(in terms of Policy of Proposed Buller District Plan)


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Buller District Council
6 Brougham Street
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Professor John L. Craig
School of Environmental and Marine Sciences
The University of Auckand

Auckland UniServices Limited
The University of Auckland
Private Bag 92019
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Report Issued 19 November 1999

Professor John Craig
Professor of Environmental Management

     John L Craig,     Significance of Forest Areas.                                                                                   Page 2 of 7


Buller District Council ("the Council") has requested whether the forests specified in a resource consent application by Timberlands West Coast Ltd ("Timberlands") are significant in terms of the criteria in Policy of the Proposed Buller District Plan. Timberlands seeks approval for 35 years to sustainably manage beech forests within the District.

In preparing this report the following information was reviewed between 15 October and 22 November 1999.

My full qualifications are listed in the report to Buller District Council on ecological aspects of the consent application. I have not undertaken ecological research in any of the forests and rely on the results of earlier surveys and my understanding of forest ecosystems in general and in New Zealand in particular.

C          POLICY

Policy relates to criteria for assessing Section 6c of the RMA. S6 lists matters of national importance that require the consent authority to recognise and provide for when considering the management of use, development and protection. S6c refers to the protection of areas of significant indigenous vegetation and significant habitats for indigenous species. Each of the nine criteria listed in the policy will be considered in turn.
Representativeness: The area is one of the best examples of an association of species which is typical of the ecological district.

     John L Craig,     Significance of Forest Areas.                                                                                   Page 3 of 7

The forests are part of a number of different ecological districts. Each forest in the application is adjacent to land in the public conservation estate managed by the Department of Conservation (DoC). As the application points out (Vol 1: ) the beech forests subject to the consent have already been assessed in the process of the Forest Accord. Those areas of special significance were put under DoC management at that time. Indeed 58% of the forests (Recovery Forests) have been modified in the past and hence could not be considered the "best examples" of an association of species. Similarly, given the process of the Accord and the subsequent process by Timberlands where further forest areas (8% of the estate; Vol 1:63) are to be reserved from production (Vol 2, Appendix 6), it is difficult to argue that any of the forests targeted for sustainable management are "the best examples".

It is important to note concern by some ecologists for the concept of "representativeness" (N Mitchell, University of Auckland, pers. comm.). This concern is built on the understanding of the dynamic nature of ecosystems and the artificiality of attempting to preserve an association of species which is undergoing change. This view would argue that sustaining natural processes is the key issue. Given the pervasive adverse effects of introduced pests, reserving a forest without adequate pest control can not constitute protection.

Distinctiveness: The area has indigenous species or an association of indigenous species which is unusual or rare in the ecological district, or endemic, or reaches its distribution limit.

Given the procedures outlined in 1 above, it is difficult to argue that any of the forests have a special distinctiveness that is unusual or rare in the respective ecological districts. The use of Twinspan analysis (Vol 1: 62) by Landcare Research would have identified any special associations of vegetation.

Intactness: The area has a cover of predominantly indigenous vegetation, is little modified by human activity, and is not affected in a major way by weed or pest species.

There is little doubt that the forests subject to the consent application are areas of predominantly indigenous vegetation. A significant proportion of them have been modified by human activity (Recovery Forests) although the extent of modification varies considerably. All are relatively free of weeds but all are affected by animal pest species.

Given the mixed response to the different parts of this criterion, it is valuable to consider how Council should interpret this issue. The forests of the Buller District do contribute to the distinctive character of the region because of the extensive areas of intact forest cover. For many people, it is difficult to distinguish forests that have been modified previously and those that are largely unaffected by human activity. The intact canopy is the dominant criteria and the question is whether this is at risk from activities proposed in the consent application.

     John L Craig,     Significance of Forest Areas.                                                                                   Page 4 of 7

The applicant has set aside some small forest areas purely to retain the visual intactness of the forest from major roads (Vol 1: 48-49). In addition, the proposed logging is based on mimicking natural gap formation and hence will still retain an intactness that will not be discernible by most people. Regardless of the values of people, the intent of S6c is more toward the effects on fauna and flora and hence it is important to ask will the consent activities cause any effects for the animals and plants.

For all intentions, the logging associated with the sustainable management will create small canopy gaps but will retain the overall structure of the forest including the relative intactness of the canopy. There is no evidence that the dispersal of species or the ecosystem functioning will be altered in anything other than a minor way. In contrast, the construction of roads will alter the ecological intactness of the forests. While roads that are infrequently used and only 10m wide will have no discernible effect on birds or most plants, movement of flightless invertebrates, frogs and possibly some lizards will be adversely affected by roads. These effects will be minor and localised and certainly do not threaten population viability.

This criteria also addresses the issue of pests. Animal pests, especially predators such as rodents, mustelids and possums have had a noticeable effect on the fauna of the forests and will continue to have adverse effects. These effects far outweigh those of logging or roading associated with the consent application. As long as pest control is part of the activities associated with the sustainable forest management, granting the consent is likely to have a more beneficial affect than not granting it. Clearly a condition requiring a declared level of pest control that exceeds that in the adjacent public conservation estate is required.

Size: The area of indigenous vegetation or habitat is 5 ha or more in size together with adjacent indigenous habitat is larger than 5ha; or in the case of natural wetlands is larger than 1 ha in size.

The forests named in the consent are vastly larger than the minimum size and are all adjacent to areas in the public conservation estate that are an order of magnitude larger still. Hence for this criteria, the forests covered by the consent application are "significant".

For reasons covered above, however, it is difficult to argue that the proposed activities associated with sustainable management will have adverse effects as there are no planned activities that will alter the size of the vegetation or habitat. Moreover, given that the presence of animal pests is the greatest threat to the area, as long as pest control is included, it is reasonable to argue that the effects will be beneficial.

     John L Craig,     Significance of Forest Areas.                                                                                   Page 5 of 7

Protected Status: The area has been set aside by statute or covenant for protection or preservation.

The forests in the application are Crown land set aside as indigenous production forests. There is a requirement that the forests are managed sustainably for the production of rimu and beech (Vol 1: 1-5). As mentioned above, the process of the West Coast Accord 1986 set aside areas for protection and preservation under the management of DoC whereas the forests covered by the application were set aside for sustainable management including logging.

Connectivity: The area is connected to one or more other significant areas in a way (through ecological processes) which make a major contribution to the overall functioning of those areas.

The forests in the consent application are contiguous with similar forests in the public conservation estate. In terms of ecological processes such as pollination, seed dispersal and bird movement, the forests are connected. Given that the proposed activities do not threaten this connectivity, it is not possible to argue that the functioning of the area will be threatened. Indeed if pest control is included as part of the sustainable forest management, connectivity will be enhanced.

The planned activities include the retention of major corridors. The minimal disturbance of riparian zones will retain import land and water connections. In addition, Timberlands have identified areas that will be reserved from production (Vol 1: 48 – 50; Vol 2: Appendix 6) and these may enhance connectivity between areas.

Threat: The area supports an indigenous species or community of species which is threatened within the ecological district or ecological region or threatened nationally.

The forests in the consent application do support a range of species which are recognised as locally and nationally threatened. Long tailed bats, South Island kokako, South Island kaka, great spotted kiwi, falcon, yellow crowned kakariki, two rare shrubs and three mistletoe species are especially relevant although other species are also present (see Vol 1: 13 – 17, 62). The issue is whether the proposed activities will adversely affect these species.

Proposed logging regimes will leave large beech trees as well as a range of trees of all sizes in order to leave nesting holes, roost sites and feeding areas. In addition the consent application lists other self imposed conditions to minimise effects on native fauna. Protection for trees with mistletoe and bat roosts is also considered and is more fully dealt with in my advice to Council on ecological effects.

     John L Craig,     Significance of Forest Areas.                                                                                   Page 6 of 7

The most important issue is not just the protection of habitat and habitat features believed necessary for threatened species but an integrated management that ensures survival of the threatened species as well. Introduced pests are the greatest threat for these species and it is valuable to ask what are the best options for sustaining these species rather than just protecting or preserving habitat. Given the measures proposed by the applicant plus the conditions proposed in my report on ecological aspects such as pest control, granting the consent will have a beneficial effect on the threatened species present in the forest. It is important to contrast this with the declared low level of national predator control on the public conservation estate (DoC 1998) and the acknowledged nationwide decline in biodiversity that is largely attributed to the presence of pests (Anon 1998).

Migratory Habitat: The area is important as habitat for significant migratory species or for reeding, breeding or other vulnerable stages of indigenous species, including indigenous freshwater fish.

The streams in the forests covered by this application do contain threatened and migratory fish. Birds such as cuckoo are present and are long distance migrants. Other species such as tui, bellbird, fantail and others will undertake shorter distance seasonal movements for food.

The proposed activities will not adversely affect these species. The proposed controls over activities associated with streams appear adequate to sustain fish habitat. The opening of greater canopy gaps and the associated increase in growth of more light demanding plants is more likely to enhance bird habitat slightly than be adverse. Addition of pest control as part of the sustainable forest management will benefit these birds.

Scientific or Cultural Value: The area is a scientific reference area, is listed as a geopreservation site, or has significant amenity value.

The area covered by the application to the best of my knowledge is not a scientific reference area and is not listed as a geopreservation site. Should the consent be granted, there is considerable scientific information to be gained on sustainable forest management. This information will be of both national and international interest.

Regarding amenity value, using the definition under S2 of the RMA, the forests do have "natural and physical qualities and characteristics that contribute to people's appreciation of its pleasantness, aesthetic coherence and cultural and recreational attributes". Having visited forest areas where helicopter extraction has occurred and reading the provisions for recreation (Vol 1: 107), I believe that the proposed activities will not result in adverse effects with respect to amenity values.

     John L Craig,     Significance of Forest Areas.                                                                                   Page 7 of 7


The beech forests included in this resource consent do include many characteristics that can allow the conclusion that they contain significant areas of vegetation and habitat. Timberlands have moved to identify the more important of these areas and proposes to reserve these from production (Vol 1: 48 – 50; Vol 2: Appendix 6). Rare species do occur in other forest areas where logging and roading is planned. Conditions suggested by Timberlands plus those outlined in my report on ecological effects should be adequate to ensure that effects are minor.

The most important issue with the protection of significant indigenous vegetation and significant habitats of indigenous fauna is to sustain both the species and the functional links between them. The greatest threat is from introduced predators and it is important that the Council ensures that adequate pest control is undertaken. Provided that this condition is imposed as part of granting this consent, the intent of S6c and Policy will be achieved. Moreover, this will be achieved more effectively than simply setting an area aside from sustainable management.


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

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