|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.|
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Monitoring of the forests is to be undertaken to achieve the objective of ecologically based sustainable management. According to an emerging international consensus this objective can be accepted as being met if certain criteria listed below are met in full on any one particular site or on a regional landscape basis.
The criteria are the:
Within the context of New Zealand law, the Resource Management Act 1991 (Part II) also requires that similar such criteria be met and any adverse effects upon them be avoided, remedied, or mitigated. To demonstrate compliance within the management system, certain key indicators will require monitoring. During the Crown managed submission process in October 1998, there was some criticism that TWCL had not been specific enough about its monitoring program. TWCL seeks to clarify its position in respect of monitoring in the following sub-sections.
The international criteria and the extent to which these nationally scaled criteria and indicators can be met by the TWCL monitoring system are summarised in section 6.4 of the TWCL Sustainable Management Overview Plan.
The prime tools and strategy for monitoring is defined below.
9.1.1 Working Circle Monitoring
These represent continuous natural ecosystems with full altitudinal and bathymetric sequences encompassing a range of land tenures, which are focuses for biodiversity management on the West Coast. Initial areas in the TWCL estate will be the eastern Paparoas and Station Creek in the Maruia Valley.
In general, these ecosystems are deteriorating due to browsing and predation by introduced animals, weed invasions, and fragmentation. The policy, outcomes and restoration operations will be co-ordinated co-operatively with the Department of Conservation and other participating landowners. Principally, these will involve:
This will involve replicated, paired sites where intensive monitoring and research of harvesting impacts will be focused. These sites include harvested as well as undisturbed forest or naturally disturbed forest as a control.
Outside research providers will also be encouraged to work at these sites to build an intensive knowledge base of the ecosystem.
9.1.4 General Issues
Avifauna remains one of the key monitoring areas in terms of the effects of any management. However, because key threatened species are already sparse and severely at risk from predation from rats and stoats it will be extraordinarily difficult to isolate any population variations due to timber management from background environmental variation which can be substantial from season to season. A monitoring strategy (Buckingham, 1997) based on intensive and repeated five-minute bird counts has been devised. However, there remain significant concerns as to the reliability and effectiveness of this method for providing absolute indices, repeatable over time with sufficient sensitivity to show true trends. This especially applies in variable country and Buckingham (pers comm, 1997) has commented that resources directed on predator research may be a better course of action.
An intensive avifauna sampling approach is already operating in rimu forests at Okarito Forest in South Westland. The results of a re-measurement program re-started after a twelve year break, covering before and after harvesting were completed in March 1999. The results gave no grounds for concern about decline in species as most changes were within the range of seasonal and annual variation. Robin, riflemen, tits and parakeet show a measured increase over time, (James, pers comm). These results may assist in determining further application of bird monitoring systems. As a minimum, the extensive benchmark surveys conducted over much of the estate will serve to provide a basis for very coarse comparisons over long intervals and at least one site in beech forests will be monitored in similar fashion to Okarito to confirm trends related to avifauna under a managed forest scenario.
Consideration has been given to the capability and usefulness of monitoring invertebrates. The conclusion drawn from advice given is that such a proposal falls into the situation where there is no established systematic approach yet applied in New Zealand. Much of the invertebrate fauna of the nation is yet undescribed and the extraordinarily expensive process would yield an invaluable database which would nevertheless be unable to be benchmarked against surrounding lands. It is very unlikely that significant progress will be made in surrounding lands in the near future.
Because invertebrate fauna serves an essential ecosystem function, targeted research will be used to evaluate and interpret the impacts of the management system on ubiquitous fauna. Such research has been underway for two years (Evans A, Entomology Division, Lincoln University). The results to date have indicated no significant differences between control, treatment and natural forest gaps. The study will be scaled up to test for any impacts.
There are some, usually larger, invertebrate fauna (none identified in the beech estate) that are known to be rare or threatened. Predation is thought to be the prime cause. It is expected that any benefits derived from the avifauna research may also be conferred upon this segment of the ecosystem. To this extent the research into predation will also seek to include one or two
target ‘macro-invertebrates’ if program funding is supported in part by FRST Public Good Science Funds.
Any extraction process has the potential to remove nutrients from the system. However, wood harvesting over long rotations will be at very low levels relative to other land-based activities. No systematic New Zealand wide monitoring systems have yet been implemented. As a coarse indicator of soil status, pH has been collected from soil samples in the PSP system. The approach noted in section 9.1.3 (5) above is being developed around internationally recognised criteria and as such fits well with the monitoring objectives of this proposal. Advice given nevertheless suggests the impacts of log removal as proposed will be too low for wide scale monitoring to detect any changes. Instead a more localised intensive research based program may be able to prove or disprove any adverse effects over time.
9.2 Audit Procedures
Section 1.4 of the TWCL Sustainable Management Overview Plan states that there will be an audit process undertaken on a five yearly basis to confirm that management and operational practices are inline with the prescribed requirements.
Submissions from the public during the Government public comment process indicated that there were concerns about the depth and comprehensiveness of the proposed audit process. Some of this probably arose from a lack of detail in the plans as to the other audit structures operating within TWCL. Nevertheless audit is a very important element in TWCL’s adaptive management system and TWCL has responded to clarify and improve the audit process.
9.2.1 Clarifying the Current Process
TWCL operations are subject to a number of audit processes that have developed to fulfil the objectives of a variety of stakeholder interests. While TWCL is currently exempt from the legal requirements of the Forests Amendment Act, its plans are subject to “compliance approval” as if they were bound by the Act. (Current changes to the legislation will shortly bring TWCL under this Act.) MAF undertakes this process, in dialogue with the Department of Conservation, as if it would apply to private landholders.
In addition, TWCL operations are subject to 6 monthly field checks by MAF, 6 monthly physical and environmental audits by external auditors and more comprehensive 5 yearly audits. These five-year audits do include ecological as well as forestry matters as prescribed in the management plans and do make recommendations for improvement as well as record matters of compliance. The general natures of the Audit processes are illustrated below in Diagram 3.
9.2.2 Five Yearly Audit
An independent audit of all key operations will be undertaken five yearly by an agency fully competent in forestry and environmental practice. With regard to TWCL’s responsibilities under the RMA, the scope of the audit shall be:
On completion of the audit, an audit report will be prepared by the auditor which will be made available to the Crown, the consent authority, and the public, through its website and Annual Reports.
9.2.3 Proposed Audit Structures
At the time the Beech Management Plans were written it was signalled that TWCL would be seeking to attain ISO 14001 Environmental Accreditation. TWCL has subsequently gained accreditation under that standard. This process enables auditing of all the standards inclusive of the prescriptions (rules) in the beech plans that the company has undertaken to meet. It also requires an automatic compliance with all relevant laws and the public disclosure of audit results.
Under the present audit structure, the ISO process represents an additional layer of audit. However the very nature of its structure should enable most current processes to be subsumed within the ISO framework. TWCL proposes over time to move toward a more streamlined process that seeks to attain a streamlined cumulative flow of checks and audits all of which are managed through the ISO 14001 structure (see Diagram 3). This structure would also be compatible with the introduction of a further independent third party forest certification system such as the Forest Stewardship Council.
TWCL are negotiating with its owners in respect of this matter now. Should the owner not wish to accept these proposals then as a minimum the structure illustrated in Diagram 3 will prevail.
9.2.4 Independent 3 rd Party Oversight
Some submitters to the Government process sought the inclusion of independent third party oversight of the management system in the Audit processes. TWCL has signalled to the Crown that it is not adverse to such a body and that it could be effectively incorporated within the proposed audit system.
Such a system could look like that shown in diagram 4, however any decision to proceed is a matter for the Crown.
Pages 116 to 120 inclusive contained maps that have already been displayed in chapters above.
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