A state-owned enterprise, Timberlands West Coast Ltd. (TWC), proposed to sustainably manage beech forests on 0.1 million hectares of New Zealand's 2.8 million hectare beech forest estate. The scheme was to be reviewed by a Resource Management Act (RMA) commission hearing to establish whether or not it was sustainable in terms of the RMA, a scrutiny that would have been pivotal for the granting of a resource consent.

The New Zealand Labour Party adopted a policy against the scheme during September 1999, just weeks prior to gaining power (in coalition with the Alliance party) in a general election. Mr Jim Sutton, Labour party spokesman on forestry, immediately resigned his spokesmanship, and will no longer correspond on forestry matters.

One of the first acts of our new Labour/Alliance government (elected in November 1999) was to make TWC withdraw its application for consent for the beech scheme. This was achieved by removing sustainable beech management from TWC's mission statement. The action delighted some environmental groups, but dismayed other environmental groups and resource management professionals.

The Department of Conservation (DOC) prepared draft documents for presentation to the Commission, but the withdrawal of TWC from the hearing resulted in these documents not being presented. They have been obtained from DOC under the provisions of the Official Information Act, and have been re-typed and presented in these pages. Please note that the draft documents contained what appear to be typographical errors; they have been reproduced as obtained from DOC.

Resource Management Act 1991

Buller District Council and Tasman District Council
BDC Resource Consent Application 99/75
Timberlands West Coast Ltd
TDC Application : RM330361 & NN990491:TWC



1.1   My name is Philippe Jean Robert GERBEAUX. I have a PhD in Ecology and Resource Management from University of Canterbury and Lincoln college. have been employed by September 1995. Between 1992 and 1995, I was employed as a planner and scientist by "Station Biologique de la Tour du Valat", a French-based private research institute, reknown internationally for its contribution to the conservation of Mediterranean wetlands. Before that, from 1990, I was a scientist with DSIR Hydrology Centre. I was involved in research on river ecology and on aquatic habitat protection. In my present position I am responsible, amongst other things, for overseeing and co-ordinating the conservancy's wetland and freshwater fish conservation programmes.

1.2   My evidence will discuss the indigenous freshwater fisheries values and freshwater fish habitats of the Beech Forests proposed for sustainable logging. It will also discuss the potential impacts of the proposed activity on these values and habitats and highlights how instream values and riparian margins can be adequately managed and monitored.


2.1  I have reviewed the information supplied on fisheries in the Sustainable Management Beech Overview and am satisfied that, to the exception of the Maruia, the values associated with the working circles have been correctly identified.

2.2   Because the information contained in the Sustainable Management Beech Overview includes sites that are not covered by the current application, a revised set of data restricted to the areas covered by the application is presented in Tables 1, 2, 3 and 4 in order to facilitate further interpretation. The origin of the data is the same as that used by the applicant (National Freshwater Fish Database, NIWA).

2.3   Table 1 summarises the native fish species recorded from and adjacent to each forest in the Maruia, Inangahua and Grey working circles with an indication of their status (Category A - highest priority for conservation action, B or C - respectively second and third priority species for conservation). Their life-cycle characteristics (migratory/non-migratory) are also included in the table.

2.4   Tables 2, 3 and 4 contain the detailed data available on the distribution and abundance of all fish species found for all streams and rivers in and adjacent to the forests included in the working circles.

2.5   It can be seen that eight migratory native species and two non-migratory native species are present in the Grey working circle catchments. Seven migratory native species (including the rare migratory shortjawed kokopu) circle and two non-migratory native species have been found within the Inangahua working. Only five native fish species (three of them being non-migratory species) are present within the Maruia working circle.

2.6   This data confirms that the number and abundance of migratory (or diadromous) fish species decrease with altitude and distance from the sea, whereas the abundance of non-migratory (or non diadromous) species, especially dwarf galaxias and upland bully, increases with altitude and distance from the sea. This observation has been reported by several authors (e.g. Jowett, Richardson and McDowall 1996; McDowall 1998).

2.7   All diadromous species migrate between freshwater and the sea as a regular, often obligatory phase of their life cycles (a significant feature of New Zealand fish fauna) and thus require free, unimpeded access to and from it.

2.8   They penetrate long distances inland, constrained only by physical, chemical or other barriers to migration. For these species, the entire creek system, from the valley floor to the higher headwaters of the catchment comprise their habitat.

2.9   Threatened species were restricted to the Grey and Inangahua working circles (shortjawed kokopu and koaro) and were in relatively low numbrs (see Tables 1 and 2).

2.10   However, other threatened species not recorded in the database could be present in the working circles, most notably banded kokopu (Galaxias fasciatus, category C species) and brown mudfish (Neochanna apoda, category B species) in the Grey and Inangahua circles, and longjawed galaxias (Galaxias prognathus, Category C) in the Maruia circle. The later has been recorded from the Maruia River above Springs Junction.

2.11   Longfinned eel, an important species for customary and commercial fishing, is present throughout the working circles, sometimes in large quantities.

2.12   The same observation applies to the introduced trout.

2.13   Aquatic invertebrates are an important source of food for fish. Although these invertebrates have not been well studied in the areas under scrutiny, some data is available from two streams in the Maruia catchment.

2.14   The data showed that there were only slight differences in total invertebrate abundance between the two streams but showed contrast in sppecies richness in relation to the flood disturbance regime. (... Scarsbrook, pers. Com). This suggest that any monitoring should include representative sites reflecting variability associated with hydrological regimes (see?

2.15   It should be noted that the native crayfish or koura (Paranephrops planifrons) was also found at several sites.


3.1   The Department presently identifies three key areas for indigenous fish conservation: threats, vulnerable species, and harvested species.

   Under threats, there are three primary concerns ( in order):

      a   habitat loss,

      b   barriers to migration and

      c   alien species interactions.

3.2   While forest harvest and road building both have the potential to impact biodiversity values, only the second one is of concern to the department in relation to fish and fisheries and their habitat. It can cause undesirable changes when roading takes place along waterways and I seek appropriate conditions on any resource consents that may be granted to protect riparian and aquatic values.

3.3   As a basic principle the margins of all waterways require active managment and protection. Riparian areas need to be viewed as an integral part of the waterway itself. In their draft streamside management protocols Timberlands have identified three functions of riparian zones relevant to its operations: biodiversity and nature conservation, instream habitat enhancement and management and water quality management.

3.4   The more diverse the range of habitat types available the greater the diversity of plant and animal species present. Riparian protection can safeguard existing instream habitats and enhance diversity by providing shaded areas, overhanging vegetation, leaf litter and other energy inputs ( e.g. terrestrial invertebrates falling from overhanging vegetation), woody debris for instream cover and substrate for aquatic animals. Riparian protection also prevents excessive in put of sediment in to the waterways.

3.5   Habitat diversity can be reduced by the input of sediment. Sediment may directly smother and interfere with the respiration of invertebrates and fish, and change substrate character by infilling gaps and reducing habitat available and ecosystem diversity.

3.6   Vegetation along riparian margins is important for not only protection of water quality but also for the intrinsic worth of plants and as features of natural character. Carefully managed riparian margins can provide suitable habitat for both common and threatened indigenous plant species therefore improving both biodiversity and the natural character of the area.

3.7   The Department is currently reviewing a recently revised version of the applicants' stream management protocols. This revised version is the result of discussions with specialists from the West Coast Conservancy and with Fish and Game Council staff.

3.8   In the revised version, Timberlands has classified its streams into two categories: high and low priority. High priority streams are those which are:

3.9   High priority streams greater than 3 metres in width within the indigenous circles have the same conditions of management as marginal strips (refer to Section 10.5 of the Timberlands Environmental Manual) and a number of requirements must be adhered to. In high priority streams less than 3 metres in width, the width of the streamside management zone is to be agreed between DOC or Fish and Game and Timberlands as appropriate. Any differences are to be resolved by West Coast Regional Council. I seek this revision, once agreed by all parties, be adopted as part of the resource consent conditions.

3.10   The installation of culverts will ensure fish pasage for migratory species where road crossings are built. Such culverts may not be necessary for non-migratory species where these species occur their own (i.e. where migratory specie are absent) and where alien species are absent.

3.11  Both the few records of threatened fish species (see Table 2, 3 and 4) and their low abundance may be the result of inadequate fishing techniques (it has been recently discovered that shortjawed kokopu are better surveyed by spot lighting). It may also result from a lack of survey (especially in the case of the Maruia circle).

3.12   I recommend that further fish surveys should be carried out prior to any new roading in the Maruia working circle to compensate for the current lack of information (see Table 4), in particular with a view to determine whether the longjawed galaxias is present within the working circles.

3.13   The West Coast Conservancy is currently engaged in a shortjawed kokopu programme and endeavours to pass on any new information on the distribution of this species and that of other threatened species where it is thought the proposed activity may impact on the survival.


4.1   I wish to addrees here some concerns related to the proposed fish monitoring programme.

4.2   Timberlands proposes to monitor the waterways at only one site, in Granville Forest (located in the Grey District and so outside the scope of this application, but still within the TWCL operation of the Grey working circle).

4.3   I consider that this is insufficient considering that a very distinctive type of non-migratory fish communities prevails in the Maruia valley. I seek that a more comprehensive aquatic monitoring scheme be developed that can consequently provide greater confidence in the results obtained should any consents be granted. Sites within the Maruia beech forests, where the fish fauna charactistics differ, are required, given that Granville podocarp/beech forest contains communities of migratory fish species.

4.4   The monitoring programme should also acknowledge differences in flood disturbance regimes between streams as pointed out in 2.14.


5.1   A small isolated area of karst occurs in the lower Cave creek catchment in Pea Soup forest and has not been identified as a reserve in TWC's application. Cave stream exits the underground karst system at about the junction of Cave Creek and the un-named creek to the south. Either Cave Creek itself or the un-named creek could be the main source of the resurgence.

5.2   Karst areas can have both surface and subterranean values of scientific and conservation interest. In particular, the caves within karst act as time vaults, accumulating and preserving evidence of past ages and events which would rapidly be lost or destroyed in surface environments. Isolated karst area such as the one in Cave Creek can have values out of all proportion to their size simply by being the only sites in their area where such evidence has accumulated.

5.3   Karst areas are highly sensitive to surface disturbances such as logging and associated roading which can result in increases in sedimentation, and consequent increases in flood-pulse size and frequency within the cave systems. The consequence is erosion or destruction of accumulated values. Therefore a condition of any consents granted should be that the catchment of Cave Creek to the junction with the un-named branch to the south (about 150 ha as shown on the attached map) be excluded from logging.


6.1   The areas proposed for sustainable logging have distinctive fish and fisheries values that need to be recognised by the applicant and reflected in the conditions attached to the application.

6.2   major feature is the difference between the fish communities (migratory vs non-migratory) of the Grey working circleand those of the Maruia working circle (respectively).

6.3   Other values present in the Maruia working circle may have been under-estimated due to a lack of fish records from that area. I recommend additional fish surveys to be carried out in the streams located within this working circle.

6.4   I regard roading activities included in the application as a major threat to aquatic instream values.

6.5   However, the set of streamside management protocols currently revised by the applicant in liaison with the Department of Conservation and the Fish and Game Council should mitigate and/or remedy any detrimental effects and should therefore be adopted as part of the resource consent application.

6.6   I recommend that the freshwater monitoring programme be revisited to reflect the diversity of fish and fisheries values present in the different working circles.

6.7   Because of its high sensitivity and very special value, I recommend that the catchment of Cave Stream be excluded from logging.

7.         REFERENCES

7.1   Jowett, I.G., Richardson, J. and R.M. McDowall 1996. Relative effects of in-stream habitat and land-use on fish distribution and abundanec in tributaries of the Grey River, New Zealand. New Zealand Journal of Marine and Freshwater Research 30: 463-475.

7.2   McDowall, R.M. 1998. Fighting the flow: downstream-upstream linkages in the ecolgy of diadromous fish faunas in West Coast New Zealand rivers. Freshwater Biology 40: 111-122.



(NIWA fish database records)

Common name Scientific name Abbrev. Status Migratory Non-migratory Working circle
Lamprey o Geotria australis (LA) X G
Shortfinned eel Anguilla australis (SFE) X G, I
Longfinned eel Anguilla dieffenbachii (LFE) X G, I, M
Shortjawed kokopu o * Galaxias postvectis (SJK) A X I
Koaro o * Galaxias brevipinnis (KO) C X G, M
Common river galaxias Galaxias vulgaris (CRG) X M
Longjawed galaxias (Galaxias prognathus) (LJG) C X M
Dwarf galaxias Galaxias divergens (DG) X G, I, M
Torrent fish o Cheimarrichthus fosteri (TF) X G
Common bully Gobiomorphus cotidianus (CB) X G, I
Upland bully Gobiomorphus breviceps (UB) X G, I
Red-finned bully Gobiomorphus huttoni (RF) X G, I
Blue gilled bully Gobiomorphus hubbsi (BGB) X G

*        Juveniles of these species make up the whitebait catch.
o        Priority species for conservation action (see Molloy and Davis, 1992 - 2nd Edition Tisdall 1994)
         Working Circle Code: G = Grey, I = Inangahua, M = Maruia.

Note from transcriber: omitted at this stage from the transcription are,

  1.   Map 1, a topographical map, "Recommended Reserve to protect Karst Cave Creek Catchment, Pea Soup Forest.
  2.   Table 2: Grey Valley Working Circle, 4 pages of individual freshwater fish surveys, 129 records in all.
  3.   Table 3: Inangahua Working Circle, 1 page of individual freshwater fish surveys, 31 records in all.
  4.   Table 4: Maruia Working Circle, 1 page of individual freshwater fish surveys, 11 records in all.