos below the road (located towards the top of the photos) and inside the TWCL boundary to the right of the photos. The before and after photos demonstrate that it is very difficult to detect any change in the visual appearance of the forest as a result of group tree selection.


6.5.2 Visual Effects of Roads

Roads are considered to have a greater potential for adverse impacts on the landscape than the actual harvest areas. As outlined above, approximately 80% of the roading network is already in place within and adjacent to the sustainable management estate. Therefore, adverse effects need only be considered in the context of the incremental increase in roading.

Road construction standards for new roads are proposed to minimise adverse effects on the environment from new roads. Where roads fall outside these restrictions, separate land use consents will be required. The density of roading required for aerial harvesting operations is significantly lower than for other methods of harvesting. In addition, new road locations can be limited to valley floors to avoid large side cuts. Performance standards to minimise landscape impacts include a maximum road gradient of 8°, a maximum width of 10m and a maximum batter height of 3.0m. The fact that most of the roading network is already in place and completely invisible even from the air unless directly overhead is testimony to the fact that the visual impacts of narrow valley floor roading can be substantially avoided or mitigated.

New roading and landing sites will also not be permitted within areas of identified landscape importance which have been reserved from production.

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6.5.3 Sites of Geological Importance

There are some sites of national geological importance within the sustainable management estate, the details of which are contained in Section 8.3 of each TWCL working circle Sustainable Management Plan. Aerial harvesting of logs will not adversely affect any of these sites.

Roading operations could impact on these sites and they have thus been avoided when access routes were defined.

6.6 Socio-Economic Effects

6.6.1 Efficient Use and Development of Resources

Section 7(b) of the RMA requires the consent authority to have particular regard to the efficient use and development of natural and physical resources. However, in the case of the Buller applications, the Council has not reserved any discretion over this matter. Accordingly the economic efficiency of the activity is not under scrutiny and in any event will be addressed in the medium term by the profitability and therefore feasibility of the activity. That is, the market will decide whether or not the activity is efficient. Nevertheless, for the sake of completeness, efficiency issues are discussed below.

Unlike past proposals for utilisation of the beech resource, the current proposal represents a more efficient use of the (natural) resource, with more value extracted from harvested trees and retained locally with dramatically reduced cost to the environment. Previous proposals such as chipping would have seen little downstream economic benefit derived locally with chipped beech product being exported without any added value processing on the West Coast.

Sustainable beech management will target a niche market with a high value solid wood product (e.g. veneer, feature flooring and panelling, and furniture) being part or fully manufactured locally prior to export overseas and to other areas within New Zealand. This will enable a higher economic value to be derived domestically from the harvested beech. Furthermore, the beech production estate of the West Coast is nationally significant as the only integrated, multi-species native forest area set aside specifically to provide for the supply of native timbers in perpetuity.

Currently there is sufficient existing capacity on the West Coast to potentially mill the produce from beech management with little capital investment using existing infrastructure. However, at full scale there will need to be investment in drying facilities. The ultimate nature, scale and location of processing will be determined through commercial interaction of local processors, investors, those with market access and the resource manager.

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6.6.2 Direct and Downstream benefits

Today on the West Coast and in Tasman District a resource exists that is capable of producing a range of quality wood products. This provides an opportunity for giving rise to further social and economic activity in a region where economic (and social) diversity and sustainability is limited by historical, geographical and, to some extent, external political influences. Seventy-eight percent of the region’s landmass is formally protected under the Conservation Act 1987. This is the direct opposite to most of the rest of New Zealand. The current small economic base (including tourism), remains either extractive, vulnerable to international market swings or seasonal. Furthermore, within any given economic segment, diversity is low whether the activity is agriculture (where dairying is the only currently profitable venture), or tourism where the key attractions remain ‘eco-focused’, widely separated over the length of the West Coast and highly seasonal.

The West Coast beech forests are capable of production under management regimes that can meet the highest international standards for sustainability. They can contribute to meeting the demands of both domestic and international markets where the qualities of such timbers show little sign of substitution by commodity industrial timbers such as radiata pine. As such, beech management will provide a much needed additional diversification to the West Coast economy. Potentially, value added processing of the beech resource could be developed on the West Coast.

The forest industry on the West Coast is the fourth largest behind mining, agriculture and tourism (West Coast Regional Council, 1997). Its relative position is determined by the fact that forestry is presently at the lowest point in transition from a total reliance on unsustainable quantities of high valued rimu, to plantation radiata and dramatically reduced volumes of sustainably produced rimu. Due to the resource age, plantation volumes are presently constrained to levels marginal for the efficient processing of commodity plantation products. Under these constraints the industry remains at its most vulnerable, being both confined to relatively inefficient levels of processing and unable to expand until increased volumes of the resource become available early next century. Even at full regional production, the West Coast’s plantation resources are small by the scale of production available elsewhere in New Zealand. Being distant from ports, the local forest industry will never achieve low cost economies of scale achievable elsewhere.

For this reason a focus on quality, utilising the highly tended nature of the local plantation forest resources to advantage in combination with unique indigenous resources, provides a strategic position the West Coast industry can capture. It is a position that is unavailable to any other major forestry region in New Zealand except Southland to a much lesser degree.

Analysis of the indigenous forest industry has revealed a very high value added multiplier, largely because the industry is strongly supported by consumer demand for rimu timbers. Almost all of the value is accumulated within the domestic economy, as timber is processed and reprocessed until reaching the market as New Zealand’s premier furniture product. For rimu, the value multiplier has been assessed at around four in terms of regional processing and eleven to the end user at the furniture manufacturer. These figures compare with an average for commodity plantation products of a little over two to a maximum of four. Exotic supply is

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well in excess of domestic demand and most additional solid wood production is exported in a semi-processed form to highly competitive international commodity markets.

In employment terms high value recovery required of fine woods operations are much more labour intensive, with an efficient operation employing in the order of two or more times the labour for a given level of pine production.

The future potential of the West Coast forest industry lies with being able to position itself to become New Zealand’s forestry focus for the production of a variety of highest quality fine wood products. It has neither a competitive advantage, nor the economies of scale required to compete at the low end of the Pinus commodity spectrum.

Market research has established that the markets for beech timber, particularly for furniture, flooring and panelling and bench tops is already well established and at sufficient price to support sustainable management costs. The markets are largely in Australia where a “solid wood culture” is already established and where substitution of diminishing supplies of eucalyptus can occur. The opportunities for beech in the New Zealand market are also increasing but will not open fully until sources of cheap wood from unsustainably managed SILNA forests in Southland are brought onto sustainable regimes. At this point and with the final decline in the availability of rimu to its sustainable level, the New Zealand market is expected to easily absorb a significant proportion of production. The main anticipated product lines will be furniture, feature and composite flooring and solid and composite joinery.

6.6.3 Tourism

Eco-tourism is a significant contributor to the West Coast economy. While there is very little direct use of the sustainable management estate for tourism, its naturalness contributes indirectly to the tourism experience. Visual impacts of harvesting and roading from state highways has the greatest potential for adverse impacts on tourism. The Landscapes and Natural Features Section above concludes that there will be no adverse effects on landscape values from the most sensitive areas (i.e. state highways).

Commercial tourism ventures within the sustainable management estate will be encouraged. Proposals will need to conform with TWCL’s environmental, health and safety responsibilities and must not conflict with sustainable forestry operations. Such ventures will be required to submit appropriate proposals and will be treated on a case by case commercial basis. Improvement and extension of the forest road network will also improve the opportunity for use of the sustainable management estate for tourism through improved vehicle access. Though the types of tourism that benefit from management of the estate may be different to those that theoretically might benefit from an unmanaged estate, the differences will complement the overall diversity of the tourism experience and will certainly compliment the vast unmanaged resource opportunity in the public conservation estate.

6.7 Cultural and Heritage

6.7.1 Relationship of Maori to Land, Water and Sites

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Section 6(e) identifies the relationship of Maori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, and other taonga, as a matter of national importance.

TWCL has undertaken consultation with the Natural Resources Manager of Ngai Tahu Group Management, as well as Te Runaka o Katiwaewae and Te Runanga o Makawhio. No specific sites of significance to Maori within the sustainable management estate have been officially identified to TWCL to date. Should any sites of Maori occupation be identified during harvesting and/ or roading operations, TWCL will liaise with the appropriate iwi authority regarding appropriate protective measures. TWCL’s accidental discovery protocol is discussed further in Section 6.7.3 below.

Maintenance of the quantity and quality of water is also of great cultural significance to Maori. The nature of operations and riparian management practices proposed will ensure that water quality and quantity is not compromised by harvesting and roading.

6.7.2 Historic and Archaeological Sites

Several historical sites are located throughout the sustainable management estate which reflect past sawmilling, gold and coal mining activities undertaken by pioneers of the West Coast. Records of all known registered historic sites are held on a TWCL database, and the locations are shown on Map 5.

Harvesting of trees and earthworks associated with road construction will be undertaken in a manner which does not physically impact on any registered sites. Should any additional sites be identified during forest operations, damage to these sites will be avoided, their location recorded, and the New Zealand Historic Places Trust and relevant iwi authorities (unless the site is clearly an example of early European occupation) advised accordingly. TWCL has protocols incorporated into its environmental management system to ensure the correct treatment of these sites.

6.7.3 Accidental Discovery Protocol

Objectives:
  • To avoid, minimise or mitigate the impact of TWCL's operations on significant protected archaeological sites, i.e. sites associated with human activity occurring before 1900.
  • To achieve approval from New Zealand Historic Places Trust to carry out any operations where modification of these sites may be required.
Pre-Operational Planning

TWCL has undertaken a classification system for historic and archaeological sites within its estate. As part of pre-operational planning prior to harvesting, Form D2 from TWCL’s Environmental Manual must be completed and the site classified into a category using Timberlands Classification and Management System for Historic, Cultural and Archaeological Sites (Table 6 Below).

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As part of the planning of an operation within an area where there are known or suspected archaeological sites, an archaeological field survey will be undertaken to accurately determine the location and significance of such sites. All or any archaeological sites within areas where operations are planned will be recorded and accurately shown on maps by an appropriate consultant. The archaeological report prepared by the consultant will assess the significance of the recorded historic features.

Following the forest archaeological survey TWCL will obtain relevant authority from New Zealand Historic Places Trust, where necessary, to modify any affected archaeological sites within the operations area. The Historic Places Trust may wish to set conditions on the modification that is undertaken. These must be observed at all times.

Planning for operations will consider the location and importance of any archaeological sites. The New Zealand Historic Places Trust acknowledge that mining sites may be of little significance individually, but the location of sites is of importance to provide an overview of historic activities.

In operational areas where mine shafts are numerous, and present a major hazard to field staff, one or two good examples of the local norm will be selected and fenced off. An authority to close the balance will be made by TWCL management for reasons of safety. However, their locations will be GPS located where practical and highlighted on a map. This information will be passed onto the New Zealand Historic Places Trust.

Inadvertent Damage to Unknown Sites:

There are some sites on the West Coast that are not visible on the surface, e.g. underground tunnels, races etc. If such a site is found during an operation the following steps must be taken:-
  • The contractor must report the site to the supervisor in charge,
  • An assessment must be made of the site's significance, if considered not a protected archaeological site (see below) then operations may continue,
  • The Supervisor records the description and location of the site using Form D2 (TWCL Environmental Manual) , and
  • The location of the site is defined by GPS if possible, located on relevant maps, and recorded the site in the TWC Historic Places Database. The information is passed onto the New Zealand Archaeological Association file keeper.

Timberlands Classification System for Historic Sites:

Much has been written on site assessment and significance in New Zealand and overseas. Formal ranking systems provide an attempt at objectively assessing inter-site relationships, based on a number of variables to achieve various research or management objectives. However perceptions vary between assessors and over time. The table below is a general guide for TWC operations.

Table 6: Timberlands Classification and Management System for Historic, Cultural and Archaeological Sites

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CATEGORY
SITE TYPE
ACTION
A. NATIONALLY
OR
REGIONALLY
SIGNIFICANT





  • Identified regionally significant sites.
  • A combination of preserved, locally significant sites and structures within a confined area of historical/cultural workings, e.g. Woods Creek Track.
  • Site of Maori cultural significance.
  • Notify Historic Places Trust for advice. Reserve area if Trust advises this.
  • Notify local iwi representative, if appropriate.
  • Notify the Department of Conservation.
B. LOCALLY
SIGNIFICANT
SITES






  • Readily identifiable structures or parts of structures in good or largely complete condition, eg historically recorded water races, tracks and mine shaft complexes, suite of undamaged adjacent mining/historic features.
  • A site type that occurs sparsely throughout the West Coast.
  • Locate site with GPS where practical and record site on map.
  • Protect site from damage by restricting or modifying operational procedures.
  • Pass information onto Historic Places Trust prior to operation commencement.
C. SITES/AREAS
OF LOW
SIGNIFICANCE







  • A site of little significance e.g. pile of tailings, sluice faces, mine shafts.
  • A site already destroyed or damaged.
  • A site or feature that occurs repeatedly throughout the West Coast.
  • Locate site with GPS where practical and record site on map.
  • Pass information onto Historic Places Trust prior to operation commencement

6.8 Recreational Values

6.8.1 Recreational fisheries

Section 7(h) of the RMA requires the consent authority to have particular regard to the protection of the habitat of trout and salmon. Although this is not a matter over which the Buller District Council has reserved discretion, it has reserved discretion over effects on recreational values.

The West Coast Fish and Game Council has identified a number of waterways within the sustainable management estate that are important for recreational fishing. TWCL’s riparian margin management measures will ensure that habitat values of these streams are not compromised.

In addition, an upgraded and improved roading network will improve public access to waterways within the estate.

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Wilderness values, which are a component of the recreational fishing experience relevant for some anglers in some specific situations, are discussed separately below.

6.8.2 Hunting

Recreational hunting is also carried out in many of the TWCL forests. Hunting is a free public good. It will be limited for public safety reasons during operational or pest or predator eradication (poisoning) operations. To ensure the safety of hunters, forest workers and the public, hunting will continue to be allowed by permit only as is current practise. Restrictions on the use of dogs for hunting will apply in certain forests where kiwi are known to exist. Hunting to control pests and predators will be encouraged.

6.8.3 Public Access

Access to forests, other than operational areas or at times when safety or research is an issue, will be free and open. Most roads will be maintained to the level required for management (i.e. four wheel drive surfaces). Therefore, management of the estate will enhance public access to the forests.

TWCL will actively encourage research and educational activities, and will also consider any commercial recreation ventures subject to its health and safety criteria.

6.8.4 Wilderness Values

Particular forest compartments which have recently been harvested are likely to have slightly reduced wilderness values compared with unharvested compartments. The effects will generally be barely noticeable on the ground within five years immediately following harvest. This must also be considered in the context that these areas are a small fraction of the overall indigenous forest resource on the West Coast, and areas with the highest wilderness values are already protected within the conservation estate. Only a small percentage of the sustainable management estate will be undergoing harvesting operations at any one time minimising intrusion to recreational users of the estate. Typically this will be close to 15 years. On average the time operations are conducted in a compartment per felling cycle will be 1 to 3 months. This is an extremely short period of time when considered over the full felling cycle period. In addition, operations such as felling trees will move around the compartments, which may be as large as 600 ha. The same area in the recovery forest even aged forests will only be revisited a minimum of once every 10 years, and in any case the prior disturbance or over-cutting of these areas is already likely to have reduced wilderness values in relation to the old growth forests in the estate.

A number of roads and walking tracks receive light use for tramping access into and beyond the sustainable management estate, as well as access for picnickers and recreational hunters. Some streams are also utilised for recreational fishing. A perception of reduced naturalness within the estate will adversely affect wilderness values derived by those tramping in the area. However, opportunities for alternative recreation activities such as mountain biking will be enhanced as will increased options and opportunities for family based recreation. Riparian management areas will minimise impacts on the wilderness values of streams, while management practices will also seek to avoid felling of trees across roads and tracks.

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A buffer strip of 250 m has also been set aside along a 12 km length of Waitahu Valley Road through to the TWCL boundary in Station Creek near Montgomery Hut. This is an addition to the normal riparian management area because these areas have been identified as having particularly high recreation value. Twenty metre buffer strips are also established along Blackwater Forest Roads which provide access to the townships of Waiuta and Blackwater. This includes Blackwater Road from SH 7 to Waiuta, and Snowy River Road, where these roads pass through or are adjacent to Blackwater Forest.

Ten metre buffers reserved from logging will also be established along all boundaries adjacent to the conservation estate, to mitigate any impacts on recreation values within these areas.

6.8.5 Noise

Noise is likely to have some temporary and very short term adverse effects on the wilderness and amenity values of the particular operational compartments being harvested. However, these effects will only occur for a few days for each felling cycle (e.g. once every 10 - 15 years for old growth forests). Helicopter operation would typically occur for two to three days in an operational compartment per felling cycle, up to a maximum period of one week. Noise level readings have indicated that other than directly under or within 100m of the helicopter, noise levels rapidly decline to quite moderate or low levels.

Chainsaw noise associated with tree felling will be conducted more regularly within the estate, and will be undertaken within compartments being harvested throughout the year. It is estimated that felling operations over a compartment would take one to three months depending on the size and topography of the compartment. However, such noise will rarely carry more than 1km across flat land and will often be screened by hills and ridges. Areas being felled will continuously move around resulting in only temporary affects while areas are being selectively harvested. Again, areas will not then be revisited during the felling cycle. Given this, the overall adverse effects of noise on the recreation and wilderness values of the sustainable management estate are considered to be minor.

6.9 Traffic Effects

As discussed above, the total number of existing and proposed new vehicle accesses to and from TWCL forests to public roads is 50. The location of these accesses is shown on the maps in Appendix 9, Volume 2. Accesses generally involve an extension to an existing metal local road, or an intersection with an existing local road or state highway. All accesses will be upgraded or formed to the requirements of the relevant road controlling authority to ensure appropriate standards of formation are provided.

As the proposal is a passive management system, vehicle movements will generally only occur from accesses during harvesting operations. These movements will only be temporary and for relatively short periods of time. Predictions of the volume of traffic movements associated with forest management are discussed in Section 4.10 above. It is considered that the low volumes of traffic (light and heavy), and temporary periods of usage of accesses by heavy vehicles during harvesting, will be such that potential adverse effects on traffic safety

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and management on public roads can be adequately mitigated by appropriate standards of access formation, and, where necessary, temporary traffic management measures such as warning signage near forest access sites during harvesting operations.

It is anticipated that any direct access formation to state highways would be constructed to an all weather gravel access standard rather than a sealed formation given the low volume and temporary nature of usage.

No significant impacts on the wider roading network are anticipated. The total volume of truck movements per year is estimated to be a maximum of 420 truck loads/840 movements per working circle per year. These movements will be spread diffusely throughout the roading network. Road user charges are already taken from heavy transport operators which goes towards the upkeep of roads. Safety and efficiency of roads at access points to the estate will be provided by compliance with site distance, intersection offset and construction standard standards in the District Plans. Where these are not meet, one-off consents will be applied for and the site specific suitability of each access from a safety perspective will be able to be scrutinised.







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7. CONSULTATION

7.1 West Coast Forests Accord 1986

Consultation on the sustainable beech management proposal effectively began in the 1980s culminating in the West Coast Forest Accord 1986. The West Coast Forest Accord included extensive consultation with conservation groups, forest industry representatives and local and central government. The Accord process identified a number of significant natural areas. This subsequently resulted in establishment of an extensive network of reserves and the creation of a new national park, as well as specified areas of indigenous forest being set aside to allow a continuing supply of indigenous timber in perpetuity. The Accord made specific provision for sustainable beech management within areas set aside for ongoing indigenous timber supply. Signatories to the Accord, who were involved in an extensive consultation process, included:
  • West Coast United Council (now West Coast Regional Council);
  • Native Forests Action Council;
  • Royal Forest and Bird Protection Society of New Zealand;
  • Federated Mountain Clubs of New Zealand;
  • West Coast Timber Association;
  • Westland Timber Workers Union; and
  • The Crown (represented by the Minister for the Environment).
7.2 Forests Amendment Act 1993

There was general public participation in the formulation of the Forests Amendment Act 1993, which exempted the Crown beech management forests in North Westland from the Act. The exemption was due to these forests already being the subject of more specific control under the West Coast Forest Accord and the resultant Deed of Appointment between the Crown and TWCL. Notwithstanding, TWCL has prepared sustainable management plans for its proposed beech management, and sought “compliance verification” of its plans from the Minister of Agriculture and Forestry as if the proposals were subject to the Act.

At present the Forests Amendment Act is in the process of being further amended specifically among other things to bring the Crowns indigenous West Coast estate under its provisions. It is expected that by the time resource consent processes for this project have been completed, the forests administered by TWCL will be under the jurisdiction of the further amended act.

In the preparation of the plans, a number of organisations and individuals with environmental knowledge were consulted. Draft management plans were produced and submitted to the Parliamentary Commissioner for the Environment (PCE) for independent review. The PCE’s review involved extensive consultation with stakeholder groups and submissions from a number of these groups were incorporated into the PCE’s report. These submissions can be viewed in the report Timberlands West Coast Limited.     Draft Beech Management Prescriptions Review Panel Report, Office of the Parliamentary Commissioner for the

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Environment, 1995. The plans submitted to the Minister of Forestry for “compliance verification” were modified to incorporate many of the issues raised in submissions to the PCE during the audit process.

Plans submitted to the Ministry of Forestry for were also subject to a public submissions process where over 12,000 submissions were received. Submissions ranged from brief comments form individual members of the public, to detailed scientific analysis and review by environmental groups, government agencies and academics. While this process of consultation was not an RMA process related to the current applications, submissions in this process have resulted in further modification to TWCL’s proposal, most notably being the removal of improvement fellings in the old growth forests, and clarification of monitoring and pest control strategies.

7.3 Pre-lodgement Consultation

In addition to the consultation outlined above, TWCL has undertaken additional specific consultation in association with preparing the resource consent application for sustainable management.

Consultation with potentially affected iwi groups was undertaken to determine if any specific sites of significance to Maori are located within the sustainable management estate, protocols for discovery of undiscovered sites, and proposed measures to maintain water quality in recognition of the special relationship Maori have with water. This included the Natural Resources Manager of Ngai Tahu Group Management, as well as Te Runaka o Katiwaewae and Te Runanga o Makawhio. No specific sites of significance or particular issues of concern have been identified to date.

A draft resource consent application/assessment of environmental effects was circulated to the Department of Conservation for comment prior to finalisation and lodgement. TWCL is working through a programme of consulting with land owners who will be physically impacted upon by proposed forest access roads.

A significant list of other stakeholder groups and individuals have also been consulted, provided the opportunity to visit operational trials and provide feedback. The list of such parties is documented in the preface Pg XVII of the TWCL Sustainable Management Overview Plan. There has also been substantial public and political debate regarding the proposal. In summary, submissions to date and public views could be described as fitting into the following broad categories.
  • Those (including a clear majority of the West Coast Community ) who support the proposal because of the economic and employment opportunities it will maintain or create. Because they believe on the basis of existing similar operations in the regions that it is ecologically sustainable and because it was part of the Accord agreement.
  • Those who are opposed to the scheme on philosophical/ emotional grounds (all indigenous forests should be totally protected) irrespective of whether the proposal will result in adverse effects.
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  • Those who are concerned with the ecological sustainability of the proposal and potential adverse environmental effects.
This Assessment of Effects is addressed to the latter issues. TWCL accepts that those in the second group (some of whom also rely on ecological arguments) will remain opposed to the proposal irrespective of the Accord and irrespective of scientific views. However, in terms of the requirements of the Resource Management Act, TWCL is required to address issues of sustainability as defined in the Act. This includes provision for the economic wellbeing of the West Coast community provided adverse effects can be adequately avoided remedied or mitigated.






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8. MITIGATION MEASURES

8.1 General Management Objectives

The prime goal of management is to successfully, commercially and sustainably extract a wood product while sustainably managing the forest resource within the framework of Part II of the Resource Management Act 1991.

In particular, management seeks in providing a commercial good to also avoid, remedy or mitigate all potentially significant adverse effects on the environment and in particular to safeguard ecosystems and to protect any areas of significant indigenous vegetation or significant habitats of indigenous fauna. The objectives that provide for the required protection are to:
  1. recognise areas or species of extra-normal importance to ecosystem processes at the landscape level that will be protected or subject to modified management.
  2. restrict or avoid harvesting in some forest areas known or identified from surveys as being of special importance to the survival or breeding of threatened species of native fauna.
  3. use a forest silvicultural system itself that seeks to protect these values by aiming "at forest structures which keep the rainforest ecosystem as robust, elastic, versatile, adaptable, resistant, resilient and tolerant as possible…..".

More specific objectives for the TWCL sustainable management estate are:

Ecological Sustainability

  • To structure management to meet the definition of sustainability contained in the Resource Management Act 1991 and in particular to seek :
    • To avoid, remedy or mitigate any adverse effects upon ecological processes of the forest and its associated biota;
    • To safeguard the life supporting capacity and intrinsic value of forest ecosystems;
    • To sustain the potential for the forest resource to meet the needs of future generations; and
    • To protect areas of significant indigenous vegetation and significant habitats of indigenous fauna.
  • To undertake management intervention that is in alignment with spatial and temporal scales of natural disturbance process in the forest ecosystem consistent with information of the day.
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  • To minimise adverse impacts upon biodiversity and the environment in general.
  • To contribute to New Zealand's obligations under the criteria for sustainable management of forests in the Montreal Process (see P. 8 of TWCL Sustainable Management Overview Plan for a discussion of the Montreal Process).
  • To seek ISO 14001 accreditation with incorporation of Forest Stewardship Council (FSC) principles (ISO 14001 certification has been achieved).
Forestry and Economic
  • To operate to standards equivalent to the Forest Amendment Act 1993 and be a leader in the standards generally accepted under that Act.
  • To manage the forests using natural forest management principles.
  • To maintain the current potential of the forests to produce high value native timbers at levels that will not diminish in quantity and quality over time.
  • To enable production of other commercial forest products where compatible with the ecology of the forests.
  • To achieve commercially appropriate rates of return on investment in the forest assets.
  • To manage the forests to assist, commensurate with sound business practice, the development and diversification of employment and economic opportunity on the West Coast and New Zealand as a whole.
  • To achieve continuous improvement in the application of forest management practices.
Social
  • To sustainably manage the forest resource so as to enable people and communities to provide for their economic wellbeing.
  • To protect resources of cultural and historic significance.
  • To enable public use of and recreation within the forests.
  • To have regard to the efficient use and development of these finite natural resource areas.
To meet the overall management objectives, more specific management objectives, operational policies and specific controls (rules) have been devised for previously unlogged old growth forests and previously logged recovery forests as outlined below. It is anticipated that the specific controls proposed would be included as conditions of consent.

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8.2 Old Growth Forest Harvesting

8.2.1 Additional Management Objectives
  1. To select and fell groups of trees that will create gaps corresponding in scale and pattern with the natural replacement processes within forest types.
  2. To encourage the establishment, growth, and survival of forest regeneration with minimal site manipulation.
  3. To harvest a percentage of the gross increment across specified diameter classes so as to maintain, based on existing average conditions, a near natural forest structure, composition of species and biodiversity.
  4. To take care in all operations to at least maintain, if not improve, the productivity (in quality and quantity) and relative site characteristics of the forest ecosystem.

8.2.2 Operational Policies
  1. In old growth (previously unlogged) forests, management systems employing only group tree selection silviculture will be practised except when trees are recovered. following windthrow, earthquake or other natural disturbances.
  2. The permissible harvest will be regulated by the maximum numbers of trees in each diameter class by species that may be felled. Annual operational areas will have specific harvest rates determined based on the respective forest type data.
  3. Harvested yields will be reconciled against permissible yields through the establishment and maintenance of appropriate databases.
  4. Trees to be felled must be selected in proportion to their natural presence from across the existing diameter range to protect the structural and species diversity of the forest.
  5. The harvest yield must be taken without bias in relation to the natural ratio of commercial and non-commercial trees to maintain the ecological and wood quality status of the forests.
8.2.3 Specific Controls
  1. The permissible selection harvest shall not exceed 50 % of the estimated forest growth (less any recovered salvage yield) predicted over a defined 15-year period ahead. This provides for large precautionary margins in initial yield projections, the accommodation of significant resource losses due to major natural disturbances and ensures that through partial subsuming of predicted natural mortality into the yield, the average age of the forest is not substantially altered.


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  1. Groups of trees must be harvested from gaps of no greater than 0.05 ha, a size that is similar to the natural gap formation scale.
  2. The minimum distance between gaps, to be measured from the edge of one gap to the next, shall be 25 m.
  3. The maximum number of gaps per hectare created by group selection harvesting shall be five in any felling cycle period of 10 – 15 years.
  4. The felling cycle for each operational compartment defined as the elapsed time between harvesting events will be a maximum of 15 years to ensure a spatial arrangement of felling gaps within the range of natural occurrence in terms of the density of gaps created over each hectare.
  5. To maintain forest productivity, reduce waste and protect fauna and biodiversity generally, the selection harvest will only include stems greater than 30 cm dbh up to the following maximum diameter limits for specific species:

    Red Beech: 110 cm dbh
    Silver Beech: 90 cm dbh
    Hard Beech: 110 cm dbh
    Mountain Beech: 70 cm dbh
    Rimu:




    No upper diameter specified (i.e. large rimu do not provide same habitat as large old beech trees. Large trees will still remain and provide for intrinsic values as with all tree sizes they will only be removed at levels in proportion to their actual presence.)
  6. Each working circle will be divided into several operational compartments ranging in size from 100 ha to 600 ha. To protect against excessive harvesting impact upon forest types or species of limited distribution, and to ensure a uniform supply of species mix and quality, tree removal may be undertaken in a number of such compartments concurrently within the following guidelines:
Maruia: Two - Five Compartments
Grey Valley: Six - Eleven Compartments
Inangahua Valley: Three - Six Compartments


8.3 Recovery Forest Harvesting

8.3.1 Additional Management Objectives

  1. To maintain landscape, soil and water values and improve wildlife habitat.
  2. To select groups of trees that will create gaps corresponding to natural spatial ranges for the species concerned and that will encourage stand stability consistent with similar unharvested forest types.


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  1. To encourage the establishment, growth, and survival of forest regeneration with minimal site manipulation.
  2. To harvest a percentage of the gross increment across specified diameter classes so as to maintain a productive near natural forest structure, with a diverse composition of species and forest structure, while returning the stand to a more all-aged structure.
  3. To return the standing merchantable biomass on the site to levels comparable with similar unharvested forest types and to take the opportunity where appropriate to improve forest timber quality and ecosystem productivity.

8.3.2 Operational policies
  1. Recovery forests will be silviculturally managed based on their past history and current status. Such management will fall along a continuum of options between those proposed for old growth forests and the maxima described below for even aged forests.
  2. Recovery forests and young even-aged stands suitable for harvesting operations are excluded from the productive area calculations of the working circle. Yields produced, if any, will be additional to the volumes produced from the remainder of the productive estate.
  3. Production thinning will be investigated as a means of breaking the cycle of 'even-aged' management required for the previously clearfelled and regenerating stands.
  4. Upon thinned areas gaining a more balanced, stable all-aged composition, the productive area and sustainable yield will be incorporated into the total of the "old growth" forests productive estate.

8.3.3 Specific Controls

  1. To maintain forest productivity and to protect biodiversity generally, the selection harvest will only include stems greater than 20 cm dbh up to the following maximum diameter limits for specific species:
    Red Beech: 110 cm dbh
    Silver Beech: 90 cm dbh
    Hard Beech: 110 cm dbh
    Mountain Beech: 70 cm dbh
    Rimu: No upper limit.
  2. Production thinning shall not exceed 12 % of the basal area of stems per hectare per decade to protect the stability and naturalness of the managed stand .
  3. The maximum number of trees per hectare which may be harvested is 50 per hectare/per cycle (including any salvage harvest).


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  1. The felling cycle for any stand of trees shall be a minimum of 10 years. A stand of trees is a definable area of trees of similar age and management potential within a compartment.
  2. To protect the genetic composition of the stands and assist in the creation of an all aged structure the maximum number of return thinning cycles to the stand will be five before any such stand or operational compartment must be managed as an old growth forest.
  3. For waste thinning silvicultural thinning where stands are not yet suitable for production thinning treatment, an adequate final crop stocking shall be maintained of no less than 400 trees per hectare for trees averaging greater than 12 metres in height and no less than 1000 trees per hectare when the height average is less than 12 metres down to a minimum average height of 4 metres.

8.4 Forest Operations Management

8.4.1 Specific Controls

8.4.1.1 Harvesting Operations
  1. Specially trained and experienced personnel will be responsible for gap and tree marking work, and employed for tree harvesting work.
  2. Directional felling techniques will be employed at all times to minimise damage to the residual forest.
  3. Helicopter extraction will be used in all cases for log extraction with the exception of tree removal within road lines and landing sites.
  4. Logs must be lifted clear of the canopy before horizontal transportation starts, to minimise canopy damage.
  5. Harvesting over steep (30°) shallow soils after prolonged wet periods shall be avoided.

8.4.1.2 Forest Regeneration.
  1. Coarse woody debris will be retained to provide important elevated and nutrient rich substrates on which regeneration can occur in the absence of ground disturbance or scarification.
  2. Regeneration within gaps shall be assessed by a walk over of at least 50 % of felling sites at least once every five years. As a matter of last resort except for rimu, planting of seedlings will be undertaken if regeneration has not occurred after 10 years. Seedling stock from local genetic sources will be planted at a rate of five seedlings per tree harvested.
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8.4.1.3 Roading
  1. The location of additional roading and landing areas shall be generally in accordance with the indicative proposed network shown on the maps in Appendix 1, Volume 2.
  2. No felling of trees across or into streams.
  3. No disposal of slash or disturbed soil within any stream, or streamside protection zone (i.e. within 10 m of medium priority stream or 20 m of high priority stream). A definition of medium and high priority streams is included in Appendix 5, Volume 2.
  4. No clearing of vegetation for new roads or landing areas to be undertaken within 20 m either side of a high priority stream, or 10 m either side of a medium priority stream. Road approaches to stream crossings will be excluded from this restriction within 50 m of a stream crossing point.
  5. No new roads or landings to be constructed within areas reserved from production shown on maps in Appendix 6, Volume 2.
  6. Maximum road gradient:       8° over any continuous 100 m section.
  7. All road and stream crossing construction to be undertaken in accordance with generic construction operational standards sourced from the TWCL Environmental Manual, Standards Eight and Nine, included in Appendix 4, Volume 2.
  8. Maximum batter height:       3 m over any 100 m continuous section.
  9. Maximum accessway (cleared corridor width): 10 m
  10. Wherever possible road aggregate will be obtained from within the forest and / or sources as free as possible from weed sources.
  11. TWCL will undertake road side spraying to control all noxious weeds on and within 20 m of any forest roads and landing sites.
8.5 Forest Ecological Management

8.5.1 Operational Policies

8.5.1.1 Forest Pests and Predators
  1. TWCL shall seek to maintain possum numbers at medium to low levels generally throughout its forests through contributions to regional and "local initiative" possum control programs, the regular sequential treatment of annual operations areas and where appropriate through the use of commercial operations.
  2. In areas where landscapes are identified as important, "Integrated Management Landscapes" by the Department of Conservation and include TWCL managed lands,


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          TWCL will work co-operatively with the Department to achieve the mutually agreed targets for
          pest control in these priority areas.
  1. Management will work with adjacent neighbours to seek to limit or have removed any domestic stock.
  2. High density populations of goats known to occur over limited locality ranges in particular forests shall be controlled by the most appropriate mechanism and in co-operation with neighbours.
  3. The applications of certain possum control strategies are known to have additional flow-on effects on rats, mice and stoats. These pests will remain secondary targets of the established techniques until successful means of multi-predator control can be proven. In the mean time, TWCL will actively invest in the area of predator control systems targeting stoats through their poisoned prey.
  4. TWCL will continue to provide assistance in-kind in the form of free access, use of forest blocks, and some labour toward continued trials of wasp control methods as part of the national effort.
8.5.2 Specific Controls

8.5.2.1 Forest Pests and Predators
  1. TWCL will undertake roadside spraying to control all noxious weeds on and within 20 m of any forest roads and landing sites.
  2. Between 5 and 10 % of annual net revenue derived from sustainable beech management of the forests subject to this application, will be spent on research, pest control and monitoring strategies.
  3. Dogs will not be permitted within the TWCL sustainable management estate during the kiwi breeding season.

8.5.2.2 Forest Diseases, Protection and Hygiene
  1. Management priority will be to recover merchantable volume from large natural disturbance sites in preference to the felling of live trees.
  2. Windthrow salvage clearance will be confined to the boundaries established by the natural event that led to the collapse except to the extent necessary to remove damaged edge trees.
  3. Mitigation of pinhole borer attack will involve basic hygiene measures including application of urea to stumps and cutting up of large woody debris.
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  1. If an adjacent marked tree is subject to accidental damage to the stem or large branch breakout during felling, that tree too must be felled irrespective of quality subject to maximum gap criteria. Such trees become part of the regulated harvest calculation
  2. Forests will be protected from fire under the auspices of TWCL's standard forest and rural fire control planning.
8.5.2.3 Nutrient Conservation and protection of Invertebrate Diversity and Habitat.
  1. Coarse woody debris will be retained on site for ecological and nutrient recycling purposes.
  2. Low grade harvest will not be removed for industrial wood use but rather retained on site as coarse woody debris.
  3. No more than 50 % by volume of stems in an individual windthrown site will be permitted to be harvested annually for ecological reasons (i.e. nutrients and regeneration enhancement).
8.5.2.4 Species and Habitat Protection
  1. Harvesting shall not be permitted in any of the areas reserved from production identified on the maps in Appendix 6, Volume 2.
  2. Only beech and rimu trees will be extracted for commercial use. Tree species requiring removal to facilitate road and landing site construction are not part of this control.
  3. Operations staff will be trained to recognise and report rare and endangered plants or fauna that may be present within forest working circles so as to accumulate a data base of distribution and occurrence.
  4. Operations plans will prescribe methods for identifying the presence of rare and endangered plants during marking in annual operational areas and make specific prescriptions to either eliminate or mitigate any potential adverse impacts of roading or harvesting on rare or endangered plants.
  5. TWCL will survey the actual frequency of felling of mistletoe host trees during sustainable management operations and research ways to mitigate the impacts of harvesting on mistletoe species through recognition and avoidance of felling host trees.
  6. In those forests where a presence of bats has already been established by survey, prime "bat habitat" zones will be defined within these forests and rechecked for presence of bat roost trees or bat concentrations prior to the commencement of harvesting operations and such key areas avoided.
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  1. Harvesting will be avoided during the breeding season for kiwi in those forest areas where kiwi presence has been established by prior surveys.
  2. Dead spars and snags will be retained except for safety reasons
8.5.2.5 Aquatic Environments
  1. Harvesting shall not be permitted within 20 m either side of streams identified as high priority, or 10 m either side of streams identified as medium priority, excluding road approaches to stream crossings. A definition of medium and high priority streams is included in Appendix 5, Volume 2
  2. Felling of trees across or into streams is to be avoided.
  3. All road and stream crossing construction to be undertaken in accordance with generic construction operational standards sourced from the TWCL Environmental Manual, Standards Eight and Nine, included in Appendix 4, Volume 2.
8.6 Protection of Cultural and Heritage Values

8.6.1 Specific Controls
  1. Harvesting and roading operations will be conducted to avoid damage to known historic sites identified on Map 5.
  2. Should any additional historic or archaeological sites be identified during harvesting and/ or roading operations, TWCL shall implement its accidental discovery protocol as outlined in Section 6.7.3 of this application document.
8.7 Recreation and Landscape Values

8.7.1 Specific Controls
  1. No harvesting within recreational or landscape protection areas shown on the maps in Appendix 6, Volume 2.
  2. No felling of trees across streams, walking tracks or access roads.
8.8 Term of Consent and Council Reviews

The application has been limited to a 35 year consent term rather than applying in perpetuity. TWCL is agreeable to provision for review of the consent conditions at any time during the 11 th , 21 st and 31 st years of operation. This will enable consent conditions to be altered or made more stringent in the unlikely event that monitoring discloses unforeseen adverse effects that require different conditions. In any event, as outlined below TWCL’s environmental

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management system requires it to adjust its practices to meet the management objectives set out earlier. There are also opportunities for external review (audits) which if necessary could provide a basis for a council initiated review of consent conditions. These audits are five yearly and it is proposed that any Council review follow such audits.













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