REPORT

to

BULLER DISTRICT COUNCIL



on

ECOLOGICAL ISSUES
of
RESOURCE CONSENT APPLICATION

by

TIMBERLANDS WEST COAST
SUSTAINABLE BEECH FORESTRY





JOHN L CRAIG


8 November 1999
.
.

     Professor John L Craig, Report to Buller District Council                                                               Page 2 of 18

.

EXECUTIVE SUMMARY


     Professor John L Craig, Report to Buller District Council                                                               Page 3 of 18


1        INTRODUCTION

Buller District Council ("the Council") has requested a review of the ecological aspects of a resource consent application by Timberlands West Coast Ltd ("Timberlands") for sustainable logging of beech forests. Timberlands seeks approval for 35 years to selectively log beech (and some rimu) trees from selected indigenous forests within the District. While the report doesn't specifically address the provisions of the Tasman plans, the general content of the report applies to operations in both Buller and Tasman forests and the Tasman District Council has reviewed the report and made comments.

While the report doesn't specifically address the provisions of the Tasman plans, the general content of the report applies to operations in both the Buller and Tasman forests and the Tasman District Council has reviewed the report and made comments.

In preparing this report the following information was reviewed between 15 October and 8 November 1999.

2         STATEMENT OF EXPERTISE

I have a BSc (Hons) (1st Class) degree in ecology from Otago University. My BSc included majors in both Botany and Zoology. My PhD is in ecology from Massey University. I have 30 years experience in New Zealand ecosystems. My specialist expertise is in biodiversity and ecosystem management and policy. My research has predominantly been in forest and wetland ecosystems and has involved the interrelationship between animals and plants. I also have experience with integrating ecological, economic and social information.
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I also have expertise in sustainability. I chair the Board of The Natural Step Environmental Foundation Aotearoa New Zealand and I am one of three trainers in New Zealand of The Natural Step sustainability approach to business.

Sustaining biodiversity when logging indigenous forests is a common topic of research internationally. I have followed aspects of this research in New Zealand, Australia and North American conferences. I have visited such forests in Australia, USA, Austria and Switzerland. I am active in indigenous forest conservation management and policy. For example, I have been a key participant in the design and implementation of island and mainland reafforestation programs such as Tiritiri Matangi Island. These and others have involved both replanting and the reintroduction of key animal species responsible for processes such as pollination and seed dispersal as well as issues of pest control. I am a frequent invited speaker to national and international fora on the integration of ecological, social and economic issues in landscape management.

3        CONTEXT

The following is provided as personal opinion of key underlying issues that influence my assessment of the ecological aspects of the application.

a) Sustainability

The Resource Management Act 1991 clearly defines sustainable management in a way that recognises the joint goals of use, development and protection. This application is a clear test of that philosophy. Whether the application deals adequately with the specific requirements of Sections 5, 6 and 7 are the key issues from an ecological perspective and there is scope for differences of opinion depending on personal interpretation of ecological values.

Many sustainability models require that humans can harvest up to the annual increment in growth of populations as long as they do not reduce the natural capital that was responsible for that increment. In addition, as a result of the Rio conference in 1992 there is a growing recognition that information is rarely adequate to be certain of all effects. The inclusion of a precautionary response as in more recent legislation and policy such as the Fisheries Act and the National Coastal Policy Statement has been the common response. The application to take only 50% of average annual growth can be viewed in this way as companies such as Collins Pine in the US and many European forestry companies have been taking 100% of annual growth and running such sustainability philosophies for more than 50 years (Nattrass & Altomare 1999).

Considerations of sustainability require concurrent considerations of ecological, social and economic effects. Where ecological considerations are taken in isolation, calls for lock up style protection and preservation often prevail in New Zealand. This is clearly an alternative publicly advocated by some with respect to Timberlands' beech forests.

     Professor John L Craig, Report to Buller District Council                                                               Page 5 of 18


The sustainability of this approach requires evaluation. Protection without pest control raises the question of whether under S7b of the RMA unregulated harvest by introduced pests is a more efficient use of the resource when compared with the regulated harvest through sustainable forestry.

Sustainability from an ecosystem approach requires some basic requirements although ecology as a profession has no widely accepted minimum requirements for sustainable use. In my opinion they would include: that there be no net loss of functioning ecosystems and that management should balance actions to ensure conservation of diversity and ecosystem processes. In other words, management should include both commercial and non-commercial species and that net take from the environment is not greater than annual energy storage.

Further comparisons seem appropriate when considering the sustainability of alternative resources when compared with those outlined in the consent application by Timberlands. Wood is a renewable resource dependent on renewable energy unlike its usual alternatives of steel, concrete and plastic. Moreover, the sustainability of indigenous forests under the proposed harvesting regimes is considerably greater than current techniques with plantation forestry based on introduced softwoods such as pine. Use of pesticides, effects of clear felling on soil and water quality, the inherent instability of monocultures as well as the low native biodiversity values of plantation forestry can all be used to support the concept of sustainable logging of some indigenous forests.

b) Conservation of New Zealand's Biodiversity

Biodiversity loss is considered New Zealand's greatest environmental problem (MfE 1997). Loss of ecosystem function is especially critical and current conservation policies are failing to deal adequately with this problem. Statistics such as the number of rare and endangered taxa relative to land area are often used to suggest that New Zealand has one of the worst conservation records of any country (eg see Glasby 1991). The draft New Zealand Biodiversity Strategy (Anon 1998) describes the ongoing loss graphically. Despite this, New Zealand is also seen as a leader in conservation with over 30% of the land area in formal reserves. The international target suggested through the Biodiversity Convention is 10%. The paradox of New Zealand as a leader and as a worst example is poorly articulated in the public debate.

Whereas the loss and fragmentation of ecosystems, especially forest, has contributed to the problem, the overwhelming cause of decline is the presence of introduced species. Indeed, the proposed Buller District Plan (S4.8.4), Timberlands Resource Consent Application and a multitude of conservation related publications about New Zealand native ecosystems record that the presence of introduced pests, especially introduced mammals plus, in beech forests, wasps, are the biggest factor threatening the "protection" and "life supporting capacity" of indigenous ecosystems. The plants and animals and soil organisms are in a dynamic equilibrium but the effects of introduced animals on these different organisms occur at vastly different time scales. Indigenous animals tend to be

     Professor John L Craig, Report to Buller District Council                                                               Page 6 of 18

lost early whereas trees will remain for hundreds and even thousands of years longer. Hence retaining the remnant architecture of forests is simple, retaining a living dynamic forest is not.

New Zealand conservation has been confused by these issues for years (Hartley 1997, Craig 1998a & b). Large areas of ecosystem remnants have been separated from most forms of human activity on the belief that this simple approach of reservation will "protect and preserve" indigenous biodiversity. Moreover, conservation has been practiced outside a sustainability framework. This has meant that reserving areas has had precedent and issues of use and the source of funds necessary for sustaining ecosystem processes has received little attention (eg Hartley 1997, Craig 1998a & b). Moreover, active intervention has largely been species based with a preoccupation with national rather than local issues.

The outcome of this is that conservation management has largely become the neglect of remnant ecosystem skeletons (current Department of Conservation spending is adequate to control possums on less than 20% of the estate and predator control occurs on less than 5%; DoC 1998). Industry, commerce and the public see conservation as the role of government and something that happens somewhere else and is funded by government welfare. Moreover, conservation is set up in ways that defy accountability (Craig & Stewart 1994, Hartley 1997, Craig 1998a & b).

Effects based legislation such as the RMA do not deal well with biodiversity threats because it is largely impossible for anyone to argue that the ravages of pests are an effect of any proposed activity because they are now almost universal. Moreover, current practice tends to place the burden of cost for conservation on current landowners while urban people and those with areas already devoid of most indigenous biodiversity values apparently carry no responsibility. One possible solution to this conundrum is the concept that biodiversity could pay for itself. This application is an example of this approach.

Forestry typifies many of these issues. In many developed countries, forestry is based on native species that have been sustainably logged for decades to centuries. Conservation and production are complimentary. In contrast in New Zealand, conservation is viewed as incompatible with production activities other than science and some tourism. Indeed at the recent native forestry conference at Waikato University, a number of territorial local authority staff acknowledged that if people planted native species for forestry, there would be no guarantee that they would be able to log them in the future. As long as conservation and production are seen as incompatible activities, and native biodiversity is prevented from earning its way, New Zealand's biodiversity will remain at risk (see Craig 1998a & b for detail).

There is a marked paradox in the prevailing conservation stand. Native biodiversity is too valuable to include in markets yet it is not valuable enough to earn its own way. As long as biodiversity is excluded from markets solely because of a preservation philosophy it will never be seen as valuable enough to justify the massive expenditure necessary to

     Professor John L Craig, Report to Buller District Council                                                               Page 7 of 18

control pests and hence ensure its long term future. This Consent Application offers a chance to compare preservation and sustainable use philosophies. The life supporting capacity of these forest ecosystems relies on the maintenance of functioning systems not the preservation of remnant structure. For these reasons a substantial trial of an independently audited and experimental logging as part of sustainable forest management has the potential to enhance sustainability and conservation outcomes in ways that are not occurring elsewhere in New Zealand.


4        SUSTAINABLE BEECH FOREST MANAGEMENT

The consent activity of "sustainable beech forest management" is management of a forest ecosystem. This means that Timberlands needs to manage biodiversity, not just the trees and maintain or preferably enhance ecosystem values. This is to ensure maintenance of all species necessary for forest function such as pollination, pest control, nutrient balance, soil formation, and carbon storage including timber production.

The proposed logging regime has advantages over comparable logging schemes anywhere else in the world. The conservative take of 50% of average annual increment based on long term measures of forest growth suggest that violation of long term sustainability is highly unlikely. Leaving 50% of average annual increment is a large safety margin that ensures that harvesting will not threaten the long term potential of the resource.

The use of helicopter extraction provides advantages over other forestry options as soil and litter modification will be minimal. The associated major reduction in road construction is especially valuable. Not only does this reduce destruction and fragmentation of forest ecosystems, it also reduces long term use of fossil fuels.

The upper and lower limits to the diameter of trees logged minimises interruption of the more sensitive ends of the growth cycles. Logging across the remaining size classes in proportion to their abundance, taking trees regardless of their marketable wood value and recovering naturally fallen trunks ahead of harvesting live trees are important silvercultural practices in line with long term maintenance of ecosystem structure and processes. Retaining dead trees and leaving all non wood components for natural breakdown ensures ecosystem values for other species.

It is noted that there is no upper limit for rimu, reasons are given and in my view are acceptable especially as rimu are a minimal component of proposed logging for most of the forests. Even in the forest types where rimu constitutes a larger proportion (eg Type 2E in Inangahua Working Circle), that trees will only be taken in proportion to their occurrence means that rimu of all sizes will remain. It is also noted that there is provision for replanting should regeneration of rimu be inadequate relative to harvest. The further provision in this forest type (p57) that no operations will be undertaken until more complete data are available.
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The agreed retention of trees that constitute a minor component of the forests such as rata, miro and kahikatea but which are of known importance for native fauna is important for maintaining biodiversity values

Planning for variable canopy gap size is realistic and necessary. Any attempt to prescribe a maximum number of trees or other detailed measures are unnecessary. The number of trees taken at any site will relate to diameter, and the need to take any individual tree damaged by felling a neighbour. Restrictions on total gap size and total harvest rate is adequate to ensure integrity of forest blocks. Larger gaps up to the maximum size of 0.05 ha will be necessary where damage to adjacent trees occurs and to ensure adequate germination of red beech.

The underlying growth model and its input values of species numbers by diameter class, the harvest cycles of 10 years for recovery forests and 15 years for old growth forests, the distance between gaps, the number of gaps per hectare, the size and number of compartments, the number of return thinning cycles and the maximum of 12% basal area production thinning of recovery forests appear well justified and worthy of trial. The typing of forests by ecological characteristics such as species ratios is valuable for refining management operations. The overall conservative take of 50% of average annual increment as well as adoption of an adaptive management regime provide considerable safeguards.

The lack of maximum canopy gap size and distance between gaps in recovery forests appears to be anomalous. There appears no reason why gap size or minimum distance between gaps should be any different from old growth forests. A lack of prescription of total number of gaps may be justified given the very high stem densities in these forests. I recommend that a clear experimental design be established with paired trials and a range of harvest ratios to ensure that future management receives the greatest information input possible.

The suggested final stem numbers of 400 trees per hectare for trees averaging greater than 12m and no less than 1,000 stems per hectare when the height average is 12m or less will still leave stem ratios markedly higher than old growth forests. These numbers appear conservative and if accompanied by maximum gap size and distance between gaps should not result in adverse effects.

The proposed monitoring and audit programs appear reasonable and acceptable. Six monthly physical and environmental audits by MAF, as well as annual reporting by the company plus 5 yearly independent audits to Parliament, to the consent authorities and available on the company web site will ensure that the information is available to all who have an interest.

Pinhole borer are identified as an important threat to forest health. The proposed hygiene measures as well as the subsequent monitoring appears appropriate.
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The 35 year time frame of the consent will allow monitoring of the detail of the underlying model and management techniques. Given the considerable safeguards built into the proposed program, (conservative harvest, frequent monitoring and independent audits) it is likely that minor changes and even increased harvesting may result. The process by which Timberlands plans to make changes and how it will determine the magnitude of these changes would benefit from clearer disclosure. Disclosure of changes undertaken and the basis for these through the monitoring and audit programs is likely to be adequate.

Long term cumulative effects of logging over a 35 year consent require comment. Long term harvesting will open forest canopy slightly as it is likely that there will also be compensatory growth by neighbouring trees. The forest will comprise younger trees on average and faster growth than unlogged forests. Seedling and shrub growth is likely to increase. Species reliant on lower light of closed old growth forests will decline slightly while light requiring species will increase. My experience in northern forests is that bird numbers will also increase. Whether these are considered adverse effects or normal ecological responses partly is a matter of personal value systems. The logging regime is built around an attempt to mimic natural gap formation and associated ecological responses. For these reasons, it would be difficult to argue that the changes are detrimental or adverse. In recovery forests, logging over 35 years should result in a more diverse age range. Again arguing that this is an adverse effect or a rehabilitation requires more input from a diverse range of stakeholders. These stakeholders include government and iwi, local through to international communities, ecology and economics. To my knowledge this input has only begun. Until logging has been undertaken for a period of up to 35 years and results known, the difference between logged and unlogged forest ecosystems is a matter of opinion.

An important part of this experimental attempt at sustainable beech forest management is adaptive management. This is management based on the knowledge that sustainability is a journey and that predictions of single end points is not possible given current understanding. Informed decision making requires information of effects with an ability of management to respond appropriately to enhance positive and remove adverse effects. This requires a combination of flexibility plus adequate audit and monitoring that allows mutual trust among stakeholders. For this reason it is important that useful and quality information will be available from the audits and monitoring to assist all stakeholders evaluate present and future options.

The universal take of 50% of net annual increment is conservative by international standards but a useful starting point. I fail to see how Timberlands or other stakeholders will be able to conclude more than yes or no options from a single cutting ratio, however. While there may be value in retaining the average of 50% over all forests, variable takes of say 30%, 50% and 70% will provide better information on the long term effects of logging. (These suggested ratios have no more logical basis than many others are purely indicative of the value of a wider range of options than the proposed 0% and 50%). How much a range of options provide in terms of combined ecological, economic and social

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returns will allow better future planning for sustainability. As the Parliamentary Commissioner for the Environment (1995) stated "New Zealand could lead the world in managing indigenous temperate forests provided that sustainable management principles are followed". My contacts suggest that the world community is watching this experiment because it appears the most sustainable methodology being trialed anywhere. For these reasons world sustainability stands to benefit if the experiment proceeds.

The greatest deficit in the application is the failure to declare clear pest control targets. Timberlands are requesting consent to "sustainably manage beech forests" and undertaking this management without adequate pest control will result in adverse effects. Without pest control, animal biodiversity will continue to decline and eventually threatens the long term sustainability of the forests. The application appears to recognise the need to conserve and manage a range of ecosystem values in addition to the marketable resource of trees. Failure to commit to declared pest control targets appears an oversight. (See below for more comment).

Given current information, the key issues (S5.3.2.4.2) in the application relate to satisfaction of aspects such as "effects on the life supporting capacity of air, water, soil and ecosystems", "effects on habitat of any threatened or protected species", "effects on water bodies", protection of areas of significant indigenous vegetation or significant habitats of indigenous fauna" and "effects on intrinsic values of ecosystems". These are discussed in turn.

a) effects on the life supporting capacity of air, water, soil and ecosystems
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Removal of 50% of annual increment in growth will reduce some communities. The effects are likely to be negligible relative to the effects of introduced pests. Effects on basic ecological functioning of the forests is likely to be minor. Pest control that enhances ecosystem functioning in the forest ecosystem will provide adequate mitigation for long term cumulative effects (see Suggested Conditions below).

b) effects on habitat of any threatened or protected species


c) effects on water bodies
d)   protection of areas of significant indigenous vegetation or significant habitats of indigenous fauna



e) effects on intrinsic values of ecosystems

Under S7 of the RMA, comment on "the efficient use and development of natural and physical resources" and "any finite characteristics of natural and physical resources".

7b the efficient use and development of natural and physical resources

7g any finite characteristics of natural and physical resources
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5          ISSUES

a) Pest Control:

Most of the above deals largely with the specific activities of logging and road construction. The activity that this resource consent application covers, however, is far broader and is described as "sustainable beech forest management" (Vol 1: ix). This broader term is appropriate given Timberlands commitment to the principles of the Montreal Process and the Forest Stewardship Council (Vol 1: 7 - 8). The first and third criteria of the Montreal Process (Overview Plan for Beech Sustainable Management p169) require "conservation of biological diversity" and "maintenance of forest ecosystem health and vitality". Broadly these are in accord with S5.2b of the RMA. The consent application (Vol 1: 6) repeats the definition of sustainable forest management from the Forests Act clearly reinforcing the requirement that "the forest's natural values" are retained.

Achieving sustainable beech forest management requires control of pests such as possum, goats, deer, rats, mustelids, cats and dogs that threaten ecosystem processes and some species. Dogs are adequately covered but the consent does not adequately cover the other aspects. Specific targets are required. Levels of pest control equal or less than occurs on the public conservation estate do not allow sustainable conservation of biodiversity or safeguarding the life supporting capacity of (forest) ecosystems as is readily documented in New Zealand's draft biodiversity strategy.

Ecosystems are dynamic functioning systems that rely on a wide range of biodiversity to retain both their function and their natural character (see S4.8.1 & 4.8.6 of the proposed Buller District Plan). Soils are formed by these interactions, water quality and intrinsic values rely on retention of the full range of biodiversity not just the trees. While beech trees are wind dispersed, many other plants in these forests require animal vectors such as birds to pollinate flowers and disperse seeds. Other species provide pest control. Long term health and resilience rely on conservation of all species and their interactions. Introduced pests such as mammals and wasps represent the greatest threat and hence for "sustainable beech forest management" pest control appears mandatory.

Timberlands sustainable forest management including logging appears fully sustainable by international standards. There are a range of minor effects but the overwhelming deleterious effects to the ecology of these forests come from the presence of introduced pests. A declared level of control of these pests is necessary to avoid the adverse effects of management without pest control. Additional control would clearly mitigate any minor and cumulative effects of most other company activities. Control to the level of the public conservation estate would be the minimal requirement. There is a suggestion (Vol 1: xxv) that this will be exceeded throughout the Timberlands forests but there is no clear statement to this effect elsewhere in the document. If Timberlands is prepared to commit to a level of pest control that exceeds that of the Department of Conservation in the adjacent public estate, it would be possible to state that the effects of the application have the potential to be overwhelmingly positive. The undertaking in Timberlands' "Objectives of Management"(Vol 1:7-8) 'to safeguard the life supporting capacity and intrinsic value of forest ecosystems' and 'to sustain the potential for the forest resource to meet the needs of future generations' are not possible without a commitment to pest control.
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Current commitment to pest control is not easily understood. There is (Vol 1, p82) a commitment to between 5% and 10% of net revenue to pest control, ecological research and monitoring. Plus "regular systematic control operations in conjunction with operation areas and along road lines", "commitment to cooperative management" in association with DoC, and "a more general application of multi-predator control schemes if research defines safe and appropriate systems". In S8.5.1.1 (p104) (1) Timberlands undertake "to maintain possum numbers at medium to low levels" and in (2) "high densities of goats will be controlled" yet these levels are not defined in a way that can be audited.

In addition, the commitment of net revenue can not be considered adequate. Pest control needs to be included as necessary operations and hence deducted before net revenue is calculated. A further commitment of 5 – 10% of net revenue to increase control and research to ensure greater biodiversity outcomes could be seen as suitable mitigation for many of the minor effects that logging may have on the forest ecosystem. Without economic information, the level of action that will flow from this commitment can not be determined (see PCE 1998 for similar comment).

Given S7f of the RMA there is a need to have regard to the "maintenance and enhancement of the quality of the environment as well as S6c where there is a need to recognise and provide for the "protection of areas of significant indigenous vegetation and significant habitats of indigenous fauna" it could be argued that pest control throughout the sustainable management estate is needed. Clearly the level required should not place "an unfair or unreasonable burden" on Timberlands. However, given the very low level of pest control on the public conservation estate (see above), a level that on average exceeds that must be seen as meeting the requirements of the RMA.

Weeds are mentioned especially in relation to new roads. Timberlands undertake to control "all noxious weeds" near roads and landing sites. New Zealand's weed legislation is based around an agricultural economy and hence legislation is not adequate for indigenous forestry operations. Many noxious weeds are of little long term consequence in a forest ecosystem whereas a number of environmental weeds can be disastrous. Timberlands should eliminate all environmental weeds. Environmental weeds are those that threaten the functioning and integrity of indigenous forests. Such weeds include pampas, honeysuckle and many others. The Department of Conservation has lists and pamphlets on these and they should be made available to ground staff responsible for weed control.

Weed control adjacent to roads and landing sites will be within 20m and this should be adequate to deal with the effects of roads.


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Possible Conditions :
  1. As mitigation for the numerous minor effects that the sustainable forestry will have, and as a requirement of ensuring sustainable beech forest management, Timberlands should be required to set a declared target for pest control that exceeds the levels of the adjacent Public Conservation Estate, and that these costs be included as operating expenses. Control should occur immediately prior to bird breeding.
  2. As mitigation for the adverse effects of total ecosystem removal associated with the construction of roads and landing pads, Timberlands should be required to restore a greater area (e.g. at least five times) than that removed in any year. The multitude of 5 times is somewhat arbitrary but is used to recognise that enhancement planting of one hectare does not replace the complete removal of one hectare of functioning forest ecosystem to construct one kilometer of 10m wide road.

    Mitigation for the adverse effects of road construction can not occur locally but could take place at other areas of the sustainably managed estate. Such areas can be negotiated once the consent is approved.

    Other options for restoration as mitigation could include high level pest control in areas thought to contain South Island kokako. The Department of Conservation has considerable experience in the North Island kokako forests of the levels of possum and rat control needed to protect this species.


b) Adaptive Management

Timberlands have adopted adaptive management of the forest ecosystem (see discussion above). This is a flexible approach to management that will allow modifications to suggested practices that is responsive to new information. This is especially important because it is difficult to determine the specific effects of forest management and especially the effects of sustainable logging. Hence adaptive management is appropriate and is in line with the approach of other resource users and conservation agencies. There are two issues however. What is the proposed structure of this management and how will decisions be made? Moreover, where the same level of logging is to be undertaken everywhere, how is it possible to test the effects of the model and know that the proposed changes will achieve the desired effects? My preference would be for logging a variable proportion of average annual increment and observe the effects and build these into future management. A scientifically monitored take of say 30%, 50% and 70% (averaging 50% as in the Consent Application) could show more than a uniform harvest.

Regardless of whether harvest levels vary from a uniform 50%, there is a clear need to stipulate what information will be used to alter management, what are the time frames for action and what is the process for this?, It is important that the process is not too tightly defined however and hence it may be difficult for Timberlands to provide much detail prior to beginning.
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c) Monitoring

The Application contains some useful suggestions for ongoing monitoring. The use of paired catchments where one is logged and the other not (even if this is in the Public Conservation Estate) will provide invaluable data on ecosystem parameters. To ensure the comparisons are not confounded by non-logging differences, levels of pest control in the paired catchments should be the same. If my suggestion of more varied harvesting ratios is adopted, comparisons across these and with unlogged plots would be required. Exactly what information will be collected and who will audit the sustainability of operations is also not clear. The suggestion (pp107-8, Fig 4) that Council establish 5 yearly review of audits and that there be an "Independent Parliamentary Oversight Body" should be adopted (see PCE 1998 for supporting comments).

Five minute bird counts have been established to monitor bird numbers in selected forests. While the application acknowledges the problems of this methodology, there is value in adding a more robust technique. Five minute counts do not provide estimates of abundance and are of limited validity for comparing between sites. They do provide measures of conspicuousness which may alter with logging even though abundance does not. Use of a more robust technique of distance counts for selected species is recommended as well. Choice of common indicator species such as bellbird and robin is suggested as these species will reflect changes in ecosystem health at the canopy and ground levels respectively.

There is some discussion of invertebrate monitoring and a conclusion that little will be gained as many species are unnamed and interpretation of results will be problematic. Some basic level of monitoring could be useful to follow trends in invertebrate diversity, numbers and size. Specific identification is not necessary. However, it needs to be realised that most changes are likely to relate to control of predators such as rodents rather than to forestry. If additional mitigation is required, invertebrate surveys could be used but I do not believe it will add much relative to the cost of undertaking the surveys. Monitoring of density and population health changes further up the food chain such as birds and trees is more useful.

Other suggested monitoring conditions for pin hole borer, regeneration and reporting of paired plots appears reasonable. Similarly the provision of reviews of the resource consent at 11, 21 and 31 years similarly appear reasonable as the effects of specific activity of logging will be difficult to determine in the short term. Pest control can produce effects on a much shorter time frame and densities of indicator pests such as possum and rats should be monitored and reported at least every five years. Bird monitoring should be reported in the same time frame.

d) Reporting

Reporting and monitoring is generally well covered in the application. Additional or modified reporting should include the following.
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6         RECOMMENDED MINIMUM CONDITIONS:
  1. Clear commitment to pest control that exceeds the average level of control on public conservation estate.
  2. Clear commitment to restoration of degraded river flats and other suitable areas as mitigation for the adverse effects of road and landing pad construction. Area restored annually to be at least 5 times the area of forest removed by making of roads and landing pads.
  3. Acceptance of independent audits of forestry operations to assess long term sustainability. Accept Timberlands suggestion of minor audit annually but a major audit at 5 yearly intervals.
  4. Declaration of process involved in "adaptive management" within one year.
  5. Declaration of procedures for sustaining mistletoe and bat populations within two years.
  6. All conditions suggested by Timberlands West Coast.

7         VARIATIONS:
  1. Alter logging regimes to take a mix of 30%, 50% and 70% of average annual growth. Monitoring the different effects and retaining an overall take of 50% should remain.
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  2. Add distance monitoring of selected bird species in addition to 5 minute counts. These counts using standard international methodology should be used as part of the suggested "paired trials".

8         REFERENCES:

Anon. 1998. A Draft Biodiversity Strategy for New Zealand: our chance to turn the tide. DoC & MfE, Wellington

Craig, JL 1998a. Managing bird populations: for whom and at what cost. Pacific Cons Biol 3: 172-182.

Craig, JL 1998b. An economic analysis of conservation strategies for New Zealand. Agenda 5:311-22.

Craig, JL & Stewart, AM. 1994 Conservation: a starfish without a central disk? J Pacific Cons Biol 1:163-168.

DoC 1998. Restoring the Dawn Chorus: Department of Conservation Strategic Business Plan 1998 - 2002, Wellington.

Glasby, G. 1991. 'A Review of the Concept of Sustainable Management as Applied to New Zealand', J Roy Soc New Zealand 21: 61-81.

Hager,, N. & Burton, B. 1999. Secrets and lies. Potton Publishing, Nelson.

Hartley, P. 1997, Conservation Strategies for New Zealand, New Zealand Business Roundtable, Wellington.

Nattrass, B. & Altomare, M. 1999. The Natural Step for Business: wealth, ecology and the evolutionary corporation. New Society Publishers, British Columbia.
Go to document 2 of Professor John Craig's evidence.